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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, October 30, 2011, Vol. 15, No. 301

                            Headlines

AAR CORP: S&P Affirms 'BB' Corp. Credit Rating; Outlook Stable
ALLY MASTER: Moody's Assigns Definitive Ratings to Trust 2011-5
AMERICAN CREDIT: S&P Rates Class D Asset-Backed Notes 'BB'
AMERICREDIT AUTOMOBILE: Moody's Assigns (P)Ba2 to Class E Notes
AMERICREDIT AUTOMOBILE: S&P Gives 'BB+' Rating on Class E Notes

ANTARTICA CFO: S&P Keeps 'CCC-' Rating on Class E Notes
APHEX CAPITAL: S&P Puts 'CCC+' Ratings on 2 Tranches on Watch Neg
ARBOR REALTY: Fitch Affirms Junk Ratings on Six Note Classes
ARCAP 2004-1: Fitch Lowers Ratings on Seven Note Classes
BABSON MID-MARKET: Moody's Raises Rating of $15.5MM Notes to 'Ba2'

BRYANT PARK: S&P Withdraws 'CCC-' Rating on Class C Notes
CABELA'S CREDIT: Fitch Expects to Rate $6.8 Mil. Notes at 'BB+sf'
CGMT 2006-C5: Moody's Downgrades Rating of Cl. B Notes at 'Ba3'
CIFC FUNDING: Moody's Raises Rating of Class B-1L Notes to 'Ba1'
CIFC FUNDING: Moody's Upgrades Rating of $14.5-Mil. Notes to 'Ba1'

COMM 2005-C6: Moody's Affirms Cl. B Notes Rating at 'B3'
COMM 2011: Fitch Puts Rating on $5.99 Mil. Notes at 'BBsf'
COMM 2011-FL1: Moody's Assigns 'Ba2' Rating to Cl. F Notes
CREST EXETER: Fitch Affirms Junk Rating on Two Note Classes
CSFB 2002-CKN2: Moody's Affirms Rating of Cl. F Notes at 'B1'

DALTON CDO: S&P Lowers Ratings on 5 Classes of Notes to 'D'
E*TRADE ABS: S&P Lowers Rating on Class A-2 Notes to 'B'
EQUITABLE OF IOWA: Fitch Upgrades Rating on 8.42% to 'BB'
FIRST INVESTORS: S&P Gives 'BB' Rating on Class E Notes
FM LEVERAGED: Moody's Gives Caa2/LD Probability of Default Rating

FM LEVERAGED: Moody's Upgrades Rating of Class D Notes to 'Ba1'
GECMC 2002-1: Moody's Affirms Rating of Cl. J Notes at 'Ba1'
GMAC 1999-C3: Moody's Reviews B1 Cl. H Notes Rating for Downgrade
GOLDMAN SACHS: Fitch Affirms 'Bsf' Rating on Class F Certificate
GS MORTGAGE: Fitch Junks Rating on Five Notes Classes

GSC GROUP: Moody's Raises Rating of Class C Notes to 'Ba2'
GSC PARTNERS: Moody's Raises Rating of Class D Notes to 'Ba2'
GSC PARTNERS: Moody's Upgrades Rating of Class E Notes to 'Ba3'
HARRISBURG PARKING: Moody's Reviews 'Ba3' Rating of Series T Bonds
HARTFORD MEZZANINE: S&P Lowers Rating on Class J to 'CCC-'

HIGHLAND PARK: Moody's Downgrades Rating of Cl. A-1 Notes to 'B3'
INA CBO: S&P Lowers Rating on Class A-3 Notes to 'D'
INDYMAC MORTGAGE: S&P Raises Rating on Class A-1 to 'CCC'
JPMCC 2005-CIBC11: Moody's Affirms Class F Notes Rating at 'Ba1'
KATONAH VIII: S&P Raises Rating on Class D Notes to 'CCC+'

KINDER MORGAN: S&P Puts 'BB' Rating on $10.574MM Certs. on Watch
LIBERTY CLO: S&P Raises Rating on Class C Notes to 'B+'
LNR CDO: S&P Affirms Ratings on 5 Classes at 'CCC-'
MIAMI-DADE FINANCE: Moody's Confirms B3 Ratings of 2006B-2 Bonds
MONTEBELLO: Moody's Assigns Mig 2 Rating to $2.5 Million Trans

MORGAN STANLEY: Fitch Junks Rating on Five Note Classes
MRU STUDENT: S&P Cuts Rating on Class D Notes From 'CCC-' to 'CC'
MSC 2006-SRR2: S&P Lowers Ratings on 3 Classes of Notes to 'D'
MSC 2007-HQ11: Moody's Affirms Rating of Cl. B Notes at 'Ba1'
N-45 FIRST DBRS Lifts Series 2003-3 Class F Rating From 'B'

N-45 FIRST: DBRS Upgrades Series 2003-3 Class F From 'B'
N-STAR REAL: Fitch Junks Rating on Six Note Classes
NATIONAL COLLEGIATE: S&P Cuts Ratings on 2 Note Classes to 'CC'
NATIONAL COLLEGIATE: S&P Cuts Ratings on 2 Classes of Notes to 'D'
PINE CCS: S&P Withdraws Ratings on 2 Classes From 'D'

PREFERREDPLUS TRUST: S&P Puts 'BB' Ratings 2 Classes on Watch
SCHOONER 2007-7: Moody's Affirms Rating of Cl. F Notes at 'Ba1'
SLM STUDENT: Fitch Affirms Rating on Class B Notes at 'BBsf'
TRAINER WORTHAM: S&P Lowers Rating on Class B Notes to 'CCC-'
TRICADIA CDO: S&P Raises Rating on Class A-4L Notes to 'B'

UBS AG: Moody's Raises Rating of Series 2760 Notes to 'B3'
WELLS FARGO: Fitch to Rate Two Note Classes at Low-B
WFCMT 2010-C1: Moody's Affirms Cl. E Notes Rating at 'Ba2'

* S&P Lowers Ratings on 4 Classes of Notes from 3 U.S. CDOs to 'D'
* S&P Lowers Ratings on 15 Tranches from 7 CDOs From 'CC' to 'D'
* S&P Lowers Ratings on 421 Classes from 99 U.S. RMBS Transactions
* S&P Lowers Ratings on 438 Classes of Pass-through Certs. to 'D'



                            *********



AAR CORP: S&P Affirms 'BB' Corp. Credit Rating; Outlook Stable
--------------------------------------------------------------
Standard & Poor's Ratings Services affirmed its 'BB' corporate
credit rating on AAR Corp. The outlook is stable.

At the same time, Standard & Poor's lowered the issue-level rating
on the company's unsecured debt to 'BB-' from 'BB' and revised the
recovery rating to '5' from '4'.

On Oct. 21, 2011, AAR Corp. announced the proposed acquisition of
Telair International GmbH and Nordisk Aviation Products AS (both
not rated) from Teleflex Inc. ('BB/Positive') for $280 million,
its largest acquisition to date. The company will finance the
purchase with borrowings under its unrated revolving credit
facility, which it recently increased to $580 million from
$400 million.

"The increased debt will result in modest deterioration in credit
protection measures," said Standard & Poor's credit analyst
Christopher DeNicolo. However, "we believe that strength in the
commercial aerospace market will result in growing earnings and
that ratios could return to current levels in the next 12-18
months," he continued.

AAR is a major independent provider of aviation support services
and operates in four business segments: aviation supply chain;
government and defense services; maintenance, repair, and
overhaul; and structures and systems.

"The acquisition will somewhat improve the company's position as a
supplier to commercial aircraft manufacturers and enable it to
benefit from increasing production rates," Mr. DeNicolo said.
Telair produces cargo loading systems for widebody (including the
new Boeing 747-8F) and narrowbody aircraft, complementing AAR's
business making similar systems for military aircraft. Nordisk
produces pallets and cargo containers for commercial airlines.


ALLY MASTER: Moody's Assigns Definitive Ratings to Trust 2011-5
---------------------------------------------------------------
Moody's Investors Service has assigned definitive ratings to the
Series 2011-5 notes (Notes) to be issued by Ally Master Owner
Trust (AMOT 2011-5). The Notes are collateralized primarily by
dealer floorplan loans extended by Ally Bank, a subsidiary of Ally
Financial Inc., to franchised new car dealers associated with
General Motors and Chrysler brands.

The complete rating action is:

$600,000,000, Class A Asset Backed Notes, rated Aaa (sf)

$29,577,000, Class B Asset Backed Notes, rated Aa2 (sf)

$46,479,000, Class C Asset Backed Notes, rated A2 (sf)

$33,803,000, Class D Asset Backed Notes, rated Baa2 (sf)

RATINGS RATIONALE

Moody's said the ratings are based on an assessment of the quality
of the underlying auto dealer floorplan receivables, the legal
structure and structural provisions, the manufacturers which the
transaction is primarily exposed to (General Motors and Chrysler),
the experience of Ally Financial Inc. as servicer, and the
experience of Wells Fargo Bank, National Association as back-up
servicer.

The quality of the floorplan receivables was considered based upon
a number of characteristics. A primary consideration is the
strength of the manufacturers and the vehicles that the
dealerships and the receivables have exposure. Moody's also
considered the size of the dealership base that is part of Ally
Master Owner Trust, the dealer credit rating distribution
according to Ally Bank's proprietary dealer credit evaluation
system, the age distribution of the receivables, and the overall
trust monthly payment rate. Vehicle values under stressed
scenarios were also a consideration in Moody's analysis.

The principal methodology used in this rating was "Moody's
Approach to Rating U.S. Floorplan ABS Securities" published in
January 2010.

In Moody's simulation analysis Moody's assumed that General Motors
was a B2, three notches below its current rating of Ba2, and that
Chrysler experienced a liquidation bankruptcy scenario. Chrysler
is currently rated B2. The simulation analysis incorporated a
stressed average dealer default rate of 50%. Moody's primary
assumptions for recovery rates of repossessed cars from defaulted
dealers was 72% for new cars and 67% for used cars. Moody's Aaa
Level for AMOT 2011-5 is 30%.

The V Score for this transaction is Medium, which is equal to the
Medium V score assigned for the U.S. Dealer Floorplan Loan ABS
sector. The V Score indicates "Medium" uncertainty about critical
assumptions such as dealer default probabilities and recovery
rates. Volatility of performance based on loss experience is low,
but historical data does not include key variables such as payment
rates, recoveries and dealer defaults during a stressed,
disorganized manufacturer bankruptcy scenario. Given that, Moody's
feels the level of historical data is only a moderate predictor of
future performance of a stressed environment. Additionally,
although floorplan transaction structures are typically straight-
forward, the credit risk characteristics are reasonably complex.
Therefore, despite low loss experience for the sector, the V Score
for this transaction reflects the Sector score of Medium.

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: Moody's simulation analysis
reveals Class A sensitivity down to the Baa level when dealer
defaults are increased to 65% and recovery rates are stressed an
additional 15%. The Class B rating shows sensitivity down to the
Ba level with dealer defaults up to 60% and recovery rates
stressed an additional 15%. The Class C rating shows sensitivity
down to the B level with dealer defaults up to 60% and a recovery
rate haircut of 5%. The Class D rating shows sensitivity down to
the B level with a recovery rate haircut of 5% and the initial
stressed average dealer default rate of 50%. This Parameter
Sensitivity is based upon the expected amount of enhancement in
AMOT 2011-5 at closing and does not include potential additions to
credit enhancement due to payment rate triggers that are included
with the transaction.

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.


AMERICAN CREDIT: S&P Rates Class D Asset-Backed Notes 'BB'
----------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings
to American Credit Acceptance Receivables Trust 2011-1's
$100.00 million asset-backed notes.

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

The ratings reflect S&P's view of:

    "The availability of approximately 38.98%, 36.49%, 30.17%, and
    25.25% of credit support for the class A-3, B, C, and D notes
    based on break-even stressed cash flow scenarios (including
    excess spread), which provide approximately 2.0x, 1.85x,
    1.50x, and 1.25x our expected net loss range of 19.00%-19.50%
    for the class A-3, B, C, and D notes," S&P related;

    "The timely interest and principal payments made to the rated
    notes by the assumed legal final maturity dates under our
    stressed cash flow modeling scenarios that we believe are
    appropriate for the assigned ratings," S&P said;

    "Our expectation that under a moderate, or 'BBB' stress
    scenario, the ratings on the class A-3 and B notes would
    remain within one rating category of our 'A+ (sf)' and 'A
    (sf)' ratings," S&P related;

    The collateral characteristics of the subprime automobile
    loans securitized in this transaction, including the 10 months
    of seasoning;

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

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

    The transaction's legal structure.

              Standard & Poor's 17g-7 Disclosure Report

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

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

    http://standardandpoorsdisclosure-17g7.com/1111193.pdf

Ratings Assigned
American Credit Acceptance Receivables Trust 2011-1


Class   Rating       Type            Interest          Amount
                                     rate         (mil. $)(i)
A-1     A+ (sf)      Senior          2.42               32.20
A-2     A+ (sf)      Senior          3.56               40.20
A-3     A+ (sf)      Senior          4.13                7.40
B       A (sf)       Subordinate     4.66                3.40
C       BBB (sf)     Subordinate     6.62                9.27
D       BB (sf)      Subordinate     8.07                7.53


AMERICREDIT AUTOMOBILE: Moody's Assigns (P)Ba2 to Class E Notes
---------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to the
notes to be issued by AmeriCredit Automobile Receivables Trust
2011-5 (AMCAR 2011-5). This is the fifth senior/subordinated
transaction of the year for AmeriCredit Financial Services, Inc.
(AmeriCredit).

The complete rating actions are:

Issuer: AmeriCredit Automobile Receivables Trust 2011-5

Class A-1 Notes, rated (P) Prime-1 (sf);

Class A-2 Notes, rated (P) Aaa (sf);

Class A-3 Notes, rated (P) Aaa (sf);

Class B Notes, rated (P) Aa1 (sf);

Class C Notes, rated (P) A1 (sf);

Class D Notes, rated (P) Baa2 (sf);

Class E Notes, rated (P) Ba2 (sf);

RATINGS RATIONALE

Moody's said the ratings are based on the quality of the
underlying auto loans and their expected performance, the strength
of the structure, the availability of excess spread over the life
of the transaction, the experience and expertise of AmeriCredit
Financial Services, Inc. (AmeriCredit) as servicer, and the backup
servicing arrangement with Aa3-rated Wells Fargo Bank, N.A.

The principal methodology used in this rating was "Moody's
Approach to Rating U.S. Auto Loan-Backed Securities," published in
May 2011.

Moody's median cumulative net loss expectation for the AMCAR 2011-
5 pool is 11.0% and total credit enhancement required to achieve
Aaa rating (i.e. Aaa proxy) is 40.0%. The loss expectation was
based on an analysis of AmeriCredit's portfolio vintage
performance as well as performance of past securitizations, and
current expectations for future economic conditions.

The Assumption Volatility Score for this transaction is Low/Medium
versus a Medium for the sector. This is driven by the Low/Medium
assessment for Governance due to the strong back-up servicing
arrangement present in this transaction in addition to the size
and strength of AmeriCredit's servicing platform.

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 the net loss used in
determining the initial rating were changed to 20%, 25% or 35.0%,
the initial model output for the Class A notes might change from
Aaa to Aa1, Aa2, and Baa1, respectively; Class B notes might
change from Aa1 to Baa1, Ba1, and below B3, respectively; Class C
notes might change from A1 to Ba2, B3, and below B3, respectively;
Class D notes might change from Baa2 to below B3 in all three
scenarios; and Class E notes might change from Ba2 to below B3 in
all three scenarios.

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.


AMERICREDIT AUTOMOBILE: S&P Gives 'BB+' Rating on Class E Notes
---------------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to AmeriCredit Automobile Receivables Trust 2011-5's
$900 million automobile receivables-backed notes.

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

The preliminary ratings are based on information as of Oct. 24,
2011. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflect:

    "The availability of approximately 44.1%, 39.0%, 32.3%, 25.9%,
    and 23.2% credit support for the class A, B, C, D, and E notes
    (based on stressed cash-flow scenarios, including excess
    spread), which provide coverage of more than 3.50x, 3.00x,
    2.55x, 1.75x, and 1.60x our 11.75%-12.25% expected cumulative
    net loss range for the class A, B, C, D, and E notes. These
    credit support levels are commensurate with the assigned
    preliminary 'AAA (sf)', 'AA (sf)', 'A+ (sf)', 'BBB (sf)', and
    'BB+ (sf)' ratings on the class A, B, C, D, and E notes," S&P
    related.

    "Our expectation that under a moderate, or 'BBB', stress
    scenario, our ratings on the class A, B, and C notes will
    remain within one rating category of the preliminary ratings
    (all else being equal) during the first year. This is within
    the one-category tolerance for 'AAA (sf)' and 'AA (sf)' rated
    securities and within the two-category tolerance for 'A (sf)'
    rated securities, as outlined in our credit stability criteria
    (see 'Methodology: Credit Stability Criteria,' published May
    3, 2010). In addition, under this moderate stress scenario, we
    expect that our ratings on the class D and E notes will remain
    within the two-category tolerance for 'BBB (sf)' and 'BB (sf)'
    rated securities over the first year," S&P noted.

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

    The timely interest and ultimate principal payments made under
    the stressed cash-flow modeling scenarios, which are
    consistent with the assigned preliminary ratings.

    The collateral characteristics of the securitized pool of
    subprime auto loans.

    General Motors Financial Co. Inc.'s (GM Financial, formerly
    known as AmeriCredit Corp.; B+/Stable/--) extensive
    securitization performance history since 1994. On March 30,
    2011, Standard & Poor's raised its long-term counterparty
    credit rating on GM Financial to 'B+' from 'B' and removed the
    rating from CreditWatch positive, where S&P placed it on Oct.
    8, 2010.

    The transaction's payment and legal structures.

          Standard & Poor's 17g-7 Disclosure Report

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

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

    http://standardandpoorsdisclosure-17g7.com/1111222.pdf

Preliminary Ratings Assigned
AmeriCredit Automobile Receivables Trust 2011-5

Class    Rating        Type            Interest        Amount
                                       rate(i)       (mil. $)
A-1      A-1+ (sf)     Senior          Fixed          147.300
A-2      AAA (sf)      Senior          Fixed          344.600
A-3      AAA (sf)      Senior          Fixed          145.983
B        AA (sf)       Subordinate     Fixed           69.231
C        A+ (sf)       Subordinate     Fixed           85.943
D        BBB (sf)      Subordinate     Fixed           84.510
E(ii)    BB+ (sf)      Subordinate     Fixed           22.433

(i)The actual coupons of these tranches will be determined on the
pricing date. (ii)Class E will be privately placed and is not
included in the public offering amount. NR--Not rated.


ANTARTICA CFO: S&P Keeps 'CCC-' Rating on Class E Notes
-------------------------------------------------------
Standard & Poor's Ratings Services withdrew its rating on the
class A notes from Antarctica CFO I Ltd., a U.S. collateralized
fund obligation (CFO) transaction backed by a diversified
pool of hedge funds, following the class' full paydown on Oct. 17,
2011.

Rating Withdrawn

Antarctica CFO I Ltd.
                      Rating
Class              To         From
A                  NR         AA (sf)

NR -- Not rated.

Other Ratings Outstanding

Antarctica CFO I Ltd.
Class              Rating
B                  A- (sf)
C                  B+ (sf)
D                  CCC (sf)
E                  CCC- (sf)


APHEX CAPITAL: S&P Puts 'CCC+' Ratings on 2 Tranches on Watch Neg
-----------------------------------------------------------------
Standard & Poor's Ratings Services placed its ratings on two
tranches from Aphex Capital NSCR 2007-5 Ltd., a synthetic
collateralized debt obligation (CDO) transaction backed by
commercial mortgage-backed securities (CMBS) on CreditWatch
with negative implications.

The CreditWatch negative placements reflect negative rating
migration in the portfolio and a synthetic rated
overcollateralization (SROC) ratio that has fallen below 100% as
of the September month-end run.

Rating And CreditWatch Actions

Aphex Capital NSCR 2007-5 Ltd.
                    Rating
Class       To                      From
A-1FL       CCC+ (sf)/Watch Neg     CCC+ (sf)
A-1FX       CCC+ (sf)/Watch Neg     CCC+ (sf)


ARBOR REALTY: Fitch Affirms Junk Ratings on Six Note Classes
------------------------------------------------------------
Fitch Ratings has affirmed all classes of Arbor Realty Mortgage
Securities series 2006-1 Ltd/LLC (ARMSS 2006-1) reflecting Fitch's
slightly improved base case loss expectation of 26.7% compared
to 28.2% at last review.  Fitch's performance expectation
incorporates prospective views regarding commercial real estate
market values and cash flow declines.

Since last review, six loans were disposed of with realized losses
totaling approximately $6.9 million.  Further, three new loans
were contributed as well as investments in loans already held by
the CDO; building par by an estimated $3.5 million.  The CDO exits
its reinvestment period in January 2012.  While the CDO currently
holds approximately $36 million in uninvested proceeds, those
funds are expected to be fully redeployed into new assets by the
end of the reinvestment period.

As of the September 2011 trustee report and per Fitch
categorizations, the collateral pool consists of 77% whole loans
and A-notes, 11% B-notes, 4% mezzanine debt, 2% preferred equity,
and 6% uninvested principal proceeds.  There are 4.8% defaulted
assets and 19.8% Fitch loans of concern, which are in line with
the totals at last review of 4.8% and 22.4%.

ARMSS 2006-1 is managed by Arbor Realty Collateral Management,
LLC. As of the September 2011 trustee report, all par value and
interest coverage test are in compliance.

Under Fitch's surveillance methodology, approximately 78.3% 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 6.9% from the most recent available cash
flows (generally year-end 2010 or trailing 12 months [TTM] first
quarter 2011).  Fitch estimates that average recoveries will be
better than average at 65.9% due to the significant portion of
senior debt in the pool.

The largest component of Fitch's base case loss expectation is an
A-note (10.2%) secured by a large student housing property located
on the Upper East Side of Manhattan.  In 2011, the master tenant
cancelled its master lease obligation for the entire property and
now directly leases only a portion of the space.  While the
borrower has successfully leased the property to 87%, cash flow is
still significantly below expectations.  Fitch modeled a term
default and a substantial loss on this position in its base case
scenario.

The next largest component of Fitch's base case loss expectation
is related to an A-note (7.3%) secured by a portfolio of six full
and limited service hotels located in Daytona Beach, FL.  The
portfolio was previously in bankruptcy, and an Arbor affiliate
took title to the properties in February 2011.  Fitch modeled a
term default and a substantial loss on this A-note in its base
case scenario.

The third largest component of Fitch's base case loss expectation
is related to a defaulted whole loan (4.1%) secured by 22.8 acres
of waterfront land located in Jacksonville, FL.  Due to the
economic downtown, plans for a mixed use development have stalled.
Fitch modeled a substantial loss on this 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'.
Based on this analysis, the breakeven rates for classes A-1
through C are generally consistent with the ratings assigned
below. Stable Rating Outlooks are assigned to classes A-1 through
A-2 reflecting their senior position in the capital structure and
adequate cushion in the cash flow modeling.  Class B and C
maintain a Negative Rating Outlook reflecting Fitch's expectation
of further potential negative credit migration of the underlying
collateral.

The 'CCC' ratings for classes D through H are based on a
deterministic analysis that considers Fitch's base case loss
expectation for the pool and the current percentage of defaulted
assets and Fitch Loans of Concern factoring in anticipated
recoveries relative to each class' credit enhancement.  These
classes were assigned Recovery Ratings (RR) in order to provide a
forward-looking estimate of recoveries on currently distressed or
defaulted structured finance securities.

Fitch has affirmed these classes and revised Outlooks as
indicated:

  -- $230,000,000 class A1-A at 'BBBsf'; Outlook to Stable from
     Negative;

  -- $100,000,000 class A-1R at 'BBBsf'; Outlook to Stable from
     Negative;

  -- $72,900,000 class A-2 at 'BBsf'; Outlook to Stable from
     Negative;

  -- $41,100,000 class B at 'BBsf'; Outlook Negative;
  -- $31,200,000 class C at 'Bsf'; Outlook Negative;
  -- $13,350,000 class D at 'CCCsf/RR5';
  -- $14,250,000 class E to 'CCCsf/RR6' from 'CCCsf/RR5';
  -- $13,650,000 class F at 'CCCsf/RR6';
  -- $16,950,000 class G at 'CCCsf/RR6';
  -- $14,100,000 class H at 'CCCsf/RR6'.


ARCAP 2004-1: Fitch Lowers Ratings on Seven Note Classes
--------------------------------------------------------
Fitch Ratings has downgraded seven and affirmed three classes
issued by ARCap 2004-1 Resecuritization, Inc. (ARCap 2004-1) as a
result of significant negative credit migration on the underlying
collateral.

Since Fitch's last rating action in November 2010, approximately
51.6% of the underlying collateral has been downgraded.
Currently, 97.1% of the portfolio has a Fitch derived rating below
investment grade and 56.5% has a rating in the 'CCC' category and
below, compared to 96.8% and 44.8% at the last review.  As of the
Sept. 16, 2011 trustee report, 42.1% of the underlying collateral
is considered defaulted per the transaction documents, compared to
23.6% at the prior review.

This transaction was analyzed under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Portfolio Credit Model (PCM) for projecting future default
levels for the underlying portfolio.  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'.  Fitch also analyzed the
structure's sensitivity to the assets that are distressed,
experiencing interest shortfalls, and those with near term
maturities.  Based on this analysis, the class A through D notes'
breakeven rates are generally consistent with the ratings assigned
below.

For the class E through K notes, Fitch analyzed each class'
sensitivity to the default of the distressed assets ('CCC' and
below).  As of the Sept. 22, 2011 payment date, the class E notes
received their entire interest payment while the class F notes
received approximately 71.2% of their interest payment.  Given the
high probability of default of the underlying assets and the
expected limited recovery prospects upon default, the class E and
F notes have been downgraded to 'CCsf', indicating that default is
probable.  Similarly, the class G through K notes are deferring
their entire interest payments.  Thus, the class G notes have been
downgraded and the class H through K notes affirmed at 'Csf',
indicating that default is inevitable.

The Negative Outlook on the class A and B notes reflects the
potential for further deterioration on the underlying collateral,
especially given the obligor concentration. Fitch does not assign
Outlooks to classes rated 'CCC' and below.

ARCAP 2004-1 is backed by 58 tranches from 16 CMBS transactions
and is considered a CMBS B-piece resecuritization (also referred
to as first loss CRE CDO/ReREMIC) as it includes the most junior
bonds of CMBS transactions. The transaction closed April 19, 2004.

Fitch has downgraded these classes as indicated:

  -- $45,480,874 class A notes to 'BBsf' from 'BBBsf'; Outlook
     Negative;
  -- $30,600,000 class B notes to 'Bsf' from 'BBsf'; Outlook
     Negative;
  -- $26,500,000 class C notes to 'CCCsf' from 'Bsf';
  -- $8,500,000 class D notes to 'CCCsf' from 'Bsf';
  -- $30,700,000 class E notes to 'CCsf' from 'CCCsf';
  -- $13,600,000 class F notes to 'CCsf; from 'CCCsf';
  -- $36,000,000 class G notes to 'Csf' from 'CCsf'.

Fitch has affirmed these classes as indicated:

  -- $13,000,000 class H notes at 'Csf';
  -- $31,500,000 class J notes at 'Csf';
  -- $20,500,000 class K notes at 'Csf'.


BABSON MID-MARKET: Moody's Raises Rating of $15.5MM Notes to 'Ba2'
------------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Babson Mid-Market CLO Ltd. 2007-II:

US$249,600,000 Class A-l Senior Notes Due 2021 (current
outstanding balance of $241,436,339), Upgraded to Aaa (sf);
previously on June 22, 2011 Aa1 (sf) Placed Under Review for
Possible Upgrade;

US$4,400,000 Class A-2B Senior Notes Due 2021, Upgraded to Aaa
(sf); previously on June 22, 2011 Aa2 (sf) Placed Under Review for
Possible Upgrade;

US$23,000,000 Class B Senior Notes Due 2021, Upgraded to Aa2 (sf);
previously on June 22, 2011 Aa3 (sf) Placed Under Review for
Possible Upgrade;

US$27,000,000 Class C Deferrable Mezzanine Notes Due 2021,
Upgraded to A2 (sf); previously on June 22, 2011 A3 (sf) Placed
Under Review for Possible Upgrade;

US$18,750,000 Class D Deferrable Mezzanine Notes Due 2021,
Upgraded to Baa2 (sf); previously on June 22, 2011 Baa3 (sf)
Placed Under Review for Possible Upgrade;

US$15,500,000 Class E Deferrable Mezzanine Notes Due 2021,
Upgraded to Ba2 (sf); previously on June 22, 2011 Ba3 (sf) Placed
Under Review for Possible Upgrade;

US$5,000,000 Combination Notes Due 2021 (current Rated Balance of
$3,321,507), Upgraded to A3 (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.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $410.0 million,
defaulted par of $4.8 million, a weighted average default
probability of 26.99% (implying a WARF of 3311), a weighted
average recovery rate upon default of 49.72%, and a diversity
score of 79. 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 Mid-Market CLO Ltd. 2007-II, issued in April 2007, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans with significant exposure to middle market
loans.

The principal methodology used in this rating was "Moody's
Approach to Rating Collateralized Loan Obligations" published in
June 2011. In addition, the methodology "Using the Structured Note
Methodology to Rate CDO Combo-Notes" published in February 2004
was also used.

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) 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.

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.


BRYANT PARK: S&P Withdraws 'CCC-' Rating on Class C Notes
---------------------------------------------------------
Standard & Poor's Ratings Services withdrew its ratings on nine
classes of notes from three U.S. collateralized debt obligation
(CDO) transactions.

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

Bryant Park CDO Ltd., a collateralized loan obligation (CLO)
transaction, paid down the class A-1, A-2, B, and C notes in full
following a notice of optional redemption. The Sept. 30, 2011,
notice indicated that at least a majority of the income notes had
directed a full redemption of all outstanding notes. The
transaction paid down the class A-1, A-2, B, and C notes in full
on the Oct. 17, 2011, payment date from outstanding balances of
$2.57 million, $28.00 million, $30.00 million, and $21.00 million.

Longhorn CDO III Ltd., a CLO transaction, paid down the class
A-1 notes in full on the Oct. 11, 2011, payment date, from the
$9.98 million outstanding balance.

"On Aug. 2, 2011, we placed our ratings on the class C, D-1, and
D-2 notes from NYLIM Flatiron CLO 2003-1 Ltd. (a CLO transaction)
on CreditWatch with positive implications.  On Sept. 21, 2011, we
received a noticed indicating that at least a majority of the
preference shares had directed a full redemption on the notes.
The transaction paid down the class B, C, D-1, and D-2 notes
in full on the Oct. 18, 2011, payment date from outstanding
balances of $7.17 million, $17.50 million, $11.63 million, and
$11.17 million," S&P related.

Ratings Withdrawn

Bryant Park CDO Ltd.
                            Rating
Class               To                  From
A-1                 NR                  AAA (sf)
A-2                 NR                  A+ (sf)
B                   NR                  BB+ (sf)
C                   NR                  CCC- (sf)

Longhorn CDO III Ltd.
                            Rating
Class               To                  From
A-1                 NR                  AAA (sf)


NYLIM Flatiron CLO 2003-1 Ltd.
                            Rating
Class               To                  From
B                   NR                  AAA (sf)
C                   NR                  AA (sf)/Watch Pos
D-1                 NR                  BB+ (sf)/Watch Pos
D-2                 NR                  BB+ (sf)/Watch Pos

NR -- Not rated.


CABELA'S CREDIT: Fitch Expects to Rate $6.8 Mil. Notes at 'BB+sf'
-----------------------------------------------------------------
Fitch Ratings expects to assign these ratings to Cabela's Credit
Card Master Note Trust's asset-backed notes, series 2011-IV:

  -- $212,500,000 cass A fixed/floating-rate 'AAAsf'; Outlook
     Stable;
  -- $20,000,000 class B fixed-rate 'A+sf'; Outlook Stable;
  -- $10,625,000 cass C fixed-rate 'BBB+sf'; Outlook Stable;
  -- $6,875,000 class D fixed-rate 'BB+sf'; Outlook Stable.

Fitch's expected ratings are based on the underlying receivables
pool, available credit enhancement, World's Foremost Bank's
underwriting and servicing capabilities, and the transaction's
legal and cash flow structures, which employ early redemption
triggers.

The transaction structure is similar to series 2011-II, with
credit enhancement totaling 15% for class A, credit enhancement of
7% for the class B, credit enhancement of 2.75% plus an amount
from a spread account for the class C, and credit enhancement of
an amount from a spread account for the class D notes only.


CGMT 2006-C5: Moody's Downgrades Rating of Cl. B Notes at 'Ba3'
---------------------------------------------------------------
Moody's Investors Service (Moody's) confirmed one class, affirmed
11 classes and downgraded eight classes of Citigroup Commercial
Mortgage Trust, Commercial Mortgage Pass-Through Certificates,
Series 2006-C5:

Cl. A-2, Affirmed at Aaa (sf); previously on Jan 16, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-3, Affirmed at Aaa (sf); previously on Jan 16, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-SB, Affirmed at Aaa (sf); previously on Jan 16, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on Jan 16, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-1A, Affirmed at Aaa (sf); previously on Jan 16, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-M, Confirmed at Aaa (sf); previously on Oct 13, 2011 Aaa
(sf) Placed Under Review for Possible Downgrade

Cl. A-J, Downgraded to Baa3 (sf); previously on Oct 13, 2011 Baa1
(sf) Placed Under Review for Possible Downgrade

Cl. B, Downgraded to Ba3 (sf); previously on Oct 13, 2011 Baa3
(sf) Placed Under Review for Possible Downgrade

Cl. C, Downgraded to B2 (sf); previously on Oct 13, 2011 Ba1 (sf)
Placed Under Review for Possible Downgrade

Cl. D, Downgraded to Caa1 (sf); previously on Oct 13, 2011 Ba3
(sf) Placed Under Review for Possible Downgrade

Cl. E, Downgraded to Caa2 (sf); previously on Oct 13, 2011 B1 (sf)
Placed Under Review for Possible Downgrade

Cl. F, Downgraded to Ca (sf); previously on Oct 13, 2011 Caa1 (sf)
Placed Under Review for Possible Downgrade

Cl. G, Downgraded to C (sf); previously on Oct 13, 2011 Caa2 (sf)
Placed Under Review for Possible Downgrade

Cl. H, Downgraded to C (sf); previously on Oct 13, 2011 Caa3 (sf)
Placed Under Review for Possible Downgrade

Cl. J, Affirmed at C (sf); previously on Jan 13, 2011 Downgraded
to C (sf)

Cl. XC, Affirmed at Aaa (sf); previously on Jan 16, 2007
Definitive Rating Assigned Aaa (sf)

Cl. XP, Affirmed at Aaa (sf); previously on Jan 16, 2007
Definitive Rating Assigned Aaa (sf)

Cl. AMP-1, Affirmed at Baa2 (sf); previously on Mar 25, 2010
Confirmed at Baa2 (sf)

Cl. AMP-2, Affirmed at Baa3 (sf); previously on Mar 25, 2010
Confirmed at Baa3 (sf)

Cl. AMP-3, Affirmed at Ba1 (sf); previously on Mar 25, 2010
Confirmed at Ba1 (sf)

RATINGS RATIONALE

The downgrades are due to higher expected losses from specially
serviced and troubled loans along with increased realized losses
to the trust. The confirmation and 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.

On October 12, 2011 Moody's placed nine classes on review for
possible downgrade. This action concludes Moody's review.

Moody's rating action reflects a cumulative base expected loss of
7.5% of the current balance. At last full review, Moody's
cumulative base expected loss was 5.2%. Moody's stressed scenario
loss is 19.0% of the current balance. 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 principal 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
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 48 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 January 13, 2011.

DEAL PERFORMANCE

As of the October 17, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 9% to $2.04 billion
from $2.24 billion at securitization. The Certificates are
collateralized by 190 mortgage loans ranging in size from less
than 1% to 6% of the pool, with the top ten loans representing 31%
of the pool. One loan, representing 4% of the pool, has a credit
estimate. One loan, representing 0.7% of the pool, has defeased
and is secured by U.S. Government securities.

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

Seventeen loans have been liquidated from the pool since
securitization, resulting in an aggregate of $60.6 million (57%
loss severity). These losses have resulted in the elimination of
Classes K through P and a 61% principal loss for Class J.

Currently 17 loans, representing 13% of the pool, are in special
servicing. The largest specially serviced loan is the 220 Virginia
Avenue Loan ($70.0 million -- 3.6% of the pool), which is secured
by a 562K square foot (SF) office property located in
Indianapolis, Indiana. The loan was transferred to special
servicing in April 2011 due to imminent default and the loan
matured in July 2011. The remaining 16 specially serviced loans
are secured by a mix of property types. The master servicer has
recognized appraisal reductions totaling $47.6 million for the
specially serviced loans. Moody's has estimated an aggregate
$61.4 million loss (29% expected loss on average) for the
specially serviced loans.

Moody's has assumed a high default probability for 18 poorly
performing loans representing 8% of the pool. Moody's has
estimated a $22.4 million loss (15% expected loss based on a 50%
probability default) from these troubled loans.

Moody's was provided with full year 2010 and partial year 2011
operating results for 97% and 54%, respectively, of the performing
pool. Excluding specially serviced and troubled loans, Moody's
weighted average LTV for the conduit component is 106% compared to
111% 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 9.5%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs for the conduit component are 1.34X and 1.02X,
respectively, compared 1.33X and 0.98X 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 loan with a credit estimate is the Ala Moana Portfolio Loan
($83.3 million -- 4.3% of the pool), which is secured by a
portfolio composed of two retail and two office properties
totaling 2 million SF located in Honolulu, Hawaii. The retail
component is the dominant retail mall in its market. The loan
represents an 8% interest in a pari passu mortgage loan. The
portfolio is also encumbered by a $263 million non-pooled junior
component which supports the rake classes AMP-1, AMP-2 and AMP-3.
The property was 95% leased as of March 2011. Moody's current
credit estimate and stressed DSCR are A3 and 1.11X, respectively,
compared to A3 and 1.24X at last full review.

The top three performing conduit loans represent 18% of the pool.
The largest loan is the IRET Portfolio Loan ($122.6 million --
6.3% of the pool), which is a comprised of nine office properties
located in Minnesota, Missouri, Nebraska, and Kansas. The
portfolio totals 937K SF. The loan is interest-only for its entire
10-year term and matures in October 2016. The portfolio was 86%
leased as of October 2010 compared to 100% at last review.
Although 2010 property performance has been stable, Moody's
analysis reflects a stressed cash flow because of concerns about
the increased vacancy. Moody's LTV and stressed DSCR are 136% and
0.75X, respectively, compared to 132% and 0.78X at last full
review.

The second largest loan is the 801 South Figueroa ($120 million --
6.2% of the pool), which is secured by a 443K SF office building
located in Los Angeles, California. The loan is interest-only for
its entire 10-year term and matures in October 2016. Property
performance has improved since last review due to increased rental
income. Moody's LTV and stressed DSCR are 112% and 0.90X,
respectively, compared to 133% and 0.75X at last full review.

The third largest loan is the Tower 67 Loan ($100 million -- 5.1%
of the pool), which is secured by a 449-unit multifamily property
located in New York City. As of June 2011, the property was 98%
leased compared to 96% at last full review. Property performance
has been stable. The loan is interest-only for a 10-year term and
has an anticipated repayment date of July 2016. Moody's LTV and
stressed DSCR are 81% and 1.00X, respectively, compared to 77% and
1.06X at last review.


CIFC FUNDING: Moody's Raises Rating of Class B-1L Notes to 'Ba1'
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by CIFC Funding 2006-I, Ltd.

US$100,000,000 Class A-1LR Variable Funding Notes, Upgraded to Aa1
(sf); previously on June 22, 2011 Aa2 (sf) Placed Under Review for
Possible Upgrade;

US$293,000,000 Class A-1L Floating Rate Notes, Upgraded to Aa1
(sf); previously on June 22, 2011 Aa2 (sf) Placed Under Review for
Possible Upgrade;

US$26,500,000 Class A-2L Floating Rate Notes, Upgraded to A1 (sf);
previously on June 22, 2011 A2 (sf) Placed Under Review for
Possible Upgrade;

US$30,500,000 Class A-3L Floating Rate Notes, Upgraded to Baa2
(sf); previously on June 22, 2011 Baa3 (sf) Placed Under Review
for Possible Upgrade;

US$20,000,000 Class B-1L Floating Rate Notes, Upgraded to Ba1
(sf); previously on June 22, 2011 Ba3 (sf) Placed Under Review for
Possible Upgrade;

US$23,000,000 Class B-2L Floating Rate Notes (current balance of
$21,966,922), 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 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 an increase in the
transaction's overcollateralization ratios since the rating action
in September 2009. Based on the latest trustee report dated
September 12, 2011, the Senior Class A, Class A, Class B-1L, and
Class B-2L overcollateralization ratios are reported at 122.6%,
114.3%, 109.4%, and 104.5%, respectively, versus August 2009
levels of 120.2%, 112.1%, 107.3%, and 101.9%, respectively.
Moody's notes that the Class B-2L Notes have amortized by
approximately $0.5mm or 2.1% since the rating action in September
2009 due to the diversion of excess interest to delever the Class
B-2L Notes up to the Additional Collateral Deposit Requirement.

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 $513 million
(assuming the Class A-1LR notes are fully drawn), a weighted
average default probability of 25.1% (implying a WARF of 3200), a
weighted average recovery rate upon default of 50.4%, and a
diversity score of 60. 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.

CIFC Funding 2006-I, Ltd., issued in August 2006, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans with significant exposure to loans of middle
market issuers.

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

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

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

Sources of additional performance uncertainties are:

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

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

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

4) 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.


CIFC FUNDING: Moody's Upgrades Rating of $14.5-Mil. Notes to 'Ba1'
------------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by CIFC Funding 2006-IB, Ltd.

US$224,000,000 Class A-1L Floating Rate Notes Due 2020, Confirmed
at Aa1 (sf); previously on June 22, 2011 Aa1 (sf) Placed Under
Review for Possible Upgrade;

US$75,000,000 Class A-1LR Variable Funding Notes Due 2020 (current
funded amount of $62,500,000), Confirmed at Aa1 (sf); previously
on June 22, 2011 Aa1 (sf) Placed Under Review for Possible
Upgrade;

US$22,000,000 Class A-2L Floating Rate Notes Due 2020, Upgraded to
A1 (sf); previously on June 22, 2011 A2 (sf) Placed Under Review
for Possible Upgrade;

US$22,500,000 Class A-3L Floating Rate Notes Due 2020, Upgraded to
Baa2 (sf); previously on June 22, 2011 Baa3 (sf) Placed Under
Review for Possible Upgrade;

US$14,500,000 Class B-1L Floating Rate Notes Due 2020, Upgraded to
Ba1 (sf); previously on June 22, 2011 Ba3 (sf) Placed Under Review
for Possible Upgrade;

US$16,000,000 Class B-2L 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 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 an increase in the
transaction's overcollateralization ratios since the rating action
in September 2009. Based on the latest trustee report dated
September 12, 2011, the Senior Class A, Class A, Class B-1L, and
Class B-2L overcollateralization ratios are reported at 122.3%,
114.3%, 109.7%, and 105.0%, respectively, versus August 2009
levels of 120.3%, 112.5%, 107.9%, and 103.3%, 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 $393 million
(assuming the Class A-1LR notes are fully drawn), a weighted
average default probability of 23.8% (implying a WARF of 3100), a
weighted average recovery rate upon default of 49.4%, and a
diversity score of 58. 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.

CIFC Funding 2006-IB, Ltd., issued in October 2006, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans with significant exposure to loans of middle
market issuers.

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 spread,
weighted average coupon, and diversity score. However, as a part
of the base case, Moody's considered the diversity and spread
levels higher than the covenant level 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.


COMM 2005-C6: Moody's Affirms Cl. B Notes Rating at 'B3'
--------------------------------------------------------
Moody's Investors Service (Moody's) upgraded the ratings of four
classes and affirmed 15 classes of COMM 2005-C6, Commercial
Mortgage Pass-Through Certificates:

Cl. A-AB, Affirmed at Aaa (sf); previously on Oct 20, 2005
Definitive Rating Assigned Aaa (sf)

Cl. A-2, Affirmed at Aaa (sf); previously on Oct 20, 2005
Definitive Rating Assigned Aaa (sf)

Cl. A-3, Affirmed at Aaa (sf); previously on Oct 20, 2005
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on Oct 20, 2005
Definitive Rating Assigned Aaa (sf)

Cl. A-5A, Affirmed at Aaa (sf); previously on Oct 20, 2005
Definitive Rating Assigned Aaa (sf)

Cl. A-5B, Affirmed at Aa2 (sf); previously on Dec 2, 2010
Downgraded to Aa2 (sf)

Cl. A-1A, Affirmed at Aa2 (sf); previously on Dec 2, 2010
Downgraded to Aa2 (sf)

Cl. A-J, Affirmed at Baa3 (sf); previously on Dec 2, 2010
Downgraded to Baa3 (sf)

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

Cl. C, Upgraded to Caa1 (sf); previously on Dec 2, 2010 Downgraded
to Caa2 (sf)

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

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

Cl. F, Upgraded to Ca (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 Oct 7, 2010 Downgraded to
C (sf)

Cl. J, Affirmed at C (sf); previously on Oct 7, 2010 Downgraded to
C (sf)

Cl. K, Affirmed at C (sf); previously on Oct 7, 2010 Downgraded to
C (sf)

Cl. X-C, Affirmed at Aaa (sf); previously on Oct 20, 2005
Definitive Rating Assigned Aaa (sf)

Cl. X-P, Affirmed at Aaa (sf); previously on Oct 20, 2005
Definitive Rating Assigned Aaa (sf)

RATINGS RATIONALE

The upgrades are due to lower than expected losses from specially
serviced and troubled loans along with increased credit support
due to 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
8.8% of the current balance. At last full review, Moody's
cumulative base expected loss was 10.1%. Moody's stressed scenario
loss is 17.4% of the current balance. 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 principal 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
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 26, the same as 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 2, 2010.

DEAL PERFORMANCE

As of the October 11, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 20% to
$1.82 billion from $2.27 billion at securitization. The
Certificates are collateralized by 122 mortgage loans ranging
in size from less than 1% to 12% of the pool, with the top ten
loans representing 48% of the pool. One loan, representing
less than 1% of the pool, has a credit estimate. Three loans,
representing 2% of the pool, have defeased and are collateralized
with U.S. Government securities.

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

Six loans have been liquidated from the pool since securitization,
resulting in an aggregate realized loss of $55.3 million (72% loss
severity). Ten loans, representing 8% of the pool, are currently
in special servicing. The largest specially serviced loan is the
Tropicana Center Loan ($53.3 million -- 2.9% of the pool), which
is secured by a 578K square foot (SF) retail property located in
Las Vegas, Nevada. The loan was transferred to special servicing
in March 2009 due to payment default and is currently 90+ days
delinquent. The remaining nine specially serviced loans are
secured by a mix of property types. The master servicer has
recognized appraisal reductions totaling $70.6 million for the
specially serviced loans. Moody's has estimated an aggregate
$71.7 million loss (49% expected loss on average) for the
specially serviced loans.

Moody's has assumed a high default probability for four poorly
performing loans representing 3% of the pool. Moody's has
estimated a $10.0 million loss (20% expected loss based on a 50%
probability default) from these troubled loans.

Moody's was provided with full year 2010 and partial year 2011
operating results for 97% and 40%, respectively, of the performing
pool. Excluding specially serviced and troubled loans, Moody's
weighted average LTV for the conduit component is 100% compared to
106% 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%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs for the conduit component are 1.50X and 1.05X,
respectively, compared 1.43X and 1.02X at last review. Moody's
actual DSCR is based on Moody's net cash flow (NCF) and the loan's
actual debt service. Moody's stressed DSCR is based on Moody's NCF
and a 9.25% stressed rate applied to the loan balance.

The loan with an investment grade credit estimate is the 9701
Apollo Drive Loan ($5.4 million -- 0.3% of the pool), which is
secured by a 94K SF office building located in Largo (Prince
George's County), Maryland. Moody's current credit estimate and
stressed DSCR are Aaa and 2.36X, respectively, compared to Aaa and
2.61X at last review.

The top three performing conduit loans represent 28% of the pool.
The largest loan is the Lakewood Center Loan ($218.0 million --
12.0% of the pool), which is secured by the borrower's interest in
a 2.1 million SF regional mall located in Lakewood (Los Angeles
County), California. The mall is anchored by Macy's, J.C. Penney
and Target. The property was 91% leased as of June 2011 compared
to 94% at last review. The loan is interest only throughout the
entire term. Moody's LTV and stressed DSCR are 88% and 1.05X,
respectively, compared to 80% and 1.16X at last review.

The second largest loan is the Kaiser Center Loan ($147 million --
8.1% of the pool), which is secured by a 914K SF Class A office
building located in Oakland, California. The property was 93%
leased as of December 2010, the same as at last review. The
largest tenants are BART (34% of the net rentable area (NRA);
lease expiration July 2021) and the Regents of the University of
California (13% of the NRA; lease expiration April 2016).
Performance remains stable. The loan is interest-only throughout
the entire term. Moody's LTV and stressed DSCR are 121% and 0.82X,
respectively, compared to 124% and 0.81X at last review.

The third largest loan is the Private Mini Storage Portfolio Loan
($142.3 million -- 7.8% of the pool), which is secured by a
portfolio of 38 self storage facilities totaling 22,863 units
located in six states. The properties were 75% leased as of year-
end 2010 compared to 74% at last review. Moody's LTV and stressed
DSCR are 98% and 1.02X, respectively, compared to 101% and 0.99X
at last review.


COMM 2011: Fitch Puts Rating on $5.99 Mil. Notes at 'BBsf'
-----------------------------------------------------------
Fitch Ratings has assigned these ratings and Rating Outlooks to
Deutsche Bank's COMM 2011-FL1:

  -- $356,295,000 class A 'AAAsf'; Outlook Stable;
  -- $62,428,000 class B 'AAsf'; Outlook Stable;
  -- $66,996,000 class C 'Asf'; Outlook Stable;
  -- $41,872,000 class D 'BBBsf'; Outlook Stable;
  -- $5,990,000 class NH1 'BBsf'; Outlook Stable.

Fitch does not rate the $609,052,765 interest-only class X, the
$53,293,000 class E, the $21,168,765 class F, or the $4,000,000
class ESG1.

A detailed description of Fitch's rating analysis including key
rating drivers, stresses, rating sensitivity, analysis, model,
criteria application and data adequacy is available in Fitch's
presale report dated Sept. 30, 2011.


COMM 2011-FL1: Moody's Assigns 'Ba2' Rating to Cl. F Notes
----------------------------------------------------------
Moody's Investors Service has assigned ratings to nine classes of
CMBS securities, issued by COMM 2011-FL1 Commercial Mortgage Pass-
Through Certificates.

Cl. A, Definitive Rating Assigned Aaa (sf)

Cl. X, Definitive Rating Assigned Aaa (sf)

Cl. B, Definitive Rating Assigned Aa2 (sf)

Cl. C, Definitive Rating Assigned A2 (sf)

Cl. D, Definitive Rating Assigned Baa2 (sf)

Cl. E, Definitive Rating Assigned Baa3 (sf)

Cl. F, Definitive Rating Assigned Ba2 (sf)

Cl. ESG1, Definitive Rating Assigned Ba3 (sf)

Cl. NH1, Definitive Rating Assigned Ba3 (sf)

RATINGS RATIONALE

The Certificates are collateralized by 7 floating rate loans
secured by 52 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 Stressed DSCR for the Pooled Trust is 1.69X which is
higher than the 2007 large transaction average of 1.63X. Moody's
LTV ratio for the Pooled Trust is 64.3% which is slightly higher
than the 2007 large loan transaction average of 63.3%.

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
4.5. The score is consistent with Herfindahl scores represented by
large loan, multi-borrower transactions previously rated by
Moody's. With respect to property level diversity, the pool's
property level Herfindahl score is 4.7. The transaction's property
diversity profile is also in-line most previously rated large loan
multi-borrower transactions.

The deal is structured as a Modified Pro Rata pay, whereby
principal payments with respect to the trust assets will be
distributed on a modified pro rata basis pursuant to the following
allocation: Class A: 65.50%, Class B: 8.52%, Class C: 9.14%, Class
D: 5.72%, Class E: 7.27%, and Class F: 3.84%. Relative to a
traditional senior sequential structure, modified pro rata pay
increases expected loss for senior rated tranches, but
incrementally reduces expected loss for junior rated tranches.

The modified pro rata pay structure will continue until a
sequential pay down event occurs at which time such mortgage loan
will be allocated sequentially among the certificates. A
sequential pay down event will occur when (i) a borrower fails to
make two consecutive monthly payments, (ii) the related mortgage
loan has been accelerated, (iii) an appraisal reduction event has
occurred that also constitutes a mortgage loan event of default
with respect to such mortgage loan, or (iv) there is any
modification, discounted pay-off or realized loss with respect to
the related mortgage loan.

Moody's 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 1.7, which is low compared to
other deals rated by Moody's since 2009. The low weighted average
grade is indicative of the strong market composition of the pool
and the institutional investor quality of underlying assets in the
deal.

The principal 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 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.

The V Score for this transaction is assessed as Medium, the same
as the V score assigned to the U.S. Large Loan 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%, 17%, or 29%, the model-indicated rating for the currently
rated Aaa class would be Aa1; Aa2; and A1. 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.


CREST EXETER: Fitch Affirms Junk Rating on Two Note Classes
-----------------------------------------------------------
Fitch Ratings has affirmed 10 classes issued by Crest Exeter
Street Solar 2004-1, Ltd./Corp (Crest Exeter 2004-1) as a result
of increased credit enhancement to the notes due to repayment on
the underlying collateral.

Since Fitch's last rating action in November 2010, approximately
12.7% of the underlying collateral has been downgraded and 14.6%
upgraded.  Currently, 39.9% of the portfolio has a Fitch derived
rating below investment grade and 13.9% has a rating in the 'CCC'
category and below, compared to 36.9% and 8.6% at the last review.
The class A-1 and A-2 notes have received $67.3 million in
paydowns since the last review.

This transaction was analyzed under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Portfolio Credit Model (PCM) for projecting future default
levels for the underlying portfolio.  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'.  Fitch also analyzed the
structure's sensitivity to the assets that are distressed,
experiencing interest shortfalls, and those with near-term
maturities.  Based on this analysis, the class A through D notes'
breakeven rates are generally consistent with the ratings assigned
below.

For the class E notes, Fitch analyzed the class' sensitivity to
the default of the distressed assets ('CCC' and below).  Given the
high probability of default of these assets and expected limited
recovery prospects upon default, the class E notes have been
affirmed at 'CCCsf', indicating that default is possible.  As of
the Sept. 29, 2011 trustee report, defaulted securities, as
defined in the transaction's governing documents, now comprise
14.7% of the portfolio, compared to 5.2% at last review. One
defaulted security is the Rouse Co. bond (4.9%); Rouse Co.'s
parent company, GGP, has recently emerged from bankruptcy.
Additionally, 6.3% of non-defaulted collateral is currently
experiencing interest shortfalls.

The Stable Outlook on the class A notes reflects Fitch's view that
the notes will continue to delever. The Negative Outlook on the
class B through D notes reflects Fitch's expectation that
underlying CMBS loans will continue to face refinance risk at
maturity. Fitch does not assign Outlooks to classes rated 'CCC'
and below.

Crest Exeter 2004-1 is a cash flow commercial real estate
collateralized debt obligation (CRE CDO) which closed on April 29,
2004. The collateral is composed of 54.2% commercial mortgage
backed securities (CMBS), 22.9% real estate investment trusts
(REITs), 19.6% commercial real estate loans (CREL), and 3.3% SF
CDOs.

Fitch has affirmed these classes as indicated:

  -- $83,010,094 Class A-1 at 'Asf' Outlook to Stable from
     Negative;
  -- $20,655,094 Class A-2 at 'Asf' Outlook to Stable from
     Negative;
  -- $8,377,070 Class B-1 at 'BBBsf' Outlook Negative;
  -- $9,214,777 Class B-2 at 'BBBsf' Outlook Negative;
  -- $1,675,414 Class C-1 at 'BBsf' Outlook Negative;
  -- $13,759,337 Class C-2 at 'BBsf' Outlook Negative;
  -- $5,026,242 Class D-1 at 'Bsf' Outlook Negative;
  -- $11,371,872 Class D-2 at 'Bsf' Outlook Negative;
  -- $3,769,681 Class E-1 at 'CCCsf';
  -- $5,445,095 Class E-2 at 'CCCsf'.


CSFB 2002-CKN2: Moody's Affirms Rating of Cl. F Notes at 'B1'
-------------------------------------------------------------
Moody's Investors Service (Moody's) downgraded the ratings of four
classes and affirmed nine CMBS classes of Credit Suisse First
Boston Mortgage Securities Corp., Commercial Mortgage Pass-Through
Certificates, Series 2002- CKN2:

Cl. A-3, Affirmed at Aaa (sf); previously on Mar 9, 2011 Confirmed
at Aaa (sf)

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

Cl. C-1, Affirmed at Aa2 (sf); previously on Dec 2, 2010
Downgraded to Aa2 (sf)

Cl. C-2, Affirmed at Aa2 (sf); previously on Dec 2, 2010
Downgraded to Aa2 (sf)

Cl. D, Affirmed at A2 (sf); previously on Dec 2, 2010 Downgraded
to A2 (sf)

Cl. E, Affirmed at Baa2 (sf); previously on Dec 2, 2010 Downgraded
to Baa2 (sf)

Cl. F, Downgraded to B1 (sf); previously on Dec 2, 2010 Downgraded
to Ba3 (sf)

Cl. G, Downgraded to Caa2 (sf); previously on Dec 2, 2010
Downgraded to B3 (sf)

Cl. H, Downgraded to Ca (sf); previously on Dec 2, 2010 Downgraded
to Caa2 (sf)

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

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

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

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

RATINGS RATIONALE

The downgrades are due to higher expected losses for the pool
resulting from realized and anticipated losses from specially
serviced and troubled loans, interest shortfalls and concerns
about refinance risk associated with loans approaching maturity in
an adverse environment. One hundred thirty-one loans, representing
99% of the pool, mature within the next 12 months. Fourteen of
these loans, representing 10% of the pool, have a Moody's stressed
debt service coverage ratio (DSCR) below 1.00X.

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
5.1% of the current balance. At last review, Moody's cumulative
base expected loss was 5.0%. Moody's stressed scenario loss is
7.9% of the current balance. 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 methodologies used in this rating were "Moody's Approach to
Rating Fusion U.S. CMBS Transactions" published in April 2005, and
"Moody's Approach to Rating CMBS Large Loan/Single Borrower
Transactions" published in July 2000.

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 10 compared to 31 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 2, 2010.

DEAL PERFORMANCE

As of the September 16, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 37% to
$581.0 million from $918.1 million at securitization. The
Certificates are collateralized by 135 mortgage loans ranging
in size from less than 1% to 9% of the pool, with the top ten
loans representing 41% of the pool. Twenty-one loans, representing
26% of the pool, have defeased and are collateralized with
U.S. Government securities. The pool also includes 59 loans,
representing 17% of the pool, which are secured by residential
co-op loans.

Forty-four 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.

Fifteen loans have been liquidated from the pool, resulting in an
aggregate realized loss of $35.4 million (43% loss severity
overall). Ten loans, representing 7% of the pool, are currently in
special servicing. The master servicer has recognized an aggregate
$15.4 million appraisal reduction for four of the specially
serviced loans. Moody's has estimated an aggregate $21.1 million
loss (50% expected loss on average) for the specially serviced
loans.

Moody's has assumed a high default probability for five poorly
performing loans representing 3% of the pool and has estimated a
$2.8 million aggregate loss (15% expected loss based on a 50%
probability default) from these troubled loans.

As of the most recent remittance date, the pool has experienced
cumulative interest shortfalls totaling $1.2 million and affecting
Classes N through H. Moody's anticipates that the pool will
continue to experience interest shortfalls caused by specially
serviced loans. Interest shortfalls are caused by special
servicing fees, including workout and liquidation fees, appraisal
subordinate entitlement reductions (ASERs), extraordinary trust
expenses and non-advancing by the master servicer based on a
determination of non-recoverability.

Moody's was provided with full year 2010 and partial year 2011
operating results for 100% and 87% of the pool's loans, excluding
defeased and cooperative housing collateralized loans. Excluding
specially serviced and troubled loans, Moody's weighted average
LTV is 80% compared to 81% 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 9.7%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.32X and 1.38X, respectively, essentially
the same as at last review. Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The top three performing conduit loans represent 23% of the pool
balance. The largest loan is the Paradise Island Apartments Loan
($49.6 million -- 8.5%), which is secured by a 980-unit
multifamily complex located in Jacksonville, Florida. The property
was 97% occupied as of June 2011 compared to 94% as of December
2010 and 86% as of December 2009. Performance has improved due to
the increase in occupancy. Moody's LTV and stressed DSCR are 86%
and 1.13X, respectively, compared to 98% and 1.00X at last review.

The second largest loan is the Beaver Valley Mall Loan
($42.7 million -- 7.4%), which is secured by the borrower's
interest in a 1.2 million square foot (SF) regional mall (966,000
SF of collateral) located approximately 35 miles northwest of
downtown Pittsburgh in Center Township, Pennsylvania. The mall is
anchored by Sears, J.C. Penney, Boscov's and Macy's (not part of
the collateral). The mall was 89% leased as of March 2011 compared
to 90% as of December 2010. Performance has declined due to a
decrease in effective gross income and an increase in operating
expenses. Moody's LTV and stressed DSCR are 96% and 1.04X,
respectively, compared to 88% and 1.14X at last review.

The third largest loan is the PNC Center Loan ($39.6 million --
6.8%), which is secured by a 498,000 SF office building located in
downtown Cincinnati, Ohio. The largest tenants are PNC (39% of the
NRA; lease expiration in February 2014) and Frost Brown Todd (25%
of the NRA; lease expiration in December 2011). The property was
88% leased as of March 2011, the same as of December 2010 and
December 2009. Moody's is concerned about the near-term lease
expiration of Frost Brown Todd lease. The loan matures in March
2012. Moody's LTV and stressed DSCR are 91% and 1.16X,
respectively, compared to 93% and 1.13X at last review.


DALTON CDO: S&P Lowers Ratings on 5 Classes of Notes to 'D'
-----------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on the
class A-1a1, A-1a2, A-1b1, A-1b2, and A-2 notes from Dalton CDO
Ltd. to 'D (sf)'.

The downgrades are a result of nonpayment of interest on the
transaction's nondeferrable classes. According to the notice of
acceleration, liquidation, and suspension of payments dated Sept.
23, 2011, no distributions of any kind were made on the Sept. 20,
2011, payment date.

Ratings Lowered

Dalton CDO Ltd.
                Rating
Class       To          From
A-1a1       D (sf)      CCC (sf)
A-1a2       D (sf)      CC (sf)
A-1b1       D (sf)      CC (sf)
A-1b2       D (sf)      CC (sf)
A-2         D (sf)      CC (sf)

Other Ratings Outstanding

Dalton CDO Ltd.

Class       Rating
B           D (sf)
C           D (sf)
D           D (sf)


E*TRADE ABS: S&P Lowers Rating on Class A-2 Notes to 'B'
--------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on the
class A-2 notes from E*Trade ABS CDO I Ltd. and removed it from
CreditWatch, where S&P placed it with negative implications
on Aug. 2, 2011. The transaction is a U.S. collateralized debt
obligation (CDO) transaction backed substantially by residential
mortgage-backed securities (RMBS).

"The transaction has experienced significant credit deterioration
since our last downgrade on Oct. 5, 2010. According to the Oct. 3,
2011 trustee report, the transaction had approximately $12 million
in performing assets, compared with more than $14 million noted in
the Aug. 31, 2010 trustee report, which we referenced for our
October 2010 rating action. The class A-2 notes now have
less subordination available than at the time of the last
downgrade," S&P related.

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

Rating And CreditWatch Action

E*Trade ABS CDO I Ltd.
                 Rating
Class       To            From
A-2         B (sf)        BB+ (sf)/Watch Neg


EQUITABLE OF IOWA: Fitch Upgrades Rating on 8.42% to 'BB'
---------------------------------------------------------
Fitch Ratings has upgraded the ratings of Equitable of Iowa
Companies Capital Trust II 8.42% due 1/04/2027 (EICCT2) to 'BB'
from 'B+' and maintained the Rating Watch Evolving for Equitable
of Iowa, Inc's.  Equitable of Iowa, Inc. is an indirect subsidiary
of ING Americas Insurance Holdings, Inc. (IAIH).  All ratings are
on Rating Watch Evolving.

The upgrade reflects the application of standard notching
methodology for Equity of Iowa's trust preferred securities per
Fitch's rating criteria.  The previous rating incorporated non-
standard notching reflecting concerns of coupon deferral imposed
by the Dutch government/European Union.

The Rating Watch Evolving status solely reflects uncertainty over
IAIH's pending change in ownership.  Based on an agreement with
the Dutch government, ING Group has agreed to divest its global
insurance operations by 2013.  Fitch expects that the divestiture
of IAIH will mostly likely occur via IPO as early as the second
quarter of 2012.

The rating actions are:

Equitable of Iowa Companies, Inc.

  -- Long-term IDR at 'BBB'; Rating Watch Evolving maintained.

Equitable of Iowa Companies Capital Trust II

  -- 8.42% due 4/01/2027 upgraded to 'BB' from 'B+'; Rating Watch
     Evolving.


FIRST INVESTORS: S&P Gives 'BB' Rating on Class E Notes
-------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to First
Investors Auto Owner Trust 2011-2's $100 million automobile
receivables-backed notes series 2011-2.

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

The ratings reflect S&P's view of:

    The availability of approximately 35.21%, 31.29%, 24.54%,
    17.72%, and 15.22% credit support for the class A, B, C, D,
    and E notes based on stressed cash flow scenarios (including
    excess spread). These credit support levels provide more than
    3.75x, 3.25x, 2.50x, 1.90x, and 1.55x coverage of S&P's 8.60%-
    9.10% expected cumulative net loss range for the class A, B,
    C, D, and E notes;

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

    "Our expectation that under a moderate, or 'BBB', stress
    scenario, the ratings on the class A and B notes would not
    decline by more than one rating category, which is consistent
    with our rating stability criteria, and the ratings on the
    class C and D notes would remain within the two-rating
    category outlined in our rating stability criteria (see
    'Methodology: Credit Stability Criteria,' published May 3,
    2010)," S&P stated;

    The collateral characteristics of the pool being securitized;

    First Investors Financial Services Inc.'s (First Investors')
    22-year history of originating and underwriting auto loans,
    13-year history of servicing auto loans for itself and other
    companies as a third-party servicer, and track record of
    securitizing auto loans since 2000;

    Wells Fargo Bank N.A.'s experience as the committed back-up
    servicer; and

    The transaction's payment and legal structures.

            Standard & Poor's 17g-7 Disclosure Report

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

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

   http://standardandpoorsdisclosure-17g7.com/1111176.pdf

Ratings Assigned

First Investors Auto Owner Trust 2011-2

Class   Rating          Type            Interest       Amount
                                        rate         (mil. $)
A-1     A-1+ (sf)       Senior          Fixed          13.500
A-2     AAA (sf)        Senior          Fixed          63.345
B       AA (sf)         Subordinate     Fixed           5.340
C       A (sf)          Subordinate     Fixed           8.145
D       BBB (sf)        Subordinate     Fixed           7.630
E       BB (sf)         Subordinate     Fixed           2.040


FM LEVERAGED: Moody's Gives Caa2/LD Probability of Default Rating
-----------------------------------------------------------------
Moody's Investors Service, in accordance with its issuer comment
of October 7, 2011, assigned a Caa2/LD probability of default
rating to Hovnanian Enterprises, Inc. This action follows the
company's announcement on September 28, 2011 and follow-up
announcement on October 17, 2011 that it commenced private offers
to exchange senior unsecured notes for up to $220 million of new
senior secured notes. In a related action, Moody's lowered the
rating on the company's existing senior secured notes to B3 (LGD3,
31%) from B2 (LGD2, 24%) and assigned a new rating of B3 (LGD3,
31%) to the company's proposed two new issues of senior secured
notes due 2021. The company's wholly-owned operating subsidiary,
K. Hovnanian Enterprises, Inc., will issue the new notes in a
private placement. By Moody's definition, the proposed
transactions constitute a distressed exchange and a limited
default. After three business days, Moody's will remove the LD
designation.

These ratings were affected by the proposed distressed exchange
transaction:

Probability of Default rating changed to Caa2/LD from Caa2

$797 million of existing 10 5/8% senior secured notes lowered to
B3 (LGD3, 31%) from B2 (LGD2, 24%)

Up to $220 million of proposed new 2% and 5% senior secured notes
due 2021 assigned B3 (LGD3, 31%) ratings

All other ratings and the negative outlook remain unchanged.

RATINGS RATIONALE

The principal methodology used in rating Hovnanian was the Global
Homebuilding Industry Methodology published in March 2009. Other
methodologies used include Loss Given Default for Speculative-
Grade Non-Financial Companies in the U.S., Canada and EMEA
published in June 2009.

The corporate family rating ("CFR") and the ratings on Hovnanian's
outstanding senior unsecured ratings will remain unchanged as a
result of the distressed exchange transactions. However, with less
junior debt supporting the company's senior secured obligations
going foward, the rating on these senior secured notes are being
lowered to B3 from B2 in accordance with Moody's Loss-Given-
Default methodology.

Established in 1959 and headquartered in Red Bank, New Jersey,
Hovnanian Enterprises, Inc. designs, constructs and markets
single-family detached homes and attached condominium apartments
and townhouses. Revenue and consolidated net loss for the last
twelve months ending July, 31 2011 were approximately $1.1 billion
and $0.3 million, respectively.


FM LEVERAGED: Moody's Upgrades Rating of Class D Notes to 'Ba1'
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by FM Leveraged Capital Fund I:

US$35,300,000 Class B Second Priority Senior Floating Rate Notes
Due August 1, 2017, Upgraded to Aaa (sf); previously on June 22,
2011 Aa1 (sf) Placed Under Review for Possible Upgrade;

US$24,600,000 Class C Third Priority Deferrable Floating Rate
Notes Due August 1, 2017, Upgraded to Aa2 (sf); previously on
June 22, 2011 A3 (sf) Placed Under Review for Possible Upgrade;

US$24,600,000 Class D Fourth Priority Deferrable Floating Rate
Notes Due August 1, 2017, Upgraded to Ba1 (sf); previously on
June 22, 2011 Ba3 (sf) Placed Under Review for Possible Upgrade;
and

US$12,200,000 Class E Fifth Priority Deferrable Floating Rate
Notes Due 2017 (current outstanding balance of $13,394,073),
Upgraded to Caa1 (sf); previously on June 22, 2011 Caa3 (sf)
Placed Under Review for Possible Upgrade.

RATINGS RATIONALE

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

The rating actions also reflect consideration of an increase
in the transaction's overcollateralization ratios due to
the paydown of the senior notes as a result of the Class E
overcollateralization failure. Since the last rating action in
June 2011, the Class A Notes have been paid down by approximately
22% of the original balance or $53.5 million. As a result of the
delevering, the overcollateralization ratios have increased since
the last rating action. Based on the trustee report dated
September 8, 2011, the Class A/B, Class C, Class D, and Class E
overcollateralization ratios are reported at 161.23%, 129.63%,
108.39%, and 98.95%, respectively, versus April 2011 levels of
148.63%, 123.82%, 106.11%, and 98.07%, respectively. The September
2011 overcollateralization ratios do not include the principal
payment made to the Class A notes.

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 $132.66 million,
defaulted par of $24.3 million, a weighted average default
probability of 26.7% (implying a WARF of 4444), a weighted average
recovery rate upon default of 44%, and a diversity score of 33.
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. 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.

FM Leveraged Capital Fund I, issued in December 2005, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans with significant exposure to senior secured
loans of middle market issuers.

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) 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 with 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.

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) 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
generally analyzes 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 current levels for spread due to the
limited time remaining until the end of reinvestment period.


GECMC 2002-1: Moody's Affirms Rating of Cl. J Notes at 'Ba1'
------------------------------------------------------------
Moody's Investors Service (Moody's) upgraded the rating of two
classes and affirmed 13 classes of GE Commercial Mortgage Corp.,
Commercial Mortgage Pass-Through Certificates, Series 2002-1:

Cl. A-3, Affirmed at Aaa (sf); previously on Apr 18, 2002
Definitive Rating Assigned Aaa (sf)

Cl. B, Affirmed at Aaa (sf); previously on Dec 8, 2006 Upgraded to
Aaa (sf)

Cl. C, Affirmed at Aaa (sf); previously on Jul 9, 2007 Upgraded to
Aaa (sf)

Cl. D, Affirmed at Aaa (sf); previously on Aug 13, 2007 Upgraded
to Aaa (sf)

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

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

Cl. G, Upgraded to Aa2 (sf); previously on Sep 25, 2008 Upgraded
to A2 (sf)

Cl. H, Upgraded to A2 (sf); previously on Aug 13, 2007 Upgraded to
Baa1 (sf)

Cl. J, Affirmed at Ba1 (sf); previously on Apr 18, 2002 Definitive
Rating Assigned Ba1 (sf)

Cl. K, Affirmed at B1 (sf); previously on Dec 9, 2010 Downgraded
to B1 (sf)

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

Cl. M, Affirmed at Caa3 (sf); previously on Dec 9, 2010 Downgraded
to Caa3 (sf)

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

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

Cl. X-1, Affirmed at Aaa (sf); previously on Apr 18, 2002
Definitive Rating Assigned Aaa (sf)

RATINGS RATIONALE

The upgrades are due to an increase in subordination from loan
payoffs and amortization and overall stable pool performance. The
deal's pooled balance has paid down by 19% since last review.

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

Moody's rating action reflects a cumulative base expected loss of
4% of the current pooled balance, as compared to 4.1% at last
review. Moody's base expected loss plus realized losses is 3.0% of
the original pooled balance as compared to 3.6% at last review.
Moody's stressed scenario loss is 5.7% of the current pooled
balance. 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 principal 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
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 35 as compared to 42
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.

DEAL PERFORMANCE

As of the October 11, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 39% to $633 million
from $1.04 billion at securitization. The Certificates are
collateralized by 109 mortgage loans ranging in size from less
than 1% to 5% of the pool, with the top ten loans representing 26%
of the pool. Thirty-six loans, representing 38% of the pool, have
defeased and are collateralized by U.S. Government securities.
Moody's expects this deal to pay down considerably by the first
half of 2012 since all of the defeased loans mature by the end of
April 2012. There are no loans with investment grade credit
estimates.

Thirty loans, representing 26% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, Moody's reviews the
watchlist to assess which loans have material issues that could
impact performance.

Four loans have been liquidated from the pool since
securitization, resulting in a $6 million loss (28% loss severity
on average). Three loans, representing 5% of the pool, are
currently in special servicing. The largest specially serviced
loan is the Summerlyn Park Loan ($17 million -- 2.7% of the pool),
which is secured by a 415 unit apartment complex in Lithonia,
Georgia. The property transferred to special servicing in November
2009 and became REO in March 2010. The property's name has been
changed from Highland Greens to Summerlyn Park. The servicer
intends to lease-up the property and then market it for sale. The
property was 57% leased as of July 2011. Although occupancy is
low, it has steadily increased from 32% in September 2010.

The remaining two specially serviced loans are secured by an
office and retail property. The master servicer has recognized a
$1 million appraisal reduction for one of the remaining specially
serviced loans. Moody's has estimated a $13.5 million loss (64%
expected loss) for two of the specially serviced loans.

Moody's has assumed a high default probability for seven poorly
performing loans representing 6% of the pool and has estimated a
$6 million loss (15% expected loss based on a 50% probability
default) from these troubled loans.

Moody's was provided with full year 2010 and partial year 2011
operating results for conduit loans, respectively. The conduit
portion of the pool excludes specially serviced, defeased and
troubled loans. Moody's weighted average conduit LTV is 72%
compared to 77% 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%.

Moody's actual and stressed conduit DSCRs are 1.32X and 1.52X,
respectively, compared to 1.53X and 1.43X 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. Eighty-nine
percent of the conduit loans mature by the end of 2012.
Consequently, the actual debt constant is greater than Moody's
9.25% stressed rate, which is why Moody's stressed DSCR is now
greater than Moody's actual DSCR for this deal.

The top three performing conduit loans represent 13% of the
pool balance. The largest loan is the 15555 Lundy Parkway Loan
($31 million -- 4.9% of the pool), which is secured by a two Class
A suburban office buildings located in Dearborn, Michigan. The two
buildings are connected by a center lobby/atrium and contain
453,000 square feet (SF). The property is 100% leased to the Ford
Motor Company (Ford) under a 15-year bondable net lease through
December 2016. The loan is coterminous with the lease term and
fully amortizes. Moody's LTV and stressed DSCR are 50% and 1.93X,
respectively, compared to 55% and 1.78X at last review.

The second largest loan is the Scholls Ferry Boulevard Loan
($28 million -- 4.4% of the pool), which is secured by an eleven
building, 203,000 SF mixed-use complex located in Beaverton,
Oregon. The property was 89% leased as of July 2011 compared to
87% at last review. Nineteen percent of the rent roll expires in
2011-12. Moody's LTV and stressed DSCR are 88% and 1.20X,
respectively, compared to 85% and 1.24X at last review.

The third largest loan is the Plaza at Cedar Hill Loan
($25 million -- 3.9% of the pool), which is secured by a 300,000
SF community retail center located in Cedar Hill, Texas. The
property was only 75% leased as of June 2011 compared to 97% at
2010 year end. However, Toys R Us signed a lease for 12% of the
net rentable area, which began on August 31, 2011. Moody's LTV and
stressed DSCR are 104% and 0.99X, respectively, compared to 125%
and 0.82X at last review.


GMAC 1999-C3: Moody's Reviews B1 Cl. H Notes Rating for Downgrade
-----------------------------------------------------------------
Moody's Investors Service (Moody's) placed two class of GMAC
Commercial Mortgage Securities, Inc. Mortgage Pass-Through
Certificates, Series 1999-C3 on review for possible downgrade:

Cl. G, A1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 27, 2011 Confirmed at A1 (sf)

Cl. H, B1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 27, 2011 Downgraded to B1 (sf)

RATINGS RATIONALE

The classes were placed on review for possible downgrade due to a
spike in interest shortfalls caused by the master servicer,
Berkadia Commercial Mortgage LLC, (Berkadia) recovering
outstanding advances on three specially serviced loans.

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review. Moody's prior full review is
summarized in a press release dated April 27, 2011.

The methodologies used in this rating were "Moody's Approach to
Rating Fusion U.S. CMBS Transactions" published in April 2005, and
"Moody's Approach to Surveillance of CMBS Large Loan/Single
Borrower Transactions," published March 2006.

DEAL PERFORMANCE

As of the October 17, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 96% to $45 million
from $1.15 billion at securitization. The Certificates are
collateralized by nine mortgage loans ranging in size from 1% to
14% of the pool. Two loans, representing 34% of the pool, have
defeased and are collateralized by U.S. Government securities.

No loans in 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, representing 47% of the pool, are currently in special
servicing. Nineteen loans have been liquidated from the pool since
securitization, resulting in an aggregate $26 million loss (16%
average loss severity).

Based on the most recent remittance statement, Classes G through N
have experienced cumulative interest shortfalls totaling $5
million. 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 subordinate entitlement reductions (ASERs) and
extraordinary trust expenses.

Moody's review will focus primarily on the interest shortfalls.


GOLDMAN SACHS: Fitch Affirms 'Bsf' Rating on Class F Certificate
----------------------------------------------------------------
Fitch Ratings has affirmed all classes of Goldman Sachs Commercial
Mortgage Capital, L. P. commercial mortgage pass-through
certificates, series 2010-C2.

Limited updated financial information was collected by the master
servicer (3%), which is not uncommon for a first review after
issuance.  Fitch's affirmations are based on the performance of
the underlying collateral pool, as no loans have been delinquent
or specially serviced since issuance.

The performance of the underlying collateral pool has been stable
with minimal changes since issuance.  The transaction is
geographically diversified across 32 states and Puerto Rico.
However, the transaction has high loan concentration with
the top ten loans representing 51.8% of the pool and the top 15
representing 65.2%.  Fitch has identified one loan (0.9%) as a
Fitch Loan of Concern due to the closing of Borders Books, the
largest tenant, which occupied 26% of the property.

As of October 2011 distribution date, the pool's aggregated
principal balance has been reduced by 0.7% to $869.4 million from
$876.5 million at issuance.

The largest loan of the pool (10.1%) is secured by a 399,935
square feet (SF) class B office property in the Financial District
submarket of Manhattan, NY.  The property is 100% occupied by the
United Federation of Teachers (UFT) under a long-term lease which
expires in August 2034.  UFT also holds 9.9% ownership interest in
the building. The loan is structured with a letter of credit (LOC)
which can be drawn upon to cover debt service shortfalls.

The second largest loan of the pool (7.4%) is secured by two class
B office properties totaling 1.15 million SF in Cleveland, OH.  As
of June 2011, the combined occupancy of the two properties was
77.7% compared to 78.8% at issuance.

The third largest loan of the pool (7.1%) is secured by a 669,682
SF mixed-use office retail property in Pittsburgh, PA.  The
property is considered an area landmark and tourist destination.
It consists of five buildings that house office space, retail
shops, restaurants, commuter parking, and night clubs, in addition
to river docks, marina slips, and an outdoor amphitheater.  As of
June 2011, the property was 85% occupied compared to 84.6% at
issuance.

Fitch affirms the following classes and maintains the Stable
Outlook:

-- $334 million class A-1 'AAAsf';
-- $376 million class A-2 'AAAsf';
-- $710 million class X-A 'AAAsf';
-- $26.3 million class B 'AAsf';
-- $29.6 million class C 'Asf';
-- $47.1 million class D 'BBB-sf';
-- $12 million class E 'BBsf';
-- $9.9 million class F 'Bsf'.

Fitch does not rate the IO class X-B and the $28.5 million
class G.


GS MORTGAGE: Fitch Junks Rating on Five Notes Classes
-----------------------------------------------------
Fitch Ratings downgrades five classes of GS Mortgage Securities
Corporation II, series 2006-GG6, commercial mortgage pass-through
certificates, due to further deterioration of performance,
increased loss expectations on the specially serviced loans and
realized losses from dispositions.

The downgrades reflect a slight increase in Fitch modeled losses
across the pool combined with greater certainty of losses for the
loans in special servicing.  Fitch modeled losses of 10.4% (10.6%
cumulative transaction losses, which includes losses realized to
date) based on expected losses on the specially serviced loans and
loans that could not refinance at maturity.

As of the October 2011 distribution date, the pool's aggregate
principal balance has decreased 17.8% to $3.2 billion from
$3.9 billion at issuance.  As of October 2011, there are
cumulative interest shortfalls in the amount of $21.3 million,
currently affecting classes F through S.  Fitch has designated
65 loans (39.2%) as Fitch Loans of Concern, which includes 25
specially serviced loans (23.7%).

The largest contributor to losses is the Showplace Portfolio loan
(1.1%).  The loan had a balance of $78.3 million which was written
down to $36.8 million as part of a modification.  The loan is
secured by five properties comprising 699,474 square feet (sf)
located in High Point, North Carolina.  The properties contain
showroom (72.9% of NRA), office/retail space (15.8% of NRA) as
well as exhibition space (11.2% of NRA).  The properties are
situated in an area known as the International Home Furnishings
Market, an area of High Point that consists of more than
12 million sf of showroom and exhibition space across 180
buildings that serve the home furnishing industry.

The loan transferred to the special servicer in November 2010 for
maturity default.  The portfolio was sold in July 2011 and the
loan was assumed, extended and the principal balance was written
down.  Realized losses have been incurred by the trust as a result
of the write down.  The loan remains more than 90 days delinquent,
but is expected to be made current and returned to the master
servicer once the modification is finalized.

The second largest contributor to loss is the Silver Creek
Portfolio Phase I loan (2.1%), which is secured by 37 cross-
collateralized and cross-defaulted retail strip shopping centers
totaling 636,166 sf located across 17 states primarily in the mid-
west. Thirty of the properties (87.7% NRA) are shadow-anchored by
Super Wal-Marts, while the remaining seven are unanchored. The
loan transferred to the special servicer in January 2010 for
monetary default.  Decreasing occupancy levels and continued
pressure on rental rates are the primary causes of the performance
decline.  The special servicer continues to negotiate with the
borrower while dual tracking foreclosure. A recent appraisal
indicates significant losses. The loan is more than 90 days
delinquent.

The third largest contributor to losses is the Atrium at Empire
Lakes loan (1.6%) which is collateralized by a two-story, 390,480
sf office building located in Rancho Cucamonga, California.  The
loan transferred to the special servicer in June 2009 when the
largest tenant (75% of NRA) vacated the premises.  There has been
some progress in leasing but the environment remains challenging
and the property is 37% occupied.  A recent appraisal indicates
significant losses.  The loan is more than 90 days delinquent.

Fitch has downgraded these classes as indicated:

  -- $43.9 million class F to 'CCsf/RR3' from 'CCCsf/RR3';
  -- $39 million class H to 'Csf/RR6' from 'CCsf/RR6';
  -- $43.9 million class J to 'Csf/RR6' from 'CCsf/RR6';
  -- $43.9 million class K to 'Csf/RR6' from 'CCsf/RR6';
  -- $24.4 million class L to 'Csf/RR6' from 'CCsf/RR6'.

Additionally, Fitch has affirmed and assigned Recovery these
classes:

  -- $579.5 million class A-2 at 'AAAsf'; Outlook Stable;
  -- $75.6 million class A-3 at 'AAAsf'; Outlook Stable;
  -- $169.5 million class A-AB at 'AAAsf'; Outlook Stable;
  -- $1 billion class A-4 at 'AAAsf'; Outlook Stable;
  -- $288.2 million class A-1A at 'AAAsf'; Outlook Stable;
  -- $390.1 million class A-M at 'AAAsf'; Outlook Stable;
  -- $292.6 million class A-J at 'BBB-'; Outlook Negative.
  -- $19.5 million class B at 'BBsf'; Outlook Negative;
  -- $48.8 million class C at 'Bsf'; Outlook Negative;
  -- $39 million class D at 'CCCsf/RR1';
  -- $29.3 million class E at 'CCCsf/RR1';
  -- $39 million class G at 'CCsf/RR4';
  -- $14.6 million class M at 'Csf/RR6';
  -- $19.5 million class N at 'Csf/RR6'.

Class A-1 has been paid in full. Class S is not rated by Fitch.
Classes O, P and Q have realized losses and remain at 'Dsf/RR6'.
Fitch withdrew the ratings of the interest only classes X-C and X-
P. (For additional information, see 'Fitch Revises Practice for
Rating IO & Pre-Payment Related Structured Finance Securities',
dated June 23, 2010.)


GSC GROUP: Moody's Raises Rating of Class C Notes to 'Ba2'
----------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by GSC Group CDO Fund VIII, Limited:

US$14,000,000 Class A-2 Floating Rate Senior Notes Due 2021,
Upgraded to A1 (sf); previously on June 22, 2011 A2 (sf) Placed
Under Review for Possible Upgrade

US$19,400,000 Class B Deferrable Floating Rate Notes Due 2021,
Upgraded to Baa1 (sf); previously on June 22, 2011 Ba1 (sf) Placed
Under Review for Possible Upgrade

US$17,000,000 Class C Deferrable Floating Rate Notes Due 2021,
Upgraded to Ba2 (sf); previously on June 22, 2011 B1 (sf) Placed
Under Review for Possible Upgrade

US$13,000,000 Class D Deferrable Floating Rate Notes Due 2021
(current outstanding balance of $9,152,596), 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$267,000,000 Class A-1 Floating Rate Senior Notes Due 2021
(current outstanding balance of $252,851,888), Confirmed at Aa1
(sf); previously on June 22, 2011 Aa1 (sf) Placed Under Review for
Possible Upgrade

RATINGS RATIONALE

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

The actions also reflect the consideration of credit improvement
of the underlying portfolio since the rating action in July 2009.
Based on the latest trustee report dated August 19, 2011, the
weighted average rating factor is currently 2664 compared to 3199
in June 2009. In the same report, Class A, Class B, Class C, and
Class D overcollateralization ratios are reported at 121.20%,
113.00%, 106.67%, and 103.56%, respectively, versus June 2009
levels of 117.23%, 109.58%, 103.66%, and 99.54%, respectively. All
related overcollateralization tests are currently in compliance.
In particular, the Class D overcollateralization has increased in
part due to the diversion of excess interest to delever the Class
D notes in the event of a Class D overcollateralization test
failure when all other overcollateralization tests are passing.
Since the last rating action in July 2009, $3.8 million of
interest proceeds have reduced the outstanding balance of the
Class D notes by 29.6%.

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 $320.96 million,
defaulted par of $5.7 million, a weighted average default
probability of 22.94% (implying a WARF of 2889), a weighted
average recovery rate upon default of 49.9%, 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.

GSC Group CDO Fund VIII, Limited, issued in March 2007, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans, with significant exposure to senior secured
loans of middle market issuers.

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 generally analyzes the impact of assuming the
worse of reported and covenanted values for weighted average
rating factor, weighted average spread, and diversity score.
However, as part of the base case, Moody's considered spread
levels higher than the covenant level due to the large difference
between the reported and covenant levels.

4) 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 with 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.


GSC PARTNERS: Moody's Raises Rating of Class D Notes to 'Ba2'
-------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by GSC Partners CDO Fund VI, Ltd.:

US$28,800,000 Class A-2 Floating Rate Senior Notes Due 2017,
Upgraded to Aaa (sf); previously on June 22, 2011 Aa1 (sf) Placed
Under Review for Possible Upgrade;

US$37,000,000 Class B Deferrable Floating Rate Notes Due 2017,
Upgraded to Aa3 (sf); previously on June 22, 2011 A3 (sf) Placed
Under Review for Possible Upgrade;

US$4,300,000 Class C-1 Deferrable Fixed Rate Notes Due 2017,
Upgraded to A3 (sf); previously on June 22, 2011 Baa3 (sf) Placed
Under Review for Possible Upgrade;

US$8,700,000 Class C-2 Deferrable Floating Rate Notes Due 2017,
Upgraded to A3 (sf); previously on June 22, 2011 Baa3 (sf) Placed
Under Review for Possible Upgrade;

US$21,000,000 Class D Deferrable Floating Rate Notes Due 2017
(current outstanding balance of $20,933,923.93), Upgraded to Ba2
(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 $327.8 million,
defaulted par of $13.98 million, a weighted average default
probability of 19.89% (implying a WARF of 3298), a weighted
average recovery rate upon default of 50.46%, and a diversity
score of 46. 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.

GSC Partners CDO Fund VI, Limited, issued in October 2005, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans with significant exposures to loans of middle
market issuers.

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 the future pace of delevering from unscheduled principal
proceeds. 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) 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.



GSC PARTNERS: Moody's Upgrades Rating of Class E Notes to 'Ba3'
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by GSC Partners CDO Fund VII, Limited:

US$45,600,000 Class B Notes, Upgraded to Aaa (sf); previously on
June 22, 2011 A1 (sf) Placed Under Review for Possible Upgrade;

US$29,000,000 Class C Notes, Upgraded to A1 (sf); previously on
June 22, 2011 Baa3 (sf) Placed Under Review for Possible Upgrade;

US$21,700,000 Class D Notes, Upgraded to Baa2 (sf); previously on
June 22, 2011 Ba3 (sf) Placed Under Review for Possible Upgrade;

US$17,750,000 Class E Notes, Upgraded to Ba3 (sf); previously on
June 22, 2011 Caa3 (sf) Placed Under Review for Possible Upgrade.

RATINGS RATIONALE

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

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 $326.3 million,
defaulted par of $27.5 million, a weighted average default
probability of 24.33% (implying a WARF of 3768), a weighted
average recovery rate upon default of 48.66%, and a diversity
score of 52. 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.

GSC Partners CDO Fund VII, Limited, issued in May 2006, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans with significant exposure to middle market
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) 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.

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.


HARRISBURG PARKING: Moody's Reviews 'Ba3' Rating of Series T Bonds
------------------------------------------------------------------
Moody's Investors Service has placed on review for possible
downgrade the Ba3 rating for Harrisburg Parking Authority's (HPA)
outstanding Guaranteed Parking Revenue Bonds, Series T of 2007,
affecting $18 million in outstanding debt.

RATINGS RATIONALE

The action follows the City of Harrisburg's petition for federal
bankruptcy protection under Chapter 9. A hearing to consider the
legality of the city's petition is scheduled for November 23,
2011. Moody's review will consider impact of the city's bankruptcy
filing on the assets and revenues supporting the parking debt,
taking into account the provisions of the bond indentures as well
as possible actions that could occur during bankruptcy, if the
filing is upheld

The principal methodology used in this rating was General
Obligation Bonds Issued by U.S. Local Governments published in
October 2009.


HARTFORD MEZZANINE: S&P Lowers Rating on Class J to 'CCC-'
----------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on five
classes from Hartford Mezzanine Investors I-CRE CDO 2007-1 Ltd.
(Hartford I CRE CDO), a commercial real estate collateralized debt
obligation (CRE CDO) transaction. "At the same time, we affirmed
our ratings on seven other classes from the same transaction," S&P
related.

"The rating actions follow our analysis of the transaction and
primarily reflect the deterioration in the transaction's
collateralization ratio. As of the Sept. 23, 2011, trustee report,
the transaction's collateral totaled $391.1 million, while its
liability totaled $422.3 million," S&P related.

The rating actions also reflect the reported $17.4 million (4.5%)
in defaulted assets in the transaction's collateral pool. The
volume of defaulted assets has caused further deterioration in the
transaction's collateralization.

According to the Sept. 23, 2011 trustee report, the transaction's
current asset pool included:

    11 subordinate-interest loans ($189.4 million, 48.4%);

    Six whole and senior-participation loans ($141.2 million,
    36.1%);

    One credit-tenant loan ($32.0 million, 8.2%);

    Cash ($18.5 million, 4.7%); and

    One commercial mortgage-backed securities (CMBS) tranche
    ($10.0 million, 2.6%).

Standard & Poor's reviewed and updated credit estimates for all
of the nondefaulted loan assets. "We based the analyses on our
adjusted net cash flow, which we derived from the most recent
financial data provided by collateral managers, Key Real Estate
Equity Capital Inc. and Hartford Investment Management Co., and
the trustee, Wells Fargo Bank N.A., as well as market and
valuation data from third-party providers," S&P related.

According to the trustee report, the transaction includes two
defaulted loan assets:

    The Spanish Peaks first mortgage loan ($13.8 million, 3.5%);
    and

    The 175 Fulton Avenue subordinate interest loan ($3.7 million,
    0.9%).

Standard & Poor's estimated a 42% weighted average asset-specific
recovery rate for the Spanish Peaks and 175 Fulton Avenue assets.
"We based the recovery rates on information from the collateral
manager, special servicer, and third-party data providers," S&P
related.

"We analyzed the transaction and its underlying collateral assets
according to our current criteria. Our analysis is consistent with
the lowered and affirmed ratings," S&P said.

Ratings Lowered

Hartford Mezzanine Investors I-CRE CDO 2007-1 Ltd.
Collateralized debt obligations
                  Rating
Class     To                   From
E         BB (sf)              BB+ (sf)
F         B+ (sf)              BB- (sf)
G         B- (sf)              B+ (sf)
H         CCC+ (sf)            B (sf)
J         CCC- (sf)            CCC+ (sf)

Ratings Affirmed

Hartford Mezzanine Investors I-CRE CDO 2007-1 Ltd.
Collateralized debt obligations

Class     Rating
A-1       A- (sf)
A-2       BBB+ (sf)
A-3       BBB- (sf)
B         BB+ (sf)
C         BB+ (sf)
D         BB+ (sf)
K         CCC- (sf)


HIGHLAND PARK: Moody's Downgrades Rating of Cl. A-1 Notes to 'B3'
-----------------------------------------------------------------
Moody's has affirmed the ratings of six classes and downgraded one
class of Notes issued by Highland Park CDO I due to deterioration
in the underlying collateral as evidenced by the Moody's weighted
average rating factor (WARF) and recovery rate (WARR). The
affirmations are due to 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, Downgraded to B3 (sf); previously on Oct 20, 2010
Downgraded to B1 (sf)

Cl. A-2, Affirmed at Caa3 (sf); previously on Oct 20, 2010
Downgraded to Caa3 (sf)

Cl. B, Affirmed at Ca (sf); previously on Oct 20, 2010 Downgraded
to Ca (sf)

Cl. C, Affirmed at C (sf); previously on Oct 20, 2010 Downgraded
to C (sf)

Cl. D, Affirmed at C (sf); previously on Oct 20, 2010 Downgraded
to C (sf)

Cl. E, Affirmed at C (sf); previously on Oct 20, 2010 Downgraded
to C (sf)

Cl. F, Affirmed at C (sf); previously on Oct 20, 2010 Downgraded
to C (sf)

RATINGS RATIONALE

Highland Park CDO I is a revolving cash CRE CDO transaction backed
by a portfolio of commercial mortgage backed securities (CMBS)
(31.8% of the pool balance), commercial real estate CDOs (6.0%),
real estate investment trust (REIT) debt (3.0%), one synthetic
contract (3.8%), real estate bank loans (22.1%), whole loans
(9.7%), B-Notes (17.2%) and mezzanine loans (6.4%). The
reinvestment period is to end in February 2012. As of the
September 30, 2011 Trustee report, the aggregate Note balance
of the transaction, including preferred shares, decreased to
$572.0 million from $600.0 million at issuance, with a portion
of the interest payments redirected as principal to paydown the
Class A-1 Notes, as a result of failing one or more parvalue test.

There are 25 assets with a par balance of $164.1 million (32.6% of
the current pool balance) that are considered Impaired Securities
as of the September 30, 2011 Trustee report. 8 of these assets
(36.1% of the impaired balance) are real estate bank loans, 14
asset is CMBS (51.4%), and 3 assets are commercial real estate
CDOs (12.5%). Impaired Securities that are not CMBS or commercial
real estate CDOs are defined as assets which are 60 or more days
delinquent in their debt service payment. While there have been
losses/writeoffs in the amount of approximately $82.0 million 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: weighted average
rating factor (WARF), weighted average life (WAL), weighted
average recovery rate (WARR), and Moody's asset correlation (MAC).
These parameters are typically modeled as actual parameters for
static deals and as covenants for managed deals.

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's has completed updated credit estimates for the non-Moody's
rated collateral. The bottom-dollar WARF is a measure of the
default probability within a collateral pool. Moody's modeled a
bottom-dollar WARF of 7,784 compared to 7,516 at last review. The
distribution of current ratings and credit estimates is as
follows: Aaa-Aa3 (1.2% compared to 1.0% at last review), A1-A3
(0.0% compared to 0.2% at last review), Baa1-Baa3 (0.0% compared
to 1.6% at last review), Ba1-Ba3 (17.4% compared to 10.6% at last
review), B1-B3 (2.4% compared to 9.5% at last review), and Caa1-C
(79.0% compared to 77.0% 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 3.7 years compared
to 3.4 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
18.6% compared to 18.1% 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 14.6% compared to 11.3% 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
18.6% to 8.6% or up to 28.6% would result in average rating
movement on the rated tranches of 0 to 1 notch downward and 0 to 1
notch upward, respectively.

The performance expectations for a given variable indicate Moody's
forward-looking view of the likely range of performance over the
medium term. From time to time, Moody's may, if warranted, change
these expectations. Performance that falls outside the given range
may indicate that the collateral's credit quality is stronger or
weaker than Moody's had anticipated when the related securities
ratings were issued. Even so, a deviation from the expected
range will not necessarily result in a rating action nor does
performance within expectations preclude such actions. The
decision to take (or not take) a rating action is dependent on an
assessment of a range of factors including, but not exclusively,
the performance metrics. Primary sources of assumption uncertainty
are the current sluggish macroeconomic environment and 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 methodologies used in this rating were "Moody's Approach to
Rating SF CDOs" published in November 2010, and "Moody's Approach
to Rating Commercial Real Estate CDOs" published in July 2011.


INA CBO: S&P Lowers Rating on Class A-3 Notes to 'D'
---------------------------------------------------
Standard & Poor's Ratings Services lowered its rating to 'D (sf)'
on the class A-3 notes and withdrew its ratings on two classes
other classes of notes from INA CBO 1999-1 Ltd. INA CBO 1999-1
Ltd. is a CDO transaction backed by high-yield corporate bonds.

"We lowered the rating on the class A-3 notes to 'D (sf)'
following a principal shortfall of the notes at maturity. The
proceeds from the liquidation of the collateral were insufficient
to pay the outstanding principal balance on the class A-3 notes in
full. We withdrew the ratings on the class A-2F and A-2
notes following their full repayment at maturity," S&P related.

Rating Lowered

INA CBO 1999-1 Ltd.
                    Rating
Class          To           From
A-3            D (sf)       CC (sf)

Ratings Withdrawn

INA CBO 1999-1 Ltd.
                    Rating
Class           To          From
A-2F            NR          CCC- (sf)
A-2             NR          CCC- (sf)

NR -- Not rated.


INDYMAC MORTGAGE: S&P Raises Rating on Class A-1 to 'CCC'
---------------------------------------------------------
Standard & Poor's Ratings Services corrected its rating on
class A-1 from IndyMac INDX Mortgage Loan Trust 2006-AR13
(IndyMac 2006-AR13) by raising it to 'CCC (sf)' from 'D (sf)'.
"In addition, we affirmed our ratings on two other classes from
the same transaction (see ratings list). IndyMac 2006-AR13 is a
residential mortgage-backed securities (RMBS) Alternative-A (Alt-
A) transaction," S&P related.

"On Nov. 24, 2010, we downgraded our rating on class A-1 based on
the trustee's October 2010 remittance report, which had indicated
that this class had experienced a principal write-down. However,
the trustee subsequently issued a revised remittance report during
the June 2011 distribution period, which removed the realized loss
amount previously allocated to this class," S&P related.

"The rating actions reflect our view that the current projected
credit support likely will be insufficient to meet the projected
loss amount for all three classes," S&P said.

The following is the pool information for IndyMac INDX Mortgage
Loan Trust 2006-AR13 as of Sept. 25, 2011:

Original    Pool  Lifetime loss    Total    Severe
balance   factor     projection  delinq.   delinq.
(mil $)      (%)            (%)      (%)       (%)
400.58     50.11          24.59    60.68     23.43

"In the table, the original balance represents the original pool
balance; the pool factor represents a percentage of the original
pool balance remaining; the lifetime loss projection is a
percentage of the original pool balance; and total and severe
delinquencies are percentages of the current pool balance," S&P
related.

"To assess the creditworthiness of each class, we reviewed the
individual delinquency and loss trends of each transaction for
changes, if any, in the ability to withstand additional credit
deterioration. In order to maintain a 'B' rating on a class, we
assessed whether, in our view, a class could absorb the additional
base-case loss assumptions we used in our analysis," S&P said.

Subordination, overcollateralization (prior to depletion), and
excess spread provide credit support for this transaction. The
underlying collateral for this transaction consists of
Alternative-A (Alt-A) mortgage loans secured by first liens on
one- to four-family residential properties.

Rating Corrected

IndyMac INDX Mortgage Loan Trust 2006-AR13
Series 2006-AR13
                             Rating
Class CUSIP      Current   Nov. 24, 2010  Pre-Nov. 24, 2010
A-1   45661XAA0  CCC (sf)  D (sf)         CCC (sf)

Ratings Affirmed

IndyMac INDX Mortgage Loan Trust 2006-AR13
Series 2006-AR13

Class      CUSIP         Rating
A-2        45661XAB8     CCC (sf)
A-3        45661XAD4     CCC (sf)


JPMCC 2005-CIBC11: Moody's Affirms Class F Notes Rating at 'Ba1'
----------------------------------------------------------------
Moody's Investors Service (Moody's) downgraded the ratings four
classes and affirmed 17 classes of J.P. Morgan Chase Commercial
Mortgage Trust, Commercial Mortgage Pass-Through Certificates,
Series 2005-CIBC11:

Cl. A-3, Affirmed at Aaa (sf); previously on May 25, 2005
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on May 25, 2005
Definitive Rating Assigned Aaa (sf)

Cl. A-1A, Affirmed at Aaa (sf); previously on May 25, 2005
Definitive Rating Assigned Aaa (sf)

Cl. A-SB, Affirmed at Aaa (sf); previously on May 25, 2005
Definitive Rating Assigned Aaa (sf)

Cl. A-J, Affirmed at Aaa (sf); previously on May 25, 2005
Definitive Rating Assigned Aaa (sf)

Cl. A-JFL, Affirmed at Aaa (sf); previously on May 25, 2005
Definitive Rating Assigned Aaa (sf)

Cl. B, Affirmed at Aa2 (sf); previously on Feb 24, 2011 Confirmed
at Aa2 (sf)

Cl. C, Affirmed at Aa3 (sf); previously on Feb 24, 2011 Confirmed
at Aa3 (sf)

Cl. D, Affirmed at A3 (sf); previously on Feb 24, 2011 Downgraded
to A3 (sf)

Cl. E, Affirmed at Baa1 (sf); previously on Feb 24, 2011
Downgraded to Baa1 (sf)

Cl. F, Affirmed at Ba1 (sf); previously on Feb 24, 2011 Downgraded
to Ba1 (sf)

Cl. G, Downgraded to B1 (sf); previously on Feb 24, 2011
Downgraded to Ba2 (sf)

Cl. H, Downgraded to Caa1 (sf); previously on Feb 24, 2011
Downgraded to B3 (sf)

Cl. J, Downgraded to Caa2 (sf); previously on Feb 24, 2011
Downgraded to Caa1 (sf)

Cl. K, Downgraded to Caa3 (sf); previously on Feb 24, 2011
Downgraded to Caa2 (sf)

Cl. L, Affirmed at Caa3 (sf); previously on Feb 24, 2011
Downgraded to Caa3 (sf)

Cl. M, Affirmed at Ca (sf); previously on Feb 24, 2011 Downgraded
to Ca (sf)

Cl. N, Affirmed at C (sf); previously on Feb 24, 2011 Downgraded
to C (sf)

Cl. P, Affirmed at C (sf); previously on Feb 24, 2011 Downgraded
to C (sf)

Cl. X-1, Affirmed at Aaa (sf); previously on May 25, 2005
Definitive Rating Assigned Aaa (sf)

Cl. X-2, Affirmed at Aaa (sf); previously on May 25, 2005
Definitive Rating Assigned Aaa (sf)

RATINGS RATIONALE

The downgrades are due to higher expected losses for the pool
resulting from realized and anticipated losses from specially
serviced and troubled loans and an increase in interest shortfalls
since the prior review.

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

Moody's rating action reflects a cumulative base expected loss of
4.1% of the current balance. At last review, Moody's cumulative
base expected loss was 3.0%. Moody's stressed scenario loss is
11.9% of the current balance. Moody's base expected loss is a
function of the total anticipated losses for the loans remaining
in the pool. 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 principal 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 credit neutral Herf score is 40. The
pool has a Herf of 32 compared to 33 at Moody's prior review.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review. Moody's prior full review is
summarized in a press release dated February 24, 2011.

DEAL PERFORMANCE

As of the October 12, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 20% to $1.43
billion from $1.80 billion at securitization. The Certificates are
collateralized by 131 mortgage loans ranging in size from less
than 1% to 9% of the pool, with the top ten loans representing 45%
of the pool. Seven loans, comprising 4% of the pool, have been
fully defeased by US Government securities. The pool does not
contain any loans with investment grade credit estimates.

Twenty-eight loans, representing 10% 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 have been liquidated from the pool, resulting in a
realized loss of $16.8 million (33% loss severity). Currently 14
loans, representing 16% of the pool, are in special servicing. The
largest specially serviced loan is the Southridge Mall Loan
($124.0 million -- 8.7% of the pool), which is collateralized by
the 617,000 square foot (SF) in-line portion of a 1.2 million SF
mall located in Greendale, Wisconsin. A prolonged struggle with
high vacancy due to the inability to re-lease space vacated by
tenant bankruptcies resulted in the loan being transferred to
special servicing in February 2011 to facilitate a modification of
the loan terms. The loan modification closed in August 2011 and
includes a three year maturity date extension to April 2015 and a
$36 million redevelopment plan. The redevelopment plan will be
financed with $11.6 million of equity from the sponsor, an
additional $12.4 guaranty of equity from the borrower and
$12.0 million of tax incremental financing. Simon Properties is
the loan sponsor. The loan is expected to be transferred back to
the master servicer in the near term. Moody's does not currently
anticipate the trust to realize a loss from this loan.

The remaining 13 specially serviced loans are secured by a mix of
property types. Moody's estimates an aggregate $26.1 million loss
for ten of the specially serviced loans (43% expected loss on
average).

Moody's has assumed a high default probability for ten poorly
performing loans representing 3% of the pool and has estimated an
aggregate $9.3 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 99%
of the pool. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 88% compared to 92% at Moody's
prior review. Moody's net cash flow reflects a weighted average
haircut of 10% to the most recently available net operating
income. Moody's value reflects a weighted average capitalization
rate of 9.1%.

Excluding special serviced and troubled loans, Moody's actual and
stressed DSCRs are 1.48X and 1.17X, respectively, compared to
1.40X and 1.11X 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 19% of the pool. The largest
conduit loan is the Airport Industrial Park Loan ($102.7 million -
- 7.2% of the pool), which is secured by a 826,000 SF multi-level
warehouse and office complex located in Honolulu, Hawaii. Major
tenants include Hawaii Airlines (15% of the net rentable area
(NRA); lease expiration in 2016) and Duty Free Shopper (14% of the
NRA; lease expiration in 2015). As of July 2011, the property was
95% leased, which is in-line with the prior year and
securitization. Property performance has improved since
securitization due to an increase in revenue that has been only
partially offset by an increase in expenses. Moody's LTV and
stressed DSCR are 80% and 1.15X, respectively, compared to 88% and
1.10X at last review.

The second largest conduit loan is the Palm Spring Mile Loan
($97.3 million -- 6.8% of the pool), which is secured by a
1.17 million SF anchored retail center located in Hialeah,
Florida. The multi-building complex is arranged in a strip-style
format and was constructed in four phases. Phase I is commonly
known as Mall on the Mile, Phase II is commonly known as Palms
Springs Village, Phases III and IV are commonly known as Philips
Plaza and Shoppes at 49th, respectively. As July 2011, the
property was 97% leased, compared to 94% at last review. The
property has a diverse tenant base, with no tenant accounting for
more than 11% of the NRA. Performance has been stable. Moody's LTV
and stressed DSCR are 73% and 1.33X, respectively, compared to 76%
and 1.28X at last review.

The third largest conduit loan is the Memorial Office Portfolio
Loan ($71.7 million -- 5.0% of the pool), which is secured by one
Class A and three Class B office properties located in Houston,
Texas. As of June 2011, the complex was 94% leased compared to 89%
in both March 2010 and at securitization. Property performance has
been stable but Moody's analysis incorporated near term tenancy
risk due to the upcoming expirations of leases accounting for
approximately 25% of the portfolio's NRA. Moody's LTV and stressed
DSCR are 70% and 1.43X, respectively, compared to 68% and 1.35X at
last review.


KATONAH VIII: S&P Raises Rating on Class D Notes to 'CCC+'
----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class A, B, C, and D notes from Katonah VIII CLO Ltd., a U.S.
collateralized loan obligation (CLO) transaction managed by
Katonah Debt Advisors. "At the same time, we removed our ratings
on the class A, B, and C notes from CreditWatch, where we placed
them with positive implications on Aug. 2, 2011," S&P related.

"The upgrades reflect improved performance we have observed
in the deal's underlying asset portfolio since we lowered
our ratings on all of the classes on Feb. 4, 2010, following
the application of our September 2009 corporate collateralized
debt obligation (CDO) criteria. As of the Sept. 20, 2011 trustee
report, the transaction's asset portfolio had $13.35 million
in defaulted obligations and approximately $17.44 million in
assets from obligors rated in the 'CCC' range. This was a decrease
from $42.66 million in defaulted obligations and approximately
$51.46 million in assets from obligors rated in the 'CCC' range
noted in the Dec. 18, 2009, trustee report, which we used for our
February 2010 rating actions," S&P related.

"We also observed an increase in the overcollateralization
available to support the rated notes," S&P said. The trustee
reported the following par value ratios in the Sept. 20, 2011,
monthly report:

    The class A/B par value ratio was 119.60%, compared with a
    reported ratio of 115.02% in December 2009;

    The class C par value ratio was 111.99%, compared with a
    reported ratio of 107.70% in December 2009; and

    The class D par value ratio was 104.02%, compared with a
    reported ratio of 99.51% in December 2009.

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

Rating And CreditWatch Actions

Katonah VIII CLO Ltd.
                        Rating
Class              To           From
A                  AA+ (sf)      AA (sf)/Watch Pos
B                  AA- (sf)      A+ (sf)/Watch Pos
C                  BBB+ (sf)     BBB (sf)/Watch Pos
D                  CCC+ (sf)     CCC- (sf)


KINDER MORGAN: S&P Puts 'BB' Rating on $10.574MM Certs. on Watch
----------------------------------------------------------------
Standard & Poor's Ratings Services placed its 'BB' rating on
Corporate Backed Trust Certificates Kinder Morgan Debenture-Backed
Series 2002-6's $10.574 million trust certificates on CreditWatch
with developing implications.

"Our rating on the certificates is dependent on our rating on the
underlying security, Kinder Morgan Inc.'s 7.45% senior secured
debentures due March 1, 2098 ('BB/Watch Dev')," S&P related.

"The rating action follows our Oct. 17, 2011, placement of our
'BB' rating on the underlying security on CreditWatch with
developing implications. We may take subsequent rating actions on
the certificates due to changes in our rating on the underlying
security," S&P said.


LIBERTY CLO: S&P Raises Rating on Class C Notes to 'B+'
-------------------------------------------------------
Standard & Poor's Ratings Services raised its rating on the class
C notes from Liberty CLO Ltd., a collateralized loan obligation
(CLO) transaction managed by Highland Capital Management L.P., and
removed it from CreditWatch with positive implications. "At the
same time, we affirmed our ratings on seven other classes and
removed three of them from CreditWatch with positive
implications," S&P related.

"The upgrade mainly reflects an improvement in the
overcollateralization (O/C) available to support the rated notes
since we lowered our ratings on all of the classes in February
2010. The increased support follows $15.5 million in paydowns to
the A-1 notes and a decrease in defaulted assets to $55.8 million
from $131.4 million as of the Nov. 30, 2009, report, which we
referenced for our February 2010 rating actions," S&P stated. As
of the Aug. 31, 2011, trustee report, each of the transaction's
O/C ratios has improved since November 2009:

    The class A O/C ratio is 117.3%, versus 112.2%;
    The class B O/C ratio is 109.5%, versus 104.9%; and
    The class C O/C ratio is 105.2%, versus 98.1%.

The improvement in the O/C ratios helps mitigate obligor
concentration risk in the portfolio, as the class C notes were
able to withstand the specified combination of underlying asset
defaults at the 'B (sf)' rating category in our largest obligor
default test.

The affirmations reflect the availability of credit support at the
current rating levels.

"We will continue to review our ratings on the notes and assess
whether, in our view, they remain consistent with the credit
enhancement available to support them and take rating actions as
we deem necessary," S&P related.

Rating And CreditWatch Actions

Liberty CLO Ltd.
                            Rating
Class                   To           From
A-3                     A+ (sf)      A+ (sf)/Watch Pos
A-4                     A- (sf)      A- (sf)/Watch Pos
B                       BB+ (sf)     BB+ (sf)/Watch Pos
C                       B+ (sf)      CCC- (sf)/Watch Pos

Ratings Affirmed

Liberty CLO Ltd.
Class                   Rating
A-1A                    AA+ (sf)
A-1B                    AA+ (sf)
A-1C                    AA+ (sf)
A-2                     AA+ (sf)


LNR CDO: S&P Affirms Ratings on 5 Classes at 'CCC-'
---------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on
seven classes from LNR CDO III Ltd., a commercial real estate
collateralized debt obligation (CRE CDO) transaction. "At the same
time, we affirmed our 'CCC- (sf)' ratings on five classes from the
same transaction," S&P related.

"The rating actions reflect our analysis of the transaction
after we downgraded 57 commercial mortgage-backed securities
(CMBS) certificates that serve as underlying collateral for LNR
CDO III Ltd. The downgraded certificates have a total balance of
$222.5 million (30.8% of the pool asset balance) and are from 22
CMBS transactions. We lowered our ratings on 48 of the 57
downgraded certificates ($177.8 million, 26.6%) to 'CCC (sf)'
or 'D (sf)'," S&P related.

"We lowered our ratings on classes H, J, and K to 'D (sf)' because
we determined it is unlikely that the classes will be repaid in
full," S&P said.

According to the Sept. 23, 2011 trustee report, LNR CDO III Ltd.
is collateralized by 171 CMBS certificates ($722.7 million, 100%)
from 47 distinct transactions issued between 1997 and 2004. The
reported liability for LNR CDO III Ltd. is $903.2 million.

LNR CDO III Ltd. has exposure to these CMBS certificates that
Standard & Poor's has downgraded:

    GS Mortgage Securities Corp. II's series 2004-GG2 (classes J
    through O; $42.6 million, 5.9%);

    Credit Suisse First Boston Mortgage Securities Corp.'s series
    2003-C4 (classes K through O; $24.3 million, 3.4%); and

    LB-UBS Commercial Mortgage Trust 2003-C8 (classes M through S;
    $20.2 million, 2.8%).

"We analyzed the transaction and its underlying collateral
assets in accordance with our current criteria. Our analysis is
consistent with the lowered and affirmed ratings," S&P related.

Ratings Lowered

LNR CDO III Ltd.
                       Rating
Class            To               From
A                B+ (sf)          BB (sf)
B                CCC- (sf)        B (sf)
C                CCC- (sf)        CCC+ (sf)
D                CCC- (sf)        CCC (sf)
H                D (sf)           CCC- (sf)
J                D (sf)           CCC- (sf)
K                D (sf)           CCC- (sf)

ratings affirmed

LNR CDO III Ltd.
Class            Rating
E-FL             CCC- (sf)
E-FX             CCC- (sf)
F-FL             CCC- (sf)
F-FX             CCC- (sf
G                CCC- (sf)


MIAMI-DADE FINANCE: Moody's Confirms B3 Ratings of 2006B-2 Bonds
----------------------------------------------------------------
Moody's Investors Service has confirmed the B3 rating of Miami-
Dade Housing Finance Authority Home Ownership Revenue Bonds Series
2006B-2 and removed it from review for possible upgrade, affecting
$825,000 of outstanding debt. The confirmation is based on Moody's
review that surplus funds in the master indenture may not be
available to support the 2006B-2 bonds.

STRENGTHS

* The 2006B-2 bonds maintain a high over-collateralization and
  have the ability to withstand substantial loan losses

CHALLENGES

* Lack of support from surplus revenues from within the parity
  indenture, other than the 2006B-1 bonds, result in more
  dependence on the second loan portfolio performance

* Since 2010 there have been concerns related the outstanding loan
  portfolio performance

* The second loan portfolio's negative credit characteristics,
  such as relatively small size, geographic concentration, and
  vintage

WHAT COULD MAKE THE RATING GO UP

* Significant and lasting improvement in the delinquency and
  foreclosure rates of the loan portfolio

* Material improvement in the Miami-Dade housing market (ie: price
  appreciation)

WHAT COULD MAKE THE RATING GO DOWN

* Worse-than-expected loan portfolio delinquencies or foreclosure
  rates

* A draw or reduction in the debt service reserve fund

The principal methodology used in this rating was Strength in
Structure: Moody's Approach to Rating Single-Family Housing Bonds
Secured by Mortgage-Backed Securities published in October 1998.

The Global Scale Credit Ratings on this press release that are
issued by one of Moody's affiliates outside the EU are considered
EU Qualified by Extension and therefore available for regulatory
use in the EU.

For ratings issued on a program, series or category/class of debt,
this announcement provides relevant regulatory disclosures in
relation to each rating of a subsequently issued bond or note of
the same series or category/class of debt or pursuant to a program
for which the ratings are derived exclusively from existing
ratings in accordance with Moody's rating practices. For ratings
issued on a support provider, this announcement provides relevant
regulatory disclosures in relation to the rating action on the
support provider and in relation to each particular rating action
for securities that derive their credit ratings from the support
provider's credit rating. For provisional ratings, this
announcement provides relevant regulatory disclosures in relation
to the provisional rating assigned, and in relation to a
definitive rating that may be assigned subsequent to the final
issuance of the debt, in each case where the transaction structure
and terms have not changed prior to the assignment of the
definitive rating in a manner that would have affected the rating.

Information sources used to prepare the rating are parties
involved in the public information.

Moody's considers the quality of information available on the
rated entity, obligation or credit satisfactory for the purposes
of issuing a rating.


MONTEBELLO: Moody's Assigns Mig 2 Rating to $2.5 Million Trans
--------------------------------------------------------------
Issue: 2011-2012 Tax and Revenue Anticipation Notes; Rating: MIG
2; Sale Amount: $2,500,000; Expected Sale Date: 11/01/2011; Rating
Description: Tax and Revenue Anticipation Notes

Opinion

Moody's Investors Service has assigned a MIG 2 rating to
Montebello's $2.5 million Tax and Revenue Anticipation Notes

Moody's has also affirmed the city's Baa2 Issuer Rating and the
Ba1 rating on the city's 2000 Certificates of Participation
(Refunding and Capital Improvement Project) of which $14.5 million
remains outstanding. These COPs are secured by lease payments from
the city for use of the city's police building, city hall, and
approximately 7.6 acres of land underlying these facilities. There
is no outlook on these ratings which is a revision from the
previous negative outlook.

RATINGS RATIONALE

The short term rating on the city's notes reflects the generally
favorable projected ending General Fund (GF) cash balance for
2011-12, the reasonable assumptions underlying the cash flows and
the availability of alternate liquidity. The relatively small size
of the borrowing and the sound repayment schedule also figure
favorably in the rating. The city's still generally weak financial
position with a narrow GF cash margin at the end of 2010-11 is the
key negative credit factor. The lack of a recent cash flow
projection history and audited results for 2010-11 also weigh on
the rating.

The long term ratings continue to reflect the city's still very
narrow GF reserve position and the need for external borrowing for
near-term cash flow needs. It appears that city did make
significant progress in restoring budgetary balance in 2010-11,
and the 2011-12 adopted budget appears to be in balance, with an
expected GF surplus, which if realized, will restore some
operating flexibility. The removal of the negative outlook on the
ratings reflects these apparent improvements and the diminished
likelihood of further credit deterioration in the near term.
However, the city does not yet have externally audited results to
confirm the improvements of 2010-11. The city's 2010-11 annual
financial report/audit is expected by December 2011. As credit
positives, the rating continues to reflect the city's location at
the heart of the Los Angeles area economy, and the economy's
underlying long-term strength, notwithstanding the recent severe
recession. The city's favorable debt position with a modest direct
debt burden and manageable lease burden are also reflected in the
rating.

The two notch rating distinction between the Baa2 Issuer Rating
and the Ba1 on the COPs represents Moody's standard notching
differential for fixed asset leases relative to a California
city's Issuer Rating. Broadly speaking the two notches reflect the
risk of abatement and the narrower, GF security pledge for
abatement leases compared to the very strong, voter-approved
unlimited property tax pledge implied by the Issuer Rating (the
equivalent of a G.O. bond rating, in the absence of such debt for
a municipality).

KEY SHORT TERM CREDIT STRENGTHS

Relatively small size of the borrowing

Sizable alternate liquidity

KEY SHORT TERM CREDIT CHALLENGES

Narrow ending GF cash balance for 2010-11

Lack of recent history of cash flow projections

KEY LONG TERM CREDIT STRENGTHS

Relatively stable tax base.

Below average direct debt burden.

KEY LONG TERM CREDIT CHALLENGES

Very narrow General Fund reserves and available reserves in other
governmental funds.

Establish and maintain structurally balance budgets.

What could move the rating UP

Structural balance in the General Fund.

Significantly improved reserve and liquidity position.

Significant improvement in the city's socioeconomic profile.

What could move the rating DOWN

Further deterioration of the city's financial position.

Inability to balance the General Fund budget.

Significant amount of additional debt

The methodologies used in this rating were Bond Anticipation Notes
and Other Short-Term Capital Financings published in May 2007, and
General Obligation Bonds Issued by U.S. Local Governments
published in October 2009.


MORGAN STANLEY: Fitch Junks Rating on Five Note Classes
-------------------------------------------------------
Fitch Ratings downgrades five classes of Morgan Stanley Capital I
(MSCI) Trust, series 2006-IQ11, commercial mortgage pass through
certificates.

The downgrades are the result of an increase in expected losses
attributed primarily to specially serviced loans and losses from
the further deterioration in performing Fitch loans of concern.
The Fitch modeled losses of 5.4% (5.7% cumulative transaction
losses which includes losses realized to date) is an increase from
4.8% as of the last review.  Smaller-than-average class sizes
continue to make below investment grade rated bonds susceptible to
downgrade.

Fitch expects classes J thru O to be fully depleted by losses on
specially serviced loans and class H to be significantly impacted.
As of September 2011, there are cumulative interest shortfalls in
the amount of $6.4 million currently affecting classes G through
P.

As of the September 2011 distribution date, the pool's aggregate
principal balance has been paid down by 17.5% to $1.33 billion
from $1.6 billion at issuance.  There is one defeased loan
representing 0.6% of the pool.

Fitch has identified 39 loans (16.5%) as Fitch Loans of Concern,
which includes 14 specially serviced loans (10.6%).

In total, there are currently 14 loans (10.9%) in special
servicing, which consists of four loans (2.0%) as real estate
owned (REO), one loan (1.0%) in foreclosure, five loans (2.0%)
that are 30 to 90 days delinquent and four loans (5.9%) that are
current.

At Fitch's last review there were ten loans (7.8%) in special
servicing consisting of two loans (0.9%) that were REO, four loans
(2.6%)in foreclosure, three loans (0.7%) that were 30 to 90 days
delinquent and one loan (3.6%) that was current.

The largest specially serviced asset (4.1%) is a 530,856 square
foot (sf) industrial facility in Phoenix, AZ.  The loan
transferred to special servicing in November 2006 due to the
single tenant, LeNature, filing bankruptcy and vacating the space.
The property has since been re-tenanted by I/O Data Centers and is
100% occupied under a long-term lease. The loan remains current
and continues to perform in accordance with the executed
agreements, which included a $6 million principal paydown of the
loan. Fitch expects minimal losses, if any, on this loan.

The largest contributor to losses is the L3/Bulova Building
(1.05%) which is a 212,000 sf office building in downtown
Lancaster, PA.  The loan transferred to special servicing in April
2008 due to the single tenant, L3 Communications, vacating the
space and discontinuing payment of rent. The property is currently
in foreclosure proceedings.

The second largest contributor to losses is the Merritt Square
Mall property, which is a 478,040 sf, regional mall located on
Merritt Island in Florida.  The loan remains current; however,
performance has declined since 2009.  Occupancy decreased to 88%
at year-end 2010 from 94% at year-end 2009.  The debt service
coverage ratio (DSCR) has also decreased to 1.16 times (x) at
year-end 2010 from 1.42x at year-end 2009.  Based on a servicer
reported rent roll, 8.6% of the leases are expected to expire
prior to year-end 2012.

Fitch downgrades and assigns Rating Outlooks and Recovery Ratings
(RRs) to the following classes as indicated:

  -- $12.1 million class C to 'BBB-sf' from 'BBBsf'; Outlook
     Stable;
  -- $14.1 million class F to 'CCCsf/RR1' from 'Bsf';
  -- $18.2 million class G to 'CCsf/RR1' from 'CCCsf/RR3';
  -- $14.1 million class H to 'CCsf/RR5' from 'CCCsf/RR6';
  -- $8.1 million class J to 'Csf/RR6' from 'CCsf/RR6';

Additionally, Fitch affirms and assigns and/or revises Rating
Outlooks and RRs to the following classes as indicated:

  -- $305.4 million class A-1A at 'AAAsf'; Outlook Stable;
  -- $73.2 million class A-3 at 'AAAsf'; Outlook Stable;
  -- $490 million class A-4 at 'AAAsf'; Outlook Stable;
  -- $161.6 million class A-M at 'AAAsf'; Outlook Stable;
  -- $147.5 million class A-J at 'AAsf'; Outlook Stable;
  -- $30.3 million class B at 'Asf'; Outlook to Negative from
     Stable;
  -- $22.2 million class D at 'BBsf'; Outlook to Negative from
     Stable;
  -- $16.2 million class E at 'Bsf'; Outlook to Negative from
     Stable;
  -- $4 million class K at 'Csf/RR6';
  -- $4 million class L to 'Csf/RR6'.

Fitch does not rate classes M through P or class EI. Class A-1 and
A-2 have been paid in full.  Fitch withdraws the ratings of the
interest only classes X and X-Y.


MRU STUDENT: S&P Cuts Rating on Class D Notes From 'CCC-' to 'CC'
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on the class
D notes issued by MRU Student Loan Trust 2008-A to 'CC (sf)' from
'CCC- (sf)'. "Concurrently, we placed our 'B- (sf)' rating on the
class C notes issued by the same transaction on CreditWatch with
negative implications," S&P related.

"The downgrade reflects the high likelihood, in our opinion, that
class D will miss its timely interest payments in the near term.
The CreditWatch negative placement reflects the potential that
class C will also become more at risk of missing its timely
interest payments in the intermediate term," S&P said.

                    Transaction Performance

"As more loans in the pool have come into repayment over the past
year, the transaction has realized defaults at a pace that is
marginally faster than we had assumed for this point in its life
in our prior analysis. As a result of the faster realization of
expected defaults and lower levels of loans in active repayment
status (those loans not currently in in-school, grace, deferment,
forbearance, or 30-plus day delinquency status), combined with the
transaction's high cost of funds, credit enhancement has also
deteriorated faster than we anticipated," S&P said.

The transaction structure has certain parity-based trigger tests
that, if breached, can prioritize a principal payment to a class
before paying a subordinated class' interest payment (the
prioritized principal amount). "We believe the decreased credit
enhancement levels have increased the probability of certain
triggers being breached, which could result in the payment of a
prioritized principal amount. The prioritized principal amounts
can be paid from available funds and next period borrowings, which
we believe could deplete the amounts available to make timely
interest payments to classes D and C," S&P said.

                          Credit Enhancement

Each rated class has remaining credit enhancement provided by the
subordination of other classes and a small reserve account (with a
minimum of either $313,750 or the total outstanding note balance).
Additionally, the transaction documents allow for the use of next
period borrowings for certain current period waterfall payments.
Available funds for the next period decrease by any next period
borrowings used in the current period. "Our ratings currently
reflect our belief that the next period borrowings can be used to
pay certain prioritized principal amounts," S&P related.

                       Structural Details

When one of the transaction's parity-backed triggers is breached
on a subordinate class, available funds in the transaction's
payment waterfall are used to make principal payments to the
noteholders before paying interest to the affected class. "If the
transaction breaches certain triggers, we believe the prioritized
principal amount owed to noteholders may consume any remaining
available funds and credit enhancement, causing interest
shortfalls to the affected subordinate classes. For example,
noteholders will be owed a prioritized principal amount before any
interest is paid to class D if either the sum of the class A
through D note balances exceeds the assets (as defined in the
indenture) or the sum of the class A through C note balances
exceeds the assets (as defined in the indenture). Similarly,
noteholders will be owed a prioritized principal amount senior to
any payments of class C interest if the sum of the class A and B
note balances exceeds the assets (as defined in the indenture),"
S&P related.

"We believe that available funds will not be sufficient to pay
both the prioritized principal amounts and the class D interest in
the near term. Accordingly, we expect class D will have to draw on
the reserve account and access next period borrowings to make
timely interest payments to the class D noteholders. Thereafter,
we expect credit enhancement will be depleted causing missed
interest first to the class D noteholders and eventually to the
class C noteholders," S&P stated.

"In our opinion, the prioritized principal amounts, coupled with
the ability to use next period borrowings to pay prioritized
principal amounts to the noteholders prior to paying interest to
subordinated classes is a strength for the class A and B notes,"
S&P related.

"We did not place our ratings on the class A and B notes on
CreditWatch negative at this time because we do not believe there
is a greater than 50% likelihood that, based on our criteria, we
would lower either rating within the next 90 days," S&P said.

Standard & Poor's will continue to monitor collateral trends and
review its cash flow models in light of recent performance to
determine whether class C is more susceptible to a possible
interest shortfall and to determine if the remaining credit
enhancement for classes A and B is commensurate with their
current ratings.

Rating Lowered

MRU Student Loan Trust 2008-A
               Rating
Class   To                  From
D       CC(sf)              CCC-(sf)

Rating Placed on CreditWatch

MRU Student Loan Trust 2008-A
               Rating
Class   To                  From
C       B-(sf)/Watch Neg    B-(sf)


MSC 2006-SRR2: S&P Lowers Ratings on 3 Classes of Notes to 'D'
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on the
class O, P, and Q notes from SPGS SPC, acting for the account of
MSC 2006-SRR2 Segregated Portfolio to 'D (sf)' from 'CC (sf)'.

The downgrades follow a number of write-downs in the underlying
reference portfolio, which have caused the class O notes to incur
partial principal losses and the class P and Q notes to incur full
principal losses.


MSC 2007-HQ11: Moody's Affirms Rating of Cl. B Notes at 'Ba1'
-------------------------------------------------------------
Moody's Investors Service (Moody's) affirmed the ratings of 26
classes of Morgan Stanley Capital I Trust, Commercial Mortgage
Pass-Through Certificates, Series 2007-HQ11:

Cl. A-2, Affirmed at Aaa (sf); previously on Feb 28, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-3-1, Affirmed at Aaa (sf); previously on Feb 28, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-3-2, Affirmed at Aaa (sf); previously on Feb 28, 2007
Assigned Aaa (sf)

Cl. A-AB, Affirmed at Aaa (sf); previously on Feb 28, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on Feb 28, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-4-FL, Affirmed at Aaa (sf); previously on Feb 28, 2007
Assigned Aaa (sf)

Cl. A-1A, Affirmed at Aaa (sf); previously on Feb 28, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-M, Affirmed at Aa2 (sf); previously on Nov 18, 2010
Downgraded to Aa2 (sf)

Cl. A-MFL, Affirmed at Aa2 (sf); previously on Nov 18, 2010
Downgraded to Aa2 (sf)

Cl. A-J, Affirmed at Baa3 (sf); previously on Nov 18, 2010
Downgraded to Baa3 (sf)

Cl. B, Affirmed at Ba1 (sf); previously on Nov 18, 2010 Downgraded
to Ba1 (sf)

Cl. C, Affirmed at B2 (sf); previously on Nov 18, 2010 Downgraded
to B2 (sf)

Cl. D, Affirmed at Caa1 (sf); previously on Nov 18, 2010
Downgraded to Caa1 (sf)

Cl. E, Affirmed at Caa2 (sf); previously on Nov 18, 2010
Downgraded to Caa2 (sf)

Cl. F, Affirmed at Caa3 (sf); previously on Nov 18, 2010
Downgraded to Caa3 (sf)

Cl. G, Affirmed at Ca (sf); previously on Nov 18, 2010 Downgraded
to Ca (sf)

Cl. H, Affirmed at Ca (sf); previously on Nov 18, 2010 Downgraded
to Ca (sf)

Cl. J, Affirmed at Ca (sf); previously on Nov 18, 2010 Downgraded
to Ca (sf)

Cl. K, Affirmed at C (sf); previously on Nov 18, 2010 Downgraded
to C (sf)

Cl. L, Affirmed at C (sf); previously on Nov 18, 2010 Downgraded
to C (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. O, 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. X, Affirmed at Aaa (sf); previously on Feb 28, 2007 Definitive
Rating Assigned Aaa (sf)

RATINGS RATIONALE

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

Moody's rating action reflects a cumulative base expected loss of
10% of the current balance. At last review, Moody's cumulative
base expected loss was 9.5%. Moody's stressed scenario loss is 21%
of the current balance. 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 of 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, however the downside risks
to the outlook have risen since last quarter.

The principal 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
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 30 compared to 32 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.

DEAL PERFORMANCE

As of the October 17, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 10% to
$2.18 billion from $2.4 billion at securitization. The
Certificates are collateralized by 163 mortgage loans ranging in
size from less than 1% to 10% of the pool, with the top ten non-
defeased loans representing 48% of the pool.

Fourty-three 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.

Seven loans have been liquidated from the pool, resulting in a
realized loss of $25 million (11% loss severity). Currently 18
loans, representing 13% of the pool, are in special servicing. The
largest specially serviced loan is the Galleria at Pittsburgh
Mills loan ($133 million -- 6% of the pool), which is secured by a
1 million square foot regional mall located in Tarentum
Pennsylvania, which is about 22 miles north of Pittsburgh. The
property is anchored by Sears, JC penny, and Macys, with Macy's
space not included in the collateral. The loan was transferred to
special servicing in January 2011 due to the borrower's
notification of imminent default. The loan continues to perform
under a hard lockbox, and a modification and extension proposal
are under review.

The master servicer has recognized an aggregate $51 million
appraisal reduction for 12 of the 18 specially serviced loans.
Moody's has estimated an aggregate $81.3 million loss (33%
expected loss on average) for all of the specially serviced loans.

Moody's has also assumed a high default probability for 38 poorly
performing loans representing 18% of the pool. Moody's has
estimated a $58 million loss (15% expected loss based on a 50%
probability default) from the troubled loans.

Moody's was provided with full year 2010 operating results for 98%
of the pool. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 111% compared to 116% at Moody's
prior review. Moody's net cash flow reflects a weighted average
haircut of 10.6% 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 1.45X and 0.95X, respectively, compared to
1.46X and 0.92X 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 24.3% of the
pool balance. The largest loan is the One Seaport Plaza Loan
($225.0 million -- 10% of the pool), which is secured by a
1.0 million square foot Class A office building located in the
Insurance office submarket of Lower Manhattan. The loan is
interest only for the entire term and matures in 2017. Financial
performance has remained stable since last review. The property
was 100% leased as of June 2011, essentially the same at last
review and 97% at securitization. Moody's LTV and stressed DSCR
are 81% and 1.17x, respectively, compared to 82% and 1.15x at last
review.

The second largest loan is the 525 Seventh Avenue Loan
($172 million -- 8% of the pool), which is secured by a
463,818 square foot Class A office building located in the
Garment District office submarket of New York City. The loan
is interest only for the entire term, and matures in 2017.
Financial performance has improved since last review due to
higher occupancy. The property was 96% leased as of August 2011
compared to 94% at last review and 97% at securitization. Moody's
LTV and stressed DSCR are 126% and 0.77X, respectively, compared
to 128% and 0.76X at last review.

The third largest loan is the 485 Lexington Avenue Loan
($135 million -- 6% of the pool), which is secured by a 914,807
square foot Class A office building located in the Grand Central
Office Submarket of New York City. The loan represents a 30% pari-
passu interest in a $450 million loan. The loan is interest only
for the entire term, and matures in 2017. The property's financial
performance has been stable. The property was 96% leased as
of June 2011 compared to 100% at last review and 90% at
securitization. Moody's LTV and stressed DSCR are 133% and
0.69X, respectively, compared to 136% and 0.67X at last review.


N-45 FIRST DBRS Lifts Series 2003-3 Class F Rating From 'B'
-----------------------------------------------------------
DBRS has upgraded these three classes of N-45 First CMBS Issuer
Corporation, Series 2003-1:

  -- Class D to AA (high) (sf) from AA (low) (sf)
  -- Class E to A (high) (sf) from BB (high) (sf)
  -- Class F to BBB (high) (sf) from B (sf)

DBRS has also confirmed these other classes in the transaction:

  -- Class A-2 at AAA (sf)
  -- Class B at AAA (sf)
  -- Class C at AAA (sf)
  -- Class IO at AAA (sf)

DBRS does not rate the $13.3 million Class G.  The trends for all
rated classes of the transaction are Stable.

As of the October 2011 remittance report, 13 loans remain in the
transaction.  There are no delinquent loans; however, two loans
are on the servicer's watchlist.  DBRS has placed one of those
loans on the DBRS HotList.

The 10555, Henri-Bourassa loan is secured by an industrial
property in Saint-Laurent, Qu‚bec.  The property was built in
1975, renovated in 2001 and is located near the intersection of
highway 13 and highway 40, near the Montr‚al-Pierre Elliot Trudeau
International Airport. The loan benefits from a 17-year
amortization schedule and the current leverage point, on a per
square foot basis, is low at $18.  The loan was added to the
servicer's watchlist in August 2011 because the sole tenant has a
lease that expires in January 2012.  The servicer has confirmed
that the tenant renewed their lease through September 30, 2016,
two years beyond loan maturity in 2012.

The Terrasse Terrebonne loan is secured by a retail property
in Terrebonne, Qu‚bec.  The property was built in 1977 and is
located approximately 28 km north of downtown Montr‚al.  The loan
is on the watchlist because of the low occupancy rate and the
corresponding low DSCR.  The occupancy rate was reported at 50% as
of the May 2011 rent roll, which is consistent with the occupancy
rate at YE2010 and YE2009.  As a result of the low occupancy, the
DSCR declined to 0.63x at YE2009 and down to -0.26x at YE2010.
While the cash flow decline is concerning, the borrower has kept
the loan current since the performance began to decline in 2009.
DBRS has inquired with the servicer regarding the leasing efforts
at the property, but has not received an update.  The property is
currently leased to four tenants (the largest being a restaurant),
all of which have leases expiring one year after loan maturity in
April 2012.  Based on the depressed cash flow, this loan could
have difficulty refinancing if performance does not improve.  DBRS
has placed this loan on the HotList to be monitored as the
maturity date approaches.

Since the last DBRS review in October 2010, the transaction has
exhibited stable performance.  The current weighted-average DSCR,
based on YE2010 net cash flow, was reported at 1.88x.  Excluding
the loan on the DBRS HotList, the loans have debt yields ranging
from 17.8% to 60.4%, suggesting a favourable refinance outlook for
the majority of the loans in the transaction.  Additionally, the
pool benefits from the defeasance of the fifth largest loan, which
represents 6.7% of the current pool balance.

The upgrades recognize the increased credit enhancement from the
pay down of seven loans since October 2010, in addition to the
continued amortization of the remaining loans in the transaction.

DBRS continues to monitor this transaction on a monthly basis,
with ongoing information being available in the Monthly CMBS
Surveillance Report.


N-45 FIRST: DBRS Upgrades Series 2003-3 Class F From 'B'
--------------------------------------------------------
DBRS has upgraded these three classes of N-45ø First CMBS Issuer
Corporation, Series 2003-1:

  -- Class D to AA (high) (sf) from AA (low) (sf)
  -- Class E to A (high) (sf) from BB (high) (sf)
  -- Class F to BBB (high) (sf) from B (sf)

DBRS has also confirmed these other classes in the transaction:

  -- Class A-2 at AAA (sf)
  -- Class B at AAA (sf)
  -- Class C at AAA (sf)
  -- Class IO at AAA (sf)

DBRS does not rate the $13.3 million Class G.  The trends for all
rated classes of the transaction are Stable.

As of the October 2011 remittance report, 13 loans remain in the
transaction.  There are no delinquent loans; however, two loans
are on the servicer's watchlist.  DBRS has placed one of those
loans on the DBRS HotList.

The 10555, Henri-Bourassa loan is secured by an industrial
property in Saint-Laurent, Qu‚bec.  The property was built in
1975, renovated in 2001 and is located near the intersection of
highway 13 and highway 40, near the Montr‚al-Pierre Elliot Trudeau
International Airport.  The loan benefits from a 17-year
amortization schedule and the current leverage point, on a per
square foot basis, is low at $18.  The loan was added to the
servicer's watchlist in August 2011 because the sole tenant has a
lease that expires in January 2012.  The servicer has confirmed
that the tenant renewed their lease through September 30, 2016,
two years beyond loan maturity in 2012.

The Terrasse Terrebonne loan is secured by a retail property in
Terrebonne, Qu‚bec.  The property was built in 1977 and is located
approximately 28 km north of downtown Montr‚al.  The loan is on
the watchlist because of the low occupancy rate and the
corresponding low DSCR.  The occupancy rate was reported at 50% as
of the May 2011 rent roll, which is consistent with the occupancy
rate at YE2010 and YE2009.  As a result of the low occupancy, the
DSCR declined to 0.63x at YE2009 and down to -0.26x at YE2010.
While the cash flow decline is concerning, the borrower has kept
the loan current since the performance began to decline in 2009.
DBRS has inquired with the servicer regarding the leasing efforts
at the property, but has not received an update.  The property is
currently leased to four tenants (the largest being a restaurant),
all of which have leases expiring one year after loan maturity in
April 2012.  Based on the depressed cash flow, this loan could
have difficulty refinancing if performance does not improve.  DBRS
has placed this loan on the HotList to be monitored as the
maturity date approaches.

Since the last DBRS review in October 2010, the transaction has
exhibited stable performance.  The current weighted-average DSCR,
based on YE2010 net cash flow, was reported at 1.88x.  Excluding
the loan on the DBRS HotList, the loans have debt yields ranging
from 17.8% to 60.4%, suggesting a favourable refinance outlook for
the majority of the loans in the transaction.  Additionally, the
pool benefits from the defeasance of the fifth largest loan, which
represents 6.7% of the current pool balance.

The upgrades recognize the increased credit enhancement from the
pay down of seven loans since October 2010, in addition to the
continued amortization of the remaining loans in the transaction.

DBRS continues to monitor this transaction on a monthly basis,
with ongoing information being available in the Monthly CMBS
Surveillance Report.


N-STAR REAL: Fitch Junks Rating on Six Note Classes
---------------------------------------------------
Fitch Ratings has downgraded six and affirmed one class issued by
N-Star Real Estate CDO V Ltd (N-Star V) as a result of significant
negative credit migration on the underlying collateral.

Since Fitch's last rating action in November 2010, approximately
49.4% of the portfolio has been downgraded.  Currently, 86% of the
portfolio has a Fitch derived rating below investment grade and
54.1% has a rating in the 'CCC' category and below, compared to
72.4% and 32.8%, respectively, at the last review.  The class A-1
notes have received $82.6 million in pay downs since the last
review.

This transaction was analyzed under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Portfolio Credit Model (PCM) for projecting future default
levels for the underlying portfolio.  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'.  Fitch also analyzed the
structure's sensitivity to the assets that are distressed,
experiencing interest shortfalls, and those with near term
maturities.  Based on this analysis, the class A notes' breakeven
rates are generally consistent with the ratings assigned below.

For the class B through F notes, Fitch analyzed each class'
sensitivity to the default of the distressed assets ('CCC' and
below).  Given the high probability of default of the underlying
assets and the expected limited recovery prospects upon default,
the class B notes have been downgraded to 'CCsf', indicating
default is probable.  Similarly, the class D through F notes,
currently receiving interest paid in kind (PIK) whereby the
principal amount of the notes is written up by the amount of
interest due, have been downgraded to 'Csf', indicating that
default is inevitable.

The Negative Outlook on the class A-1 notes reflects the potential
for further deterioration on the underlying collateral.  Fitch
does not assign Outlooks to classes rated 'CCC' and below.
N-Star V is a collateralized debt obligation (CDO) which closed
Sept. 22, 2005.  The transaction ended its reinvestment period on
Sept. 22, 2010.  The portfolio is composed of 83% commercial
mortgage-backed securities (CMBS), 6% real estate investment
trust debt (REIT), and 11% SF CDOs.  N-Star V is currently
overcollateralized by $107.1 million, primarily as a result of
collateral purchases at a discount during the reinvestment period.

Fitch has affirmed the following class as indicated:

  -- $252,952,559 class A-1 notes at 'Bsf'; Outlook Negative.

Fitch has downgraded the following classes as indicated:

  -- $46,472,397 class A-2 notes to 'CCCsf' from 'Bsf';
  -- $40,935,261 class B notes to 'CCsf' from 'CCCsf';
  -- $17,921,536 class C notes to 'CCsf' from 'CCCsf';
  -- $15,303,889 class D notes to 'Csf' from 'CCsf';
  -- $4,991,084 class E notes to 'Csf' from 'CCsf';
  -- $13,032,797 class F notes to 'Csf' from 'CCsf'.


NATIONAL COLLEGIATE: S&P Cuts Ratings on 2 Note Classes to 'CC'
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on the
class C and D notes from National Collegiate Student Loan Trust
2006-3 to 'CC (sf)' from 'B- (sf)'.

"The downgrades reflect our expectation that these classes will
not receive timely interest payments in the near future. The
transaction tests the class C note interest trigger monthly,
which, if breached, can be cured if it passes the appropriate
performance tests on subsequent distribution dates. However,
we believe that once the breach occurs, the transaction will
continue to breach its class C note interest trigger for the
foreseeable future," S&P related.

"The downgrades also reflects our opinion of the continued adverse
performance trends within the underlying pool of private student
loans, including the accelerated pace at which the transaction has
been realizing defaults. A breach of the class C note interest
trigger would cause a reprioritization of interest to pay down
senior bonds, which would cause interest shortfalls to each of the
class C and D notes, in accordance with the transaction's
waterfall flow of funds," S&P related.

The transaction may draw on its reserve account to cover fees to
the servicer, trustee, paying agent, and administrator, as well as
backup administrator fees and expenses, and class A, B, C, and D
note interest when no triggers are in effect. However, the
transaction cannot draw on the reserve account to cover interest
payments to the class C and D notes when a class C note interest
trigger is in effect.

The series 2006-3 class C note interest trigger breaches if the
class fails both a cumulative default rate and a parity test. The
cumulative default rate trigger beginning in June 2011 was 19.00%
(see table 1). As of the Sept. 26, 2011, distribution date, the
cumulative default rate was 19.21%, which exceeds the 19.00%
threshold rate by 0.21%. "Based on the average increase in
historical cumulative defaults, we believe actual defaults will
continue to exceed the trigger even after the rate rises to 21.00%
in June 2012," S&P related.

Table 1
Class C Cumulative Default Rate Threshold Resets
Series 2006-3
Date                      CDR (%)
6/1/2007                     3.00
6/1/2008                     7.00
6/1/2009                    12.00
6/1/2010                    16.00
6/1/2011                    19.00
6/1/2012                    21.00
6/1/2013                    23.00

CDR-Cumulative default rate.

The parity test will fail if the aggregate outstanding balance of
the class A and B notes exceeds the sum of the collateral balance
plus the amounts on deposit in the reserve account. As of the
Sept. 26, 2011 distribution date, the reported parity calculation
for testing purposes was 100.02%, two basis points (bps) above
par. "Accordingly, based on historical deteriorations in parity,
we believe the transaction will fail its parity test on the next
distribution date and parity will remain below 100% for the
foreseeable future. Accordingly, we believe a class C note
interest trigger will occur, which will put the class C and D
notes at risk of not receiving timely interest payments," S&P
related.


NATIONAL COLLEGIATE: S&P Cuts Ratings on 2 Classes of Notes to 'D'
------------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on the
class C and D notes from National Collegiate Student Loan Trust
2006-3 to 'D (sf)' from 'CC (sf)'.

"We lowered our ratings on these classes to 'D (sf)' because the
affected classes did not receive timely interest payments on the
Oct. 25, 2011, distribution date. The transaction breached the
class C note interest trigger because it failed both its
cumulative default rate and parity tests, prompting the interest
shortfalls. The transaction tests monthly the class C note
interest trigger, and the transaction can cure the breach if it
passes the appropriate performance tests on subsequent
distribution dates," S&P related.

"We believe this transaction will continue to breach its
class C note interest trigger for the foreseeable future. The
downgrades reflect the continued adverse performance trends
within the underlying pool of private student loans, including
the accelerated pace at which the transaction has been realizing
defaults. The breach of the class C note interest trigger caused
a reprioritization of interest to pay down senior bonds, causing
interest shortfalls to the class C and D notes on the Oct 25, 2011
distribution date. The transaction did not breach its class D note
interest trigger, but the waterfall provides for the class D note
interest payment only after the interest on class C has been paid.
The transaction may draw on its reserve account to cover fees to
the servicer, trustee, paying agent, and administrator, as well as
backup administrator fees and expenses, and class A, B, C, and D
note interest when no triggers are in effect. However, the
transaction cannot draw on the reserve account to cover interest
payments to the class C and D notes when a class C note interest
trigger is in effect," S&P said.

The series 2006-3 class C note interest trigger breaches if the
class fails both a cumulative default rate and a parity test. The
cumulative default rate trigger beginning in June 2011 was 19.00%
(see table 1). As of the Oct. 25, 2011, distribution date, the
cumulative default rate was 19.80%, which exceeds the 19.00%
threshold rate by 0.80%. "Based on the average increase in
historical cumulative defaults, we believe actual defaults will
continue to exceed the trigger even after the rate rises to 21.00%
in June 2012," S&P said.

Table 1
Class C Cumulative Default Rate Threshold Resets
Series 2006-3
Date                      CDR (%)
6/1/2007                     3.00
6/1/2008                     7.00
6/1/2009                    12.00
6/1/2010                    16.00
6/1/2011                    19.00
6/1/2012                    21.00
6/1/2013                    23.00

CDR -- Cumulative Default Rate

The parity test will fail if the aggregate outstanding balance of
the class A and B notes exceeds the sum of the collateral balance
plus the amounts on deposit in the reserve account. As of the
Oct. 25, 2011, distribution date, the reported parity calculation
for testing purposes was 99.65%, 35 basis points below par.
"Accordingly, based on historical deteriorations in parity,
the transaction failed its parity test on the Oct. 25, 2011,
distribution date and we believe parity will remain below 100%
for the foreseeable future," S&P said.


PINE CCS: S&P Withdraws Ratings on 2 Classes From 'D'
-----------------------------------------------------
Standard & Poor's Ratings Services withdrew its ratings on seven
classes from Pine CCS Ltd., Spruce CCS Ltd., and Verano CCS Ltd.
These transactions are cash flow CLO transactions.

"Our rating withdrawals follow the issuer's request for rating
withdrawals on the rated notes," S&P related.

Ratings Withdrawn

Pine CCS Ltd.
Class               To          From
A-1                 NR          D (sf)
A-2                 NR          D (sf)
B                   NR          CC (sf)

Spruce CCS Ltd.
Class               To          From
Sr Nts              NR          D (sf)
Mezz Nts            NR          CC (sf)

Verano CCS Ltd.
Class               To          From
Sr Nts              NR          D (sf)
Mezz Nts            NR          CC (sf)

NR -- Not rated.


PREFERREDPLUS TRUST: S&P Puts 'BB' Ratings 2 Classes on Watch
-------------------------------------------------------------
Standard & Poor's Ratings Services revised its CreditWatch
implications on its 'BB-' ratings on PreferredPLUS Trust Series
ELP-1's $40.754 million class A and B certificates to developing
from positive, where they were placed on May 31, 2011.

"Our ratings on the certificates are dependent on our rating on
the underlying security, El Paso Corp.'s 7.75% medium-term notes
due Jan. 15, 2032 ('BB-/Watch Dev')," S&P related.

"The rating actions follow our Oct. 17, 2011, CreditWatch revision
to developing from positive on our 'BB-' rating on the underlying
security. We may take subsequent rating actions on the
certificates due to changes in our rating on the underlying
security," S&P related.


SCHOONER 2007-7: Moody's Affirms Rating of Cl. F Notes at 'Ba1'
---------------------------------------------------------------
Moody's Investors Service (Moody's) affirmed the ratings of 14
classes of Schooner Trust Commercial Mortgage Pass-Through
Certificates, Series 2007-7:

Cl. A-1, Affirmed at Aaa (sf); previously on Mar 6, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-2, Affirmed at Aaa (sf); previously on Mar 6, 2007
Definitive Rating Assigned Aaa (sf)

Cl. B, Affirmed at Aa2 (sf); previously on Mar 6, 2007 Definitive
Rating Assigned Aa2 (sf)

Cl. C, Affirmed at A2 (sf); previously on Mar 6, 2007 Definitive
Rating Assigned A2 (sf)

Cl. D, Affirmed at Baa2 (sf); previously on Mar 6, 2007 Definitive
Rating Assigned Baa2 (sf)

Cl. E, Affirmed at Baa3 (sf); previously on Mar 6, 2007 Definitive
Rating Assigned Baa3 (sf)

Cl. F, Affirmed at Ba1 (sf); previously on Mar 6, 2007 Definitive
Rating Assigned Ba1 (sf)

Cl. G, Affirmed at Ba2 (sf); previously on Mar 6, 2007 Definitive
Rating Assigned Ba2 (sf)

Cl. H, Affirmed at Ba3 (sf); previously on Mar 6, 2007 Definitive
Rating Assigned Ba3 (sf)

Cl. J, Affirmed at B2 (sf); previously on Oct 22, 2009 Downgraded
to B2 (sf)

Cl. K, Affirmed at Caa1 (sf); previously on Oct 22, 2009
Downgraded to Caa1 (sf)

Cl. L, Affirmed at Caa2 (sf); previously on Oct 22, 2009
Downgraded to Caa2 (sf)

Cl. XP, Affirmed at Aaa (sf); previously on Mar 6, 2007 Definitive
Rating Assigned Aaa (sf)

Cl. XC, Affirmed at Aaa (sf); previously on Mar 6, 2007 Definitive
Rating Assigned Aaa (sf)

RATINGS RATIONALE

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

Moody's rating action reflects a cumulative base expected loss of
2.2% of the current pooled balance, which is the same as at last
review. Moody's stressed scenario loss is 8.4% of the current
pooled balance. 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 methodologies used in this rating were "Moody's Approach to
Rating U.S. CMBS Conduit Transactions" published in September
2000, and "Moody's Approach to Rating 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 pool has a Herf of 29 as compared to 30
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 January 28, 2011.

DEAL PERFORMANCE

As of the October 12, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 14% to $369 million
from $428 million at securitization. The Certificates are
collateralized by 65 mortgage loans ranging in size from less than
1% to 11% of the pool, with the top ten loans representing 44% of
the pool. The pool does not contain any loans with investment
grade credit estimates. One loan, representing less than 1% of the
pool, has defeased and is collateralized with Canadian Government
securities.

Twenty-two loans, representing 23% 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 resulting in a $6 thousand loss (1%
loss severity). There are currently no loans in special servicing.
Based on the most recent remittance report the deal has $831 of
cumulative interest shortfalls, which are contained to the non-
rated class.

Moody's has assumed a high default probability for three poorly
performing loans representing 4% of the pool and has estimated a
$2 million loss (14% expected loss based on a 50% probability of
default) from these troubled loans.

Moody's was provided full year 2010 operating results for 80% of
the conduit loans, respectively. The conduit portion of the pool
excludes defeased and troubled loans. Moody's weighted average
conduit LTV is 83% compared to 84% 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 9.1%.

Moody's actual and stressed conduit DSCRs are 1.51X and 1.28X,
respectively, compared to 1.50X and 1.24X 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 24% of the pool
balance. The largest loan is the MTS Building Loan ($39 million --
10.6% of the pool), which is secured by two adjacent office
buildings located in Winnipeg, Manitoba. One of the two buildings
serves as MTS Allstream's corporate headquarters. MTS is the
largest telecommunications company in Manitoba and the 4th largest
company in Canada. MTS occupies 89% of the net rentable area (NRA)
via a lease that runs through December 2021. The property is 100%
leased on June 1, 2011, which is the same as last review and at
securitization. Moody's LTV and stressed DSCR are 96% and 0.98X,
respectively, compared to 98% and 0.97X at last review.

The second largest loan is the Aviva Insurance Complex Loan
($30 million -- 8.1%), which is secured by a 438,000 square foot
mixed-use complex located in Toronto, Ontario. The property was
99% leased as of March 2011, which is the same as at last review.
Aviva Canada is the property's largest tenant, which leases 73%
of the net rentable area through September 2016. The rent roll
indicated that one tenant is in a free rent period and 10% of the
rent roll expires by 2011 year end. Moody's LTV and stressed DSCR
are 94% and 1.03X, respectively, compared to 80% and 1.22X at last
review.

The third largest loan is the Festival Marketplace Loan
($18 million -- 4.9%), which is secured by a 208,000 square foot
enclosed community shopping center located in Stratford, Ontario.
The property was 97% leased as of January 2011, which is the same
as at last review. Moody's LTV and stressed DSCR are 97% and .98X,
respectively, compared to 92% and 1.03X at last review.


SLM STUDENT: Fitch Affirms Rating on Class B Notes at 'BBsf'
------------------------------------------------------------
Fitch Ratings affirms senior student loan notes at 'AAAsf' and
subordinate notes at 'BBsf' issued by SLM Student Loan Trust 2005-
7.  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 and subordinate notes are affirmed based
on the sufficient level of credit enhancement to cover the
applicable risk factor stresses.  Credit enhancement for the
senior notes consists of overcollateralization, subordination
provided by the class B note, and projected minimum excess spread,
while the subordinated notes benefit from projected excess spread
only.

Fitch has taken these rating actions:

SLM Student Loan Trust 2005-7:

  -- Class A-2 affirmed at 'AAAsf'; Outlook Stable;
  -- Class A-3 affirmed at 'AAAsf'; Outlook Stable;
  -- Class A-4 affirmed at 'AAAsf'; Outlook Stable;
  -- Class A-5 affirmed at 'AAAsf'; Outlook Stable;
  -- Class B affirmed at 'BBsf'; Outlook Stable.


TRAINER WORTHAM: S&P Lowers Rating on Class B Notes to 'CCC-'
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on the A-1,
A-2, and B notes from Trainer Wortham First Republic CBO V Ltd.
"At the same time, we removed the classes A-1 and A-2 from
CreditWatch, where we placed them with negative implications on
Aug. 2, 2011. We also affirmed our ratings on two classes. The
transaction is a U.S. collateralized debt obligation (CDO)
transaction, backed substantially by U.S. residential mortgage-
backed securities," S&P related.

"The transaction has had significant credit deterioration since
our last affirmation action on Sept. 1, 2010. As per the Sept. 28,
2011, trustee report, the transaction had over $97 million in
defaulted assets, compared with the $86 million noted in the Aug.
2, 2010, trustee report, which we referenced for our September
2010 rating action. The A-1, A-2, and B notes now have lesser
subordination compared with the subordination available at the
time of the affirmation," 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

Trainer Wortham First Republic CBO V Ltd.
                   Rating
Class       To            From
A-1         BB+ (sf)      BBB (sf)/Watch Neg
A-2         CCC+ (sf)     B (sf)/Watch Neg
B           CCC- (sf)     CCC (sf)

Ratings Affirmed

Trainer Wortham First Republic CBO V Ltd.
Class       Rating
C           CC (sf)
D           CC (sf)


TRICADIA CDO: S&P Raises Rating on Class A-4L Notes to 'B'
----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1LA, A-1LB, A-2L, A-3L, and A-4L notes from Tricadia CDO 2003-1
Ltd., a U.S. collateralized debt obligation (CDO) transaction
primarily backed by collateralized loan obligations (CLO) and
managed by Tricadia CDO Management LLC. "At the same time, we
removed all of the ratings from CreditWatch, where we placed them
with positive implications on Sept. 2, 2011," S&P related.

"The upgrades mainly reflect an improvement in the performance of
the transaction's underlying asset portfolio, as well as paydowns
to the senior notes, since we lowered our ratings in May 2010,
following the application of our September 2009 CDO criteria," S&P
noted.

As of the September 2011 trustee report, the transaction had
$8.773 million of defaulted assets. "This was down from the
$40.574 million of defaulted assets noted in the February 2010
trustee report, which we used for our May 2010 rating actions.
Additionally, the collateral manager sold some of the defaulted
positions at prices that were higher than the assumed recovery
values. The trustee reported $54.104 million in assets from
obligors rated in the 'CCC' category in September 2011, compared
with $63.25 million in February 2010," S&P noted.

The upgrades also reflect an improvement in the
overcollateralization (O/C) available to support the notes due to
paydowns to the class A-1LA and A-2L notes since the May 2010
rating actions. Since that time, the transaction has paid the
class A-1LA and class A-2L notes by approximately $12.4 million
each, which has reduced their outstanding note balances to 30.84%
and 37.75% of their original issuance amounts. The trustee
reported the O/C ratios in the September 2011 monthly report:

    The senior class A O/C ratio was 136.2%, compared with a
    reported ratio of 100.1% in February 2010;

    The class A par value ratio was 121.5%, compared with a
    reported ratio of 91.3% in February 2010; and

    The class B par value ratio test was 106.91%, compared with a
    reported ratio of 81.93% in February 2010.

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

Tricadia CDO 2003-1 Ltd.
                          Rating
Class                 To           From
A-1LA                 A+ (sf)      BBB+ (sf)/Watch Pos
A-1LB                 A- (sf)      BBB- (sf)/Watch Pos
A-2L                  A- (sf)      BBB- (sf)/Watch Pos
A-3L                  BB+ (sf)     B+ (sf)/Watch Pos
A-4L                  B (sf)       B- (sf)/Watch Pos


UBS AG: Moody's Raises Rating of Series 2760 Notes to 'B3'
----------------------------------------------------------
Moody's Investors Service has upgraded its ratings of UBS AG
Fixed Rate Credit Linked Notes Series 2760, credit-linked notes
referencing CDX.NA.IG.4, a static index of corporate entities.

US$10M Fixed Rate Credit Linked Notes Series 2760 Notes, Upgraded
to B3 (sf); previously on Jan 21, 2010 Downgraded to Caa2 (sf)

RATING RATIONALE

Moody's explained that the rating action taken is the result of
the improvement of the credit quality of the reference portfolio.
The 10 year weighted average rating factor of the portfolio has
improved from 1608 from the last rating action to 1412, equivalent
to an average rating of the current portfolio of B1. Since the
last rating action on the transaction in January 2010, the
subordination has not changed. The portfolio has the highest
industry concentrations in Retail (8%), Insurance (8%),
Telecommunications (6%), and Oil & Gas (6%).

The remaining life of the deal is 3.7 years. The initial
attachment point of the downgraded tranche is 7.25%. Total erosion
of credit support since closing is 1.60%.

The portfolio has experienced six credit events. There have been
no additional credit events since the last rating action in
January 2010.

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
  results of this run generated a rating that had no ratings
  impact compared to the base case.

* Market Implied Ratings 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 results of this run generated a rating that had no
  ratings impact compared to the base case.

* Negative notch all reference entities on negative outlook.
  Negative notch all reference entities on negative watch.
  Positive notch all reference entities on positive outlook.
  Positive notch all reference entities on positive outlook watch.
  The results of this run generated a rating that had no ratings
  impact compared to the base case.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of rating committee
considerations. These qualitative factors include the structural
protections in each transaction, the recent deal performance in
the current market environment, the legal environment, and
specific documentation features. All information available to
rating committees, including macroeconomic forecasts, input from
other Moody's analytical groups, market factors, and judgments
regarding the nature and severity of credit stress on the
transactions, may influence the final rating decision.

The principal methodology used in these ratings was "Moody's
Approach to 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 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.


WELLS FARGO: Fitch to Rate Two Note Classes at Low-B
----------------------------------------------------
Fitch Ratings has issued a presale report on Wells Fargo Bank,
N.A. WFRBS Commercial Mortgage Trust 2011-C5 commercial mortgage
pass-through certificates.

Fitch expects to rate the transaction and assign Rating Outlooks:

  -- $66,527,000 class A-1 'AAAsf'; Outlook Stable;
  -- $118,410,000 class A-2 'AAAsf'; Outlook Stable;
  -- $107,908,000 class A-3 'AAAsf'; Outlook Stable;
  -- $470,955,000 class A-4 'AAAsf'; Outlook Stable;
  -- $849,728,000* class X-A 'AAAsf'; Outlook Stable;
  -- $85,928,000 class A-S 'AAAsf'; Outlook Stable;
  -- $54,557,000 class B 'AAsf; Outlook Stable;
  -- $40,918,000 class C 'Asf; Outlook Stable;
  -- $25,915,000 class D 'BBB+sf'; Outlook Stable;
  -- $49,101,000 class E 'BBB-sf'; Outlook Stable;
  -- $17,731,000 class F 'BBsf'; Outlook Stable;
  -- $16,367,000 class G 'Bsf'; Outlook Stable.

* Notional amount and interest only.

The expected ratings are based on information provided by the
issuer as of Oct. 25, 2011.  Fitch does not expect to rate the
$241,415,970 interest-only class X-B, or the $36,826,970 class H.

The certificates represent the beneficial ownership in the trust,
primary assets of which are 75 loans secured by 98 commercial
properties having an aggregate principal balance of approximately
$1.09 billion as of the cutoff date.  The loans were originated by
The Royal Bank of Scotland plc, Wells Fargo Bank, N.A., Basis Real
Estate Capital II, LLC, C-III Commercial Mortgage LLC and General
Electric Capital Corporation.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 76.2% of the properties
by balance, cash flow analysis of 86.3% of the pool and asset
summary reviews of 86.3% of the pool.

The transaction has a Fitch stressed debt service coverage ratio
(DSCR) of 1.17 times (x), a Fitch stressed loan-to value (LTV) of
95.4%, and a Fitch debt yield of 9.8%.  Fitch's aggregate net cash
flow represents a variance of 5.8% to issuer cash flows.

The Master Servicer and Special Servicer will be Wells Fargo and
Midland Loan Services, Inc., rated 'CMS2' and 'CSS1',
respectively, by Fitch.


WFCMT 2010-C1: Moody's Affirms Cl. E Notes Rating at 'Ba2'
----------------------------------------------------------
Moody's Investors Service (Moody's) affirmed the ratings of nine
CMBS classes of WFCMT 2010-C1, Commercial Mortgage Pass-Through
Certificates, Series 2010-C1:

Cl. A-1, Affirmed at Aaa (sf); previously on Nov 19, 2010
Definitive Rating Assigned Aaa (sf)

Cl. A-2, Affirmed at Aaa (sf); previously on Nov 19, 2010
Definitive Rating Assigned Aaa (sf)

Cl. B, Affirmed at Aa2 (sf); previously on Nov 19, 2010 Definitive
Rating Assigned Aa2 (sf)

Cl. C, Affirmed at A2 (sf); previously on Nov 19, 2010 Definitive
Rating Assigned A2 (sf)

Cl. D, Affirmed at Baa3 (sf); previously on Nov 19, 2010
Definitive Rating Assigned Baa3 (sf)

Cl. E, Affirmed at Ba2 (sf); previously on Nov 19, 2010 Definitive
Rating Assigned Ba2 (sf)

Cl. F, Affirmed at B2 (sf); previously on Nov 19, 2010 Definitive
Rating Assigned B2 (sf)

Cl. X-A, Affirmed at Aaa (sf); previously on Nov 19, 2010
Definitive Rating Assigned Aaa (sf)

Cl. X-B, Affirmed at Aaa (sf); previously on Nov 19, 2010
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 the existing ratings.

Moody's rating action reflects a cumulative base expected loss of
1.4% of the current balance. Moody's stressed scenario loss is
5.4% of the current balance. 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.

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

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 underlying ratings 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 underlying ratings
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 11 which is the same as at securitization.

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 October 22, 2010.

DEAL PERFORMANCE

As of the October 17, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 1% to
$726.4 million from $735.9 million at securitization. The
Certificates are collateralized by 37 mortgage loans ranging in
size from less than 1% to 25% of the pool, with the top ten loans
representing 64% of the pool. There are four loans, which
represent 39% of the pool, with investment grade credit estimates.

There are no loans currently 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 no loans currently in special servicing.

Moody's was provided with full-year 2010 and partial year 2011
operating results for 69% and 47% of the pool, respectively.
Excluding specially serviced and troubled loans, Moody's weighted
average LTV is 84% compared to 90% at securitization. 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 9.5%.

Moody's actual and stressed DSCRs are 1.55X and 1.25X,
respectively, compared to 1.46X and 1.16X at securitization.
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 Dividend Capital
Portfolio Loan ($182.0 million -- 25.1% of the pool), which is
secured by a fee interest in 14 single tenant properties located
across nine states. The portfolio consists of seven office
properties, five industrial distribution centers, one data center
and one research and development facility. In aggregate, the
portfolio contains approximately 3,643,379 square feet (SF). As of
June 2010, the portfolio was 100% leased to 13 different tenants,
all of which operate within industries that are generally
uncorrelated with each other. Moody's current credit estimate and
stressed DSCR are Baa3 and 1.46X, respectively, the same as at
securitization.

The second largest loan with a credit estimate is the Salmon Run
Mall Loan ($54.8 million -- 7.5% of the pool), which is secured by
a regional mall containing approximately 671,766 SF located in
Watertown, New York. It is the only regional mall within the trade
area and is eight miles away from Fort Drum Army Base, which is
the largest employer in Northern New York. Anchor tenants include
Sears, Burlington Coat Factory, Gander Mountain, Dick's Sporting
Goods and J.C. Penney. As of December 2010 the property was 94%
leased, the same as at securitization. Moody's current credit
estimate and stressed DSCR are A3 and 1.61X, respectively,
compared to A3 and 1.54X at securitization.

The third largest loan with a credit estimate is the 19 West 34th
Street Loan ($25.0 million -- 3.4% of the pool), which is secured
by a 224,093 SF mixed use property located directly across from
the Empire State Building in New York, New York. Constructed in
1907 (renovated in 1995), the property contains both retail and
office components. The main retail tenant, Banana Republic, is
currently operating under a sublease from Martin Building Retail,
an entity of the owner. As of December 2010 the property was 99%
leased compared to 89% at securitization. Moody's current credit
estimate and stressed DSCR are Aa2 and 1.97X, respectively, the
same as at securitization.

The fourth largest loan with a credit estimate is the Radisson
Reagan National Airport Loan ($19.8 million -- 2.7% of the pool),
which is secured by a 243-room full service hotel located a
quarter of a mile away from the Reagan National Airport in
Arlington, Virginia. The property was 81% leased as of December
2010. Moody's current credit estimate and stressed DSCR are Baa3
and 1.88X, respectively, compared to Baa3 and 1.86X at
securitization.

The top three performing conduit loans represent 16% of the
pool balance. The largest loan is the Polaris Towne Center
Loan ($45.3 million -- 6.2% of the pool), which is secured by a
443,264 SF anchored retail center located in Columbus, Ohio. The
property was 97% leased as of December 2010 compared to 92% at
securitization. Anchor tenants include Kroger and Best Buy. The
property also benefits from non-owned shadow anchors Target and
Lowes. Moody's LTV and stressed DSCR are 82% and 1.18X,
respectively, compared to 79% and 1.24X at securitization.

The second largest loan is the First Tennessee Plaza and Cedar
Ridge Loan ($35.6 million -- 4.9% of the pool), two crossed-
collateralized and cross-defaulted loans secured by two separate
office properties, totaling 536,869 SF, located in Tennessee. The
largest property is First Tennessee Plaza, a 447,013 SF high-rise
office building located in downtown Knoxville. The remaining
collateral is represented by Cedar Ridge, a 89,856 SF office
building located in suburban Knoxville. The loan is encumbered
with a $3.7 million junior participation interest held outside of
the trust. The portfolio was 89% leased as of March 2011 compared
to 91% at securitization. Moody's LTV and stressed DSCR are 99%
and 1.04X, respectively, compared to 100% and 1.03X at
securitization.

The third largest loan is the Pepper Square I and II and Central
Forest Shopping Center Loan ($31.9 million -- 4.4% of the pool),
two crossed-collateralized and cross-defaulted loans secured by
separate retail properties, totaling 372,753 SF, located in
Dallas, Texas. The portfolio's largest tenants include Hobby
Lobby, Stein Mart and Bally's Total Fitness. The portfolio was 86%
leased as of March 2011 compared to 87% at securitization. Moody's
LTV and stressed DSCR are 92% and 1.17X, respectively, compared to
93% and 1.15X at securitization.


* S&P Lowers Ratings on 4 Classes of Notes from 3 U.S. CDOs to 'D'
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on four
classes of notes from three U.S. collateralized debt obligation
(CDO) transactions following interest shortfalls on nondeferrable
tranches. "At the same time, we removed our rating on the class A
notes from CWCapital COBALT III Synthetic CDO Ltd. from
CreditWatch negative," S&P said.

The three transactions include a cash flow CDO backed
predominantly by commercial mortgage-backed securities (CMBS), a
hybrid CDO backed by CMBS, and a CDO backed by trust preferred
securities.

Rating Actions

Acacia CRE CDO 1 Ltd.
                        Rating
Class              To           From
A                  D (sf)       CCC- (sf)

CWCapital COBALT III Synthetic CDO Ltd.
                        Rating
Class              To           From
A                  D (sf)       CCC+ (sf)/Watch Neg

MMCapS Funding XIX Ltd.
                        Rating
Class              To           From
A-1                D (sf)       CCC- (sf)
A-2                D (sf)       CCC- (sf)


* S&P Lowers Ratings on 15 Tranches from 7 CDOs From 'CC' to 'D'
----------------------------------------------------------------
Standard & Poor's Rating Services lowered its ratings on 15
tranches from seven U.S. cash flow collateralized debt obligation
(CDO) transactions to 'D (sf)' from 'CC (sf)'. "We also lowered
our ratings on two classes from one market value CDO transaction.
All of the affected CDOs are collateralized by corporate bonds and
or corporate loans," S&P related.

The downgrades follow a review of U.S. CDO transactions backed
predominantly by corporate debt issuances. "We lowered our ratings
on the tranches to 'D (sf)' because they have, in our view, little
realistic prospects of repayment and many are unlikely to receive
any future principal payments. We are taking these actions given
the diminished amount of assets supporting the outstanding CDO
liabilities," S&P said.

Ratings Lowered

CASH FLOW CDOs

GE Commercial Loan Trust Series 2006-2
                            Rating
Class              To                  From
D                  D (sf)              CC (sf)
Pfd Trust          D (sf)              CC (sf)

GE Commercial Loan Trust Series 2006-3
                            Rating
Class               To                  From
C                   D (sf)              CC (sf)
D                   D (sf)              CC (sf)
Pfd Tr Cer          D (sf)              CC (sf)

Juniper CBO 2000-1 Ltd.
                            Rating
Class              To                  From
B-2                D (sf)              CC (sf)

Landmark II CDO Ltd.
                            Rating
Class              To                  From
C                  D (sf)              CC (sf)
D                  D (sf)              CC (sf)

Nicholas-Applegate CBO II Ltd.
                            Rating
Class               To                  From
C                   D (sf)              CC (sf)
D                   D (sf)              CC (sf)

South Street CBO 2000-1 Ltd.
                            Rating
Class              To                  From
A-4A               D (sf)              CC (sf)
A-4C               D (sf)              CC (sf)
A-4L               D (sf)              CC (sf)

Wilbraham CBO Ltd.
                            Rating
Class              To                  From
B-1                D (sf)              CC (sf)
B-2                D (sf)              CC (sf)

MARKET VALUE CDO

BlackRock Senior Income Series III plc
                            Rating
Class               To                  From
D                   D (sf)              CC (sf)
E                   D (sf)              CC (sf)


* S&P Lowers Ratings on 421 Classes from 99 U.S. RMBS Transactions
------------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 421
classes from 99 U.S. residential mortgage-backed securities (RMBS)
transactions and removed 273 of them from CreditWatch with
negative implications. "Concurrently, we affirmed our ratings
on 430 classes from the transactions with lowered ratings and
eight other transactions, and removed 145 of them from CreditWatch
negative. We also withdrew our rating on one class from Structured
Asset Securities Corp. Mortgage Loan Trust 2007-TC1 based on our
interest-only criteria. Prior to withdrawing it, this rating was
on CreditWatch negative," S&P related.

The complete rating list is available for free at:

     http://bankrupt.com/misc/S&P_1021_Subprime_RMBS.pdf

Subprime mortgage loan collateral supports the 107 RMBS
transactions in this review which were issued between 2005 and
2007.

"On May 11, 2011, we placed 7,389 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'). We reviewed these deals with updated loss
projections and updated structure-level loss severities where
applicable using observed liquidation data from the past 12
months (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 related.

"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 projected credit
enhancement available for these classes is sufficient to cover
projected losses associated with these rating levels," S&P said.

"The rating actions take transaction-specific loss projections
into account. 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 subprime
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. However, 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 related.

"Approximately 60 classes with 'CCC (sf)' and 'CC (sf)' ratings
experienced accumulated interest shortfalls. We may lower the
ratings on these classes further if, in accordance with our
criteria, we determine that these shortfalls are credit-related,"
S&P said.

For additional structure-level information regarding delinquencies
and cumulative losses for these transactions through the August
2011 remittance period please see:

Losses and Delinquencies*

Aames Mortgage Investment Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-1      1,200    8.42    5.80          52.12          43.18
2005-2      1,158    9.49   10.07          49.07          44.10

ABFC Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-AQ1      818   40.03    3.19          16.16          12.06

Accredited Mortgage Loan Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-2      1,008   18.03    6.97          22.09          16.43
2005-3      1,120   22.70    9.98          29.45          20.63
2005-4      1,195   26.35   14.28          28.87          21.53
2006-1      1,004   30.30   14.71          31.34          25.53
2006-2      1,400   39.26   15.49          30.71          24.02

Ace Securities Corp. Home Equity Loan Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-HE4    1,460   16.30    8.78          50.11          44.74
2006 ASAP4    568   31.69   23.39          32.63          23.59
2006-CW1      844   41.41   15.69          58.35          53.05
2006-HE2      940   24.73   24.53          34.53          24.93
2006-OP1    1,107   29.21   17.48          43.61          35.79
2006-OP2      892   35.39   20.73          40.14          31.78

Aegis Asset Backed Securities Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-2      1,000   13.63   13.42          31.13          23.31
2005-3        850   15.05   14.70          35.28          25.25
2005-5      1,200   26.24   17.97          36.04
26.082006-1
525   45.15   24.93          32.54          23.55

Argent Securities Inc.
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-W3     2,000   24.38   16.57          37.34          28.90

Asset Backed Securities Corp.
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
NC2006-HE4    909   25.27   20.88          34.59          26.69

Bear Stearns Asset Backed Securities I Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-CL1      279   35.10    7.39          25.92          16.49
2006-HE7      414   37.09   25.06          60.40          51.22
2006-HE9    1,064   43.84   20.95          60.99          52.38

Carrington Mortgage Loan Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2006-NC5    1,140   54.63   18.34          49.19          43.28
2006-RFC1     782   35.77   14.75          44.97          39.28

C-BASS Mortgage Loan Asset-Backed Certificates
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2006-CB8      572   34.13   31.00          48.83          41.33

CIT Mortgage Loan Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2007-1      7,242   49.94   19.25          38.48          33.09

Citigroup Mortgage Loan Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2006-HE2      736   30.41   17.13          35.83          29.68

CWABS Asset Backed Certificates Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-11       832   53.60    4.14          41.10          35.12
2005-11     1,168   27.92   10.44          65.97          60.95
2005-13     1,700   33.62   10.72          59.61          54.45
2005-13       300   54.52    5.68          45.62          41.92
2005-16     1,200   37.02   11.07          59.12          53.66
2005-16     1,080   54.47    4.16          40.39          34.45
2005-7      1,306   24.06    9.13          66.41          60.32
2005-7        844   45.57    3.40          37.87          32.43
2005-15       400   42.55    7.18          51.36          45.77
2005-17     1,700   38.18   10.91          59.14          53.05
2005-17       900   54.50    6.23          45.17          38.83
2005-AB2    1,000   20.65    8.18          67.64          65.07
2005-AB3      650   24.40   11.43          70.47          67.26
2006-1        358   21.55   18.56          65.46          59.50
2006-1        442   46.03    8.93          43.20          36.67
2006-2        850   35.36   12.48          58.27          53.04
2006-8      2,000   46.28   15.49          62.76          57.22
2006-9        172   53.48   12.05          48.47          43.11
2006-9        428   32.94   22.42          53.90          46.46
2006-20     1,000   56.38   13.16          66.56          61.07
2006-21     1,100   54.19   15.94          64.27          59.32
2006-23     1,600   58.14   13.73          64.06          58.97

FBR Securitization Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-2      2,280   16.82   10.43          50.82          43.13
2005-4        995   16.78   18.35          47.32          38.37
2005-5        785   25.34   15.99          53.25          46.30

Fieldstone Mortgage Investment Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-2        967   16.31   16.38          45.64          36.59
2005-3      1,165   19.84   22.64          45.90          37.37
2006-1        933   23.38   25.40          50.58          40.97
2006-2        800   29.18   32.09          48.93          39.51
2006-3        859   29.82   31.91          45.87          37.65

First Franklin Mortgage Loan Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-FF10   1,402   21.74   17.02          32.65          24.76
2005-FF12   1,965   25.43   16.07          49.40          37.11
2006-FF6      371   31.28   18.26          50.10          42.44
2005-FF9    1,706   20.23   15.89          32.20          24.25
2006-FF14   1,163   35.27   22.71          34.51          25.42

Fremont Home Loan Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-E      2,196   23.39   20.33          59.07          50.44

GE-WMC Asset Backed Pass Through Certificates
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-2      1,415   21.83   23.41          52.19          44.65

GSAMP Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-AHL2     580   28.54   19.56          37.94          31.65
2005-WMC2   1,121   19.83   18.99          46.20          39.31
2006-HE5    1,037   33.86   23.75          41.48          33.62

Home Equity Asset Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2006-2        800   19.02   22.70          39.17          32.31
2006-5        850   24.10   25.79          44.80          37.32
2006-6        850   26.00   28.15          44.80          37.07
2006-7      1,100   27.10   31.92          43.97          36.12

Home Loan Mortgage Loan Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2006-1        190   37.16   13.41          27.85          23.77

HSI Asset Securitization Corp. Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2006-NC1      329   24.26   17.41          50.89          45.44

JPMorgan Mortgage Acquisition Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2006-CH1      600   46.33   10.09          40.77          33.21
2006-CH2    1,629   48.07   16.02          47.78          41.30
2006-CH2      395   63.64    6.94          33.79          26.64
2006-CW1      892   35.34   13.19          65.59          60.77

Long Beach Mortgage Loan Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-3      1,528   15.00   16.38          54.02          46.47

Morgan Stanley Home Equity Loan Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2006-2        996   25.13   20.41          38.43          31.82

New Century Home Equity Loan Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-2      2,989   16.81    6.48          33.69          28.30
2005-A        989   45.31    2.99          33.73          28.71
2005-B      2,000   24.60   15.73          34.72          27.14

Nomura Home Equity Loan Inc. Home Equity Loan Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2006-HE3    1,075   33.47   22.02          35.08          28.53

Ownit Mortgage Loan Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-4        866   15.46   16.72          42.83          34.92
2006-5        471   31.77   27.17          47.46          38.46

Park Place Securities
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-WCW3   1,500   23.26   10.00          57.91          53.31

People's Choice Home Loan Securities Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-3      1,125   12.82   13.36          45.59          37.63

Popular ABS Mortgage Pass-Through Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2006-D        377   41.23   18.02          42.34          33.15

RASC Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2006-EMX6     645   31.16   29.42          54.71          49.51
2006-EMX7     520   30.66   30.48          58.50          52.18
2006-KS3    1,150   24.24   21.06          36.66          29.66
2006-KS6      544   33.95   23.12          31.72          23.25

Renaissance Home Equity Loan Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2006-3        825   51.10   12.01          31.10          22.06
2006-4        625   55.77   13.32          33.49          23.91
2007-1        950   60.68   13.60          32.46          23.67

Securitized Asset Backed Receivables LLC Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-FR5    1,162   18.32   11.10          72.21          69.42
2006-FR1      989   18.83   20.52          45.75          37.65

Soundview Home Loan Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-OPT4   1,559   27.20   13.65          35.19          26.83
2006-OPT2   1,600   26.79   15.84          43.75          36.05
2006-OPT3   2,000   28.89   16.58          42.27          35.02

Specialty Underwriting and Residential Finance Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-AB3      315   28.13    8.28          45.75          40.85
2006-BC1    1,500   26.40   17.77          59.47          53.39
2006-BC3      850   34.21   21.42          60.71          54.84

Structured Asset Investment Loan Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-11     1,873   20.10   18.08          44.37          36.38
2006-3      2,730   26.87   21.50          52.12          44.86

Structured Asset Securities Corp. Mortgage Loan Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-OPT1     591   23.24   15.30          38.53          32.27
2006-BC5      798   39.85   25.14          44.80          39.90
2006-OPT1     944   28.88   15.74          40.14          30.50
2006-WF2    1,299   29.61   16.63          35.10          27.39
2007-TC1      179   65.13    8.69          24.41          16.90

Terwin Mortgage Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-14HE     325   23.86   12.57          24.36          17.39

Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-CB5      431   23.45   12.74          45.84          37.47

Wells Fargo Home Equity Asset-Backed Securities Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-1      1,256   17.15    3.93          36.89          22.07
2006-2        811   33.06   12.66          45.70          30.80

*Original balance represents the original collateral balance for
the structure represented. Pool factor represents the percentage
of the original pool balance remaining. Cumulative losses are a
percentage of the original pool balance, and total and severe
delinquencies are percentages of the current pool balance.


The information shows average pool factor, cumulative loss, and
total and severe delinquency information by vintage for subprime
collateral as of the August 2011 distribution period.

2005 Vintage
    Average     Average            Average            Average
pool factor  cumulative              total             severe
        (%)  losses (%)  delinquencies (%)  delinquencies (%)
      18.59       10.16              41.70              28.00

2006 Vintage
    Average     Average            Average            Average
pool factor  cumulative              total             severe
        (%)  losses (%)  delinquencies (%)  delinquencies (%)
      32.57       21.59              47.83              41.01

2007 Vintage
    Average     Average            Average            Average
pool factor  cumulative              total             severe
        (%)  losses (%)  delinquencies (%)  delinquencies (%)
       46.72       21.62              46.72              40.22

Subordination, overcollateralization (prior to its depletion), and
excess spread, when applicable, provide credit support for the
affected transactions.


* S&P Lowers Ratings on 438 Classes of Pass-through Certs. to 'D'
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 483
classes of mortgage pass-through certificates from 308 U.S.
residential mortgage-backed securities (RMBS) transactions
issued between 2002 and 2009 to 'D (sf)', and removed two of
them from CreditWatch with negative implications. "In addition,
we placed our ratings on 10 other classes from two of these
transactions on CreditWatch with negative implications," S&P
related.

The complete rating list is available for free at:

   http://bankrupt.com/misc/S&P_1021_AffectedRMBSClasses.pdf

"The lowered ratings reflect our assessment of the impact that
principal write-downs had on the affected classes during recent
remittance periods. Prior to the rating actions, 0.62% of these
classes had ratings between 'B- (sf)' and 'BBB+ (sf)', and 99.38%
were rated 'CCC (sf)' or 'CC (sf)'. We placed our ratings on
certain classes on CreditWatch negative if they were within a loan
group that included a class whose ratings are being lowered from
a 'B- (sf)' rating or higher," S&P related.

Approximately 69.15% of the defaulted classes were from
transactions backed by Alternative-A (Alt-A) or subprime mortgage
loan collateral. The 483 defaulted classes consist of:

    240 classes from Alt-A transactions (49.69% of all defaults);

    126 from prime jumbo transactions (26.09%);

    94 from subprime transactions (19.46%);

    Six from resecuritized real estate mortgage investment conduit
    (re-REMIC) transactions;

    Six from reperforming transactions;

    Five from risk transfer transactions;

    Three from small balance commercial loan transactions;

    Two from RMBS home equity line of credit (HELOC) transactions;
    And

    One from an outside-the-guidelines transaction.

The three classes that defaulted from a rating of 'B- (sf)' or
higher were from transactions backed by prime jumbo, Alt-A and
subprime collateral. A combination of subordination, excess
spread, and overcollateralization (where applicable) provide
credit enhancement for all of the transactions.

"We expect to resolve the CreditWatch placements after we complete
our review of the related transactions. Standard & Poor's will
continue to monitor its ratings on securities that experience
principal write-downs, and it will adjust its ratings as it
considers appropriate in accordance with its criteria," S&P
related.

                           *********

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.


                  *** End of Transmission ***