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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, February 19, 2012, Vol. 16, No. 49

                            Headlines

ALLY MASTER: Moody's Assigns Provisional Ratings to Four Classes
ABACUS 2006-NS1: Moody's Affirms Cl. A Notes Rating at 'C'
ABS AUTO: DBRS Confirms Class E Rating at 'BB'
ACA CLO: S&P Raises Class D Note Rating From 'B+' to 'BB-'
AMERICAN CREDIT: S&P Gives 'BB' Rating on Class D Notes

AMERICREDIT AUTOMOBILE: Moody's Gives 'Ba2' Rating to Cl. E Notes
ARCAP 2004-1: Fitch Affirms Rating on Eight Note Classes
ARES NF: S&P Raises Rating on Class E Notes From 'B+' to 'BB'
ARES IIIR/IVR: S&P Ups Rating on Class E Notes From 'CCC-' to 'BB'
ARES XXI: S&P Raises Rating on Class D Notes From 'CCC-' to 'B+'

ASHFORD CDO: S&P Raises Rating on Class B-1L Notes to 'CCC+'
ATRIUM III: S&P Affirms Ratings on 2 Classes of Notes at 'B+'
BACM 2008-LS1: Moody's Lowers Cl. A-J Notes Rating to 'Ba2'
BANC OF AMERICA: S&P Lowers Rating on Class H Cert. to 'D'
BAYVIEW COMMERCIAL: Moody's Reviews Ratings for Possible Downgrade

BLACKROCK II: S&P Raises Ratings on 2 Classes of Notes to 'BB+'
BSCMS COMMERCIAK: Fitch Affirms Rating on Six Certificate Classes
CALIFORNIA COUNTY: S&P Ups Ratings on 2 Classes of Notes From 'B-'
CALLIDUS DEBT: S&P Raises Rating on Class E Notes to 'BB'
CARLYLE DAYTONA: S&P Keeps 'CCC-' Class B-2L Note Rating on Watch

CD COMMERCIAL: Fitch Puts Three Note Classes on Watch Negative
CITICORP MORTGAGE: Moody's Lowers Rating of Cl. IIA-1 Notes to Ba1
CITYSCAPE HOME: Moody's Withdraws Ratings of $6MM Subprime RMBS
COLTS 2007-1: S&P Raises Rating on Classes E Notes to 'B+'
COLUMBUSNOVA CLO: S&P Affirms 'BB' Rating on Class E Notes

COMMODORE CDO: Fitch Affirms Junk Rating on Three Note Classes
CSAM FUNDING: S&P Says Asset Had $32.61MM in 'CCC' Rated Obligs
CRYSTAL RIVER: Moody's Affirms Rating of Cl. A Notes at 'C'
CTX CDO: Moody's Lowers Rating of Cl. A Notes to 'C'
E*TRADE ABS: Fitch Affirms Rating on Five Note Classes

FFCA SECURED: Fitch Downgrades Rating on Class E Notes to 'Dsf'
FIRST ALLIANCE: Moody's Downgrades Rating of Cl. A-3 Notes to 'B3'
FIRST UNION-LEHMAN: S&P Cuts Rating on Class J Certs. to 'D'
FOREST CREEK: S&P Affirms Rating on Class B-2L Notes at 'CCC-'
FRANKLIN AUTO: S&P Raises Rating on Class D Notes to 'BB+'

GCCFC 2006-GG7: Moody's Reviews Ba1 Rating for Possible Downgrade
GE COMMERCIAL 2006-C1: S&P Lowers Rating on Class F Certs. to 'D'
GMAC COMMERCIAL: Fitch Affirms Junk Rating on 4 Security Classes
GOLDEN KNIGHT: S&P Raises Rating on Class E Notes to 'B+'
GOLDENTREE IV: S&P Affirms Rating on Class D Notes at 'BB'

GOLDMAN SACHS: Fitch Puts Rating on Two Note Classes at Low-B
GREYROCK CDO: S&P Raises Rating on Class B-2L Notes to 'BB+'
GSMS 2006-GG8: Moody's Affirms Rating of Cl. A-J Notes at 'Ba1'
GSMS 2012-GC6: Moody's Assigns 'Ba2' Rating to Cl. E Notes
HALCYON 2005-2: Moody's Lowers Rating of Cl. A Notes to 'B3'

INDEPENDENCE I: Fitch Lowers Rating on $50 Mil. Note to 'Dsf'
INFINITI SPC: S&P Downgrades Rating on Class B Notes to 'D'
INFINITI SPC: S&P Lowers Rating on Notes to 'D'
JP MORGAN: Fitch Puts 'B-sf' $164 Million Certs. on Watch Negative
JP MORGAN: Fitch Puts Three Note Class's Rating on Watch Negative

JPMORGAN 1997-C5: S&P Affirms 'CCC-' Rating on Class G Certificate
KLEROS REAL: S&P Lowers Rating on Class A-1 Note From 'CC' to 'D'
LAKESIDE CDO: Fitch Affirms Junk Rating on Four Note Classes
LANDMARK IX: S&P Raises Rating on Class E Notes From 'B' to 'BB'
LB-UBS 2006-C3: S&P Lowers Ratings on 2 Classes of Cert. to 'CCC-'

LEHMAN MANUFACTURED: Moody's Reviews Ratings for Downgrade
LIGHTPOINT VII: S&P Raises Rating on Class D Notes to 'B+'
LNR CDO: Moody's Affirms Rating of Cl. A Notes at 'C'
LNR CDO: Moody's Affirms Rating of Cl. B-FL Notes at 'C'
MACLAURIN SPC: Moody's Lowers Rating of Cl. A1 Notes to 'C'

MADISON PARK V: S&P Raises Rating on Class D Notes to 'BB+'
MAPS CLO: S&P Raises Rating on Class D Notes to 'BB'; Off Watch
MASTR ASSET: S&P Lowers Rating on Class 8-B-3 From 'BBB' to 'CCC'
MCG 2006-1: S&P Raises Rating on Class D Notes to 'BB+'
MERRILL LYNCH: DBRS Confirms Class F Rating at 'BB'

MERRILL LYNCH: DBRS Confirms Class G Rating at 'BB'
MERRILL LYNCH: DBRS Downgrades Class F Rating to 'C'
MERRILL LYNCH: S&P Affirms 'BB+' Rating on Class A-3 Certificates
MERRILL LYNCH: S&P Withdraws 'B-' Rating on Class J Certs.
MID-ATLANTIC FREDERAL: Fitch Assigns Viability Rating at 'B'

MONTANA RE: S&P Raises Series 2010-1 Class C Note Rating to 'B'
MORGAN STANLEY: Fitch Affirms Junk Ratings on Four Note Classes
MORGAN STANLEY: Fitch Places Rating on 8 Cert. Class at Low-B
MORGAN STANLEY: S&P Cuts Rating on Class G Cert. to 'D'
MORGAN STANLEY: S&P Lowers Class F Cert. Rating to 'D'

MORGAN STANLEY: S&P Withdraws 'CCC-' Class I Note Rating
MOUNTAIN VIEW: S&P Raises Class E Rating From 'CCC+' to 'B+'
MOUNTAIN VIEW: S&P Raises Rating on Class E Notes to 'B+'
MOUNTAIN VIEW: S&P Upgrades Rating on Class E Notes to 'B+'
MYSTIC RE: S&P Gives 'BB' Rating on Class A Notes

N-45 2003-1: Moody's Raises Rating of Cl. F Notes to 'B1'
N-STAR CDO: S&P Lowers Rating on Class C-2 Notes to 'CCC'
N-STAR REAL: Fitch Lowers Rating on Four Note Classes
NANTUCKET CLO: S&P Raises Rating on Class E Notes to 'B+'
NAUTIQUE FUNDING: S&P Raises Rating on Class D Notes to 'BB-'

NYLIM FLATIRON: S&P Affirms 'B+' Rating on Class D Notes
OCTAGON INVESTMENT: S&P Raises Rating on Class D Notes to 'BB'
OCTAGON INVESTMENT: S&P Says $2.05MM From 'CCC'-Rated Obligors
PARKRIDGE LANE: S&P Withdraws 'CCC-' Ratings on 3 Classes of Notes
PINETREE CDO: S&P Lowers Rating on Class A-1S Notes to 'CC'

PNCMA 2000-C2: Moody's Lowers Rating of Cl. J Notes to 'B2'
PUTNAM CDO: Moody's Affirms Class A-1MT -a Notes Rating at 'Ba1'
RAMP SERIES 2006-RZ1: S&P Raises Rating on Class A-2 From 'CC'
RESTRUCTURED ASSET: Moody's Raises Class A-3 Notes Rating to 'B2'
RFC CDO: Fitch Lowers Rating on $7.2 Million Notes to 'Csf'

RMBS: DBRS Confirms Series 2006-CB4, CLASS AV2 at 'C'
SB 2002-KEY: Moody's Affirms Cl. L Notes Rating at 'Ba1'
SEAWALL 2006-4: Moody's Affirms Super Senior Rating at 'Caa3'
SEAWALL 2006-4A: Moody's Affirms Rating of Cl. D-1 Notes at 'C'
SENIOR ABS: Fitch Affirms Rating on $6.6 Mil. Certs at 'Bsf'

SHASTA CLO: S&P Ups Rating on Class B-2L Notes From 'CCC-' to 'BB'
SILVERADO CLO: S&P Raises Class D Note Rating From 'B+' to 'BB'
SONOMA VALLEY: Moody's Lowers Rating of Series 114/2007 to 'Caa1'
SOUTHPORT CLO: S&P Raises Rating on Class 2 Notes From 'BB+'
SPARKS REGIONAL: Moody's Affirms Rating of Notes Due 2012 at 'B1'

ST. JAMES RIVER: S&P Hikes Class E Note Rating From 'CCC+' to 'B+'
STONE TOWER: S&P Raises Ratings on 2 Classes of Notes to 'BB+'
STONE TOWER: S&P Raises Rating on Class A-3L From 'CCC+' to 'B+'
STONE TOWER: S&P Upgrades Ratings on 2 Classes of Notes to 'B+'
SUNRISE CDO: Moody's Raises Rating of Class A Notes to 'B2'

SYMPHONY CLO: S&P Raises Rating on Class D Notes to 'BB'
TELOS CLO: S&P Raises Rating on Class E Notes to 'BB'
TERRA II: DBRS Places 'BB' Rating of Class B3 Under Review
TIAA SEASONE: Fitch Affirms Rating on 14 Certificate Classes
TIMES SQUARE: S&P Raises Rating on Mortgage Certs. From 'BB+'

VERTICAL CRE: Fitch Affirms Junk Ratings on Seven Note Classes
WACHOVIA BANK: S&P Cuts Ratings on 2 Cert. Classes to 'D'
WACHOVIA BANK: S&P Downgrades Ratings on Class 37 Ratings
WACHOVIA BANK: S&P Lowers Rating on Class E Cert. to 'D'
WASATCH CLO: S&P Lowers Class IV Note Rating From 'B' to 'CCC-'

* Fitch Lowers Ratings on 31 CMBS Bonds to 'D'
* S&P Lowers Ratings on 12 Classes from 4 U.S. RMBS re-REMIC Deals
* S&P Puts Ratings on 299 Tranches from US CDO Deals on Watch Pos



                            *********

ALLY MASTER: Moody's Assigns Provisional Ratings to Four Classes
----------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to the
Series 2012-1 notes (Notes) to be issued by Ally Master Owner
Trust (AMOT 2012-1). 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:

$750,000,000, Class A-1 and Class A-2 Asset Backed Notes, rated
(P)Aaa (sf)

$36,972,000, Class B Asset Backed Notes, rated (P)Aa2 (sf)

$58,099,000, Class C Asset Backed Notes, rated (P)A2 (sf)

$42,254,000, Class D Asset Backed Notes, rated (P)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 B1, three notches below its current rating of Ba1, 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 2012-1 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 2012-1 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.


ABACUS 2006-NS1: Moody's Affirms Cl. A Notes Rating at 'C'
----------------------------------------------------------
Moody's has downgraded one and affirmed six classes of Notes
issued by Abacus 2006-NS1, LTD. The downgrade is due to the
deterioration in the credit quality of the underlying portfolio of
reference obligations as evidenced by an increase in the weighted
average rating factor (WARF). 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 Synthetic) transactions.

Cl. A, Downgraded to C (sf); previously on Mar 26, 2010 Downgraded
to Ca (sf)

Cl. B, Affirmed at C (sf); previously on Mar 26, 2010 Downgraded
to C (sf)

Cl. C, Affirmed at C (sf); previously on Mar 26, 2010 Downgraded
to C (sf)

Cl. D, Affirmed at C (sf); previously on Mar 26, 2010 Downgraded
to C (sf)

Cl. E, Affirmed at C (sf); previously on Mar 26, 2010 Downgraded
to C (sf)

Cl. G, Affirmed at C (sf); previously on Mar 26, 2010 Downgraded
to C (sf)

Cl. H, Affirmed at C (sf); previously on Mar 26, 2010 Downgraded
to C (sf)

RATINGS RATIONALE

Abacus 2006-NS1, LTD. is a static synthetic CRE CDO transaction
backed by a portfolio of tranched credit default swaps referencing
$615.6 million notional amount of commercial mortgage backed
securities (CMBS) (88.7% of notional amount) and CRE CDO debt
(11.3%). All of the reference obligations were securitized in 2005
(76.0%), and 2006 (24.0%). Currently, 66.2% of the reference
obligations are rated by Moody's.

Moody's has identified the following parameters as key indicators
of the expected loss within CRE CDO transactions: WARF, weighted
average life (WAL), weighted average recovery rate (WARR), and
Moody's asset correlation (MAC). These parameters are typically
modeled as actual parameters for static deals and as covenants for
managed deals.

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's has completed updated credit estimates for the non-Moody's
rated reference obligations. The bottom-dollar WARF is a measure
of the default probability within a reference pool. Moody's
modeled a bottom-dollar WARF of 8,163 compared to 7,996 at last
review. The distribution of current ratings is as follows: Ba1-Ba3
(4.9% compared to 7.4% at last review), B1-B3 (9.7% compared to
13.4% at last review), and Caa1-C (85.4% compared to 79.2% at last
review).

WAL acts to adjust the probability of default of the reference
obligations in the pool for time. Moody's modeled to a WAL of 5.7
years compared to 5.4 years at last review.

WARR is the par-weighted average of the mean recovery values for
the reference obligations in the pool. Moody's modeled a variable
WARR with a mean of 1.0% compared to 1.4% at last review.

MAC is a single factor that describes the pair-wise asset
correlation to the default distribution among the instruments
within the reference obligations pool (i.e. the measure of
diversity). Moody's modeled a MAC of 100.0% compared to 99.9% 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.

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. In general, the rated notes are particularly
sensitive to rating changes within the reference pool. However, in
light of the performance indicators noted above, Moody's believes
that it is unlikely that the ratings announced are sensitive to
further change.

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 extent of the
slowdown in growth in the current macroeconomic environment and
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 in
recovery and improvements in the office sector continue, with
fundamentals in Gateway cities outperforming their suburban
counterparts. However, office demand is closely tied to
employment, where fundamentals remain weak, so significant
improvement may be delayed. Performance in the retail sector has
been mixed with on-going rent deflation and leasing challenges.
Across all property sectors, the availability of debt capital
continues to improve with monetary policy expected to remain
supportive and interest rate hikes postponed. Moody's central
global macroeconomic scenario reflects an overall downward
revision of forecasts since last quarter, amidst ongoing fiscal
consolidation efforts, household and banking sector deleveraging,
persistently high unemployment levels, and weak housing markets
that will continue to constrain growth.

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


ABS AUTO: DBRS Confirms Class E Rating at 'BB'
----------------------------------------------
DBRS has confirmed ratings on 18 tranches from 4 ABS Auto loan
transactions and discontinued ratings for 2 tranches that have
been repaid in full. Asset performance and overall credit
enhancement levels for the confirmed securities are within DBRS
expectations at the securities' respective rating levels.

First Investors Auto Owner Trust 2011-1 Series 2011-1, Class E
Confirmed BB (sf) -- Feb 10, 2012


ACA CLO: S&P Raises Class D Note Rating From 'B+' to 'BB-'
----------------------------------------------------------
Standard & Poor's Ratings Services raised and removed from
CreditWatch positive its ratings on four classes of notes from
ACA CLO 2006-2 Ltd., a collateralized loan obligation (CLO)
transaction managed by Apidos Capital Management LLC. "At the same
time, we affirmed our rating on the class A-1 notes," S&P said.

"The upgrades reflect improvements in the overcollateralization
(O/C) available to support the rated notes and in the credit
quality of the transaction's underlying asset portfolio since we
downgraded the notes in January 2010. As of the January 2012
trustee report, the class A O/C ratio increased to 124.41% from
121.68% in December 2009, which we referenced for our January
2010 rating actions. In addition, the transaction's balance of
defaulted assets decreased to $3.63 million from $14.42 million in
December 2009," S&P said.

"The affirmation reflects the availability of sufficient credit
support at the current rating level. We will continue to review
our ratings on the notes and assess whether, in our view, the
ratings remain consistent with the credit enhancement available,"
S&P said.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

          http://standardandpoorsdisclosure-17g7.com

Rating Actions

ACA CLO 2006-2 Ltd.

                   Rating
             To            From
A-2          AA- (sf)      A+ (sf)/Watch Pos
B            A- (sf)       BBB+ (sf)/Watch Pos
C            BBB (sf)      BB+ (sf)/Watch Pos
D            BB- (sf)      B+ (sf)/Watch Pos

Rating Affirmed

ACA CLO 2006-2 Ltd.

Class        Rating
A-1          AA+ (sf)


AMERICAN CREDIT: S&P Gives 'BB' Rating on Class D Notes
-------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to American Credit Acceptance Receivables Trust 2012-1's
$150 million asset-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 Feb. 14,
2012. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflect S&P's view of:

   "The availability of approximately 43.65%, 40.06%, 33.69%, and
   28.62% of credit support for the class A-2, B, C, and D notes
   based on break-even stressed cash flow scenarios (including
   excess spread), which provide approximately 2.0x, 1.80x, 1.50x,
   and 1.25x our expected net loss range of 21.50%-22.00% for the
   class A-2, B, C, and D notes," S&P said.

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

   "Our expectation that under a moderate, or 'BBB', stress
   scenario the ratings on the class A-2 and B notes would remain
   within one rating category of our preliminary 'A+ (sf)' and 'A
   (sf)' ratings," S&P said.

   "The collateral characteristics of the subprime automobile
   loans securitized in this transaction, including the 3.96
   months of seasoning," S&P said.

   "The backup servicing arrangement with Wells Fargo Bank N.A.,"
    S&P said.

   "The transaction's payment and credit enhancement structures,
   which include performance triggers," S&P said.

   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 Represent ations,
warranties and enforcement mechanisms in issuances of similar
securities. The Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Reports
included in this credit rating report are available at:

            http://standardandpoorsdisclosure-17g7.com

Preliminary Ratings Assigned
American Credit Acceptance Receivables Trust 2012-1

Class     Rating       Type           Interest          Amount
                                      rate         (mil. $)(i)
A-1       A+ (sf)      Senior         Fixed              49.00
A-2       A+ (sf)      Senior         Fixed              63.50
B         A (sf)       Subordinate    Fixed               7.00
C         BBB (sf)     Subordinate    Fixed              15.25
D         BB (sf)      Subordinate    Fixed              15.25

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


AMERICREDIT AUTOMOBILE: Moody's Gives 'Ba2' Rating to Cl. E Notes
-----------------------------------------------------------------
Moody's Investors Service has assigned definitive ratings to the
notes to be issued by AmeriCredit Automobile Receivables Trust
2012-1 (AMCAR 2012-1). This is the first public subprime
transaction of the year for AmeriCredit Financial Services, Inc.
(AmeriCredit).

The complete rating actions are:

Issuer: AmeriCredit Automobile Receivables Trust 2012-1

Cl. A-1, rated P-1 (sf):

Cl. A-2, rated Aaa (sf):

Cl. A-3, rated Aaa (sf):

Cl. B, rated Aa1 (sf):

Cl. C, rated Aa3 (sf):

Cl. D, rated Baa2 (sf):

Cl. E, rated 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, and the experience and expertise of
AmeriCredit as servicer.

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 2012-
1 pool is 11.00% and total credit enhancement required to achieve
Aaa rating (i.e. Aaa proxy) is 39.50%. 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 a Low/Medium
assessment for Governance due to the presence of a highly rated
backup servicer, Wells Fargo (Aa3 negative outlook/P-1), 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 Aa3 to Ba3, below B3, and below B3,
respectively; Class D notes might change from Baa2 to below B3 in
each scenario; 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.


ARCAP 2004-1: Fitch Affirms Rating on Eight Note Classes
--------------------------------------------------------
Fitch Ratings has affirmed eight classes issued by N-Star Real
Estate CDO VII, Ltd. (N-Star CDO VII) as a result of paydowns to
the senior notes offsetting the negative credit migration.

Since Fitch's last rating action in February 2011, approximately
38.1% of the collateral has been downgraded and 0.2% has been
upgraded.  Currently, 85.5% of the portfolio has a Fitch derived
rating below investment grade and 55.5% has a rating in the 'CCC'
category and below, compared to 69.5% and 44%, respectively, at
the last rating action.  On June 25, 2011, the transaction exited
its reinvestment period and since this time the class A-1 notes
have received $77.3 million in principal repayment.

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.  The breakeven rates in Fitch's cash flow model for
the class A and B notes are generally consistent with the ratings
assigned below.

For the class C through E 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 D through E notes have been affirmed at 'CCsf',
indicating that default is probable.

The Negative Outlook on the class A-1 and A-2 notes reflects the
potential for further deterioration on the underlying portfolio.
Fitch does not assign outlooks to classes rated 'CCC' and below.

N-Star CDO VII is a revolving collateralized debt obligation (CDO)
which closed June 22, 2006.  The transaction is collateralized by
150 assets from 98 obligors.  The portfolio is composed of 76.4%
commercial mortgage-backed securities (CMBS); 12.5% of SF CDOs;
4.7% commercial real estate loans (CREL); 3.3% corporate loans;
and 3.1% real estate investment trust securities (REIT).

Fitch has affirmed these classes:

  -- $260,970,834 class A-1 notes at 'BBsf'; Outlook Negative;
  -- $54,250,000 class A-2 notes at 'Bsf'; Outlook Negative;
  -- $50,000,000 class A-3 notes at 'CCCsf';
  -- $30,300,000 class B notes at 'CCCsf';
  -- $22,000,000 class C notes at 'CCsf';
  -- $14,000,000 class D-FL notes at 'CCsf';
  -- $2,000,000 class D-FX notes at 'CCsf';
  -- $16,200,000 class E notes at 'CCsf'.


ARES NF: S&P Raises Rating on Class E Notes From 'B+' to 'BB'
-------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class B, C, D, and E notes from Ares NF CLO XIV Ltd., a U.S.
collateralized loan obligation (CLO) transaction managed by
Ares Management LLC. "At the same time, we removed our ratings on
the class B, C, and D notes from CreditWatch, where we placed them
with positive implications on Nov. 14, 2011. We also affirmed our
rating on the class A notes," S&P said.

"The upgrades reflect improved performance we have observed in the
deal's underlying asset portfolio since we downgraded the notes on
Feb. 25, 2010. As of the Jan. 5, 2012 trustee report, the
transaction's asset portfolio had no defaulted obligations and
$5.87 million in 'CCC' rated obligations. This was a decrease from
$4.10 million in defaulted obligations and $34.27 million in
'CCC' rated obligations noted in the Jan. 7, 2010 trustee report,
which we used for our February 2010 rating actions," S&P said.

"We also observed an increase in the overcollateralization (O/C)
available to support the rated notes," S&P said. The trustee
reported the O/C ratios in the Jan. 5, 2012 monthly report:

    The class A/B O/C ratio was 124.17%, compared with a reported
    ratio of 120.35% in January 2010;

    The class C O/C ratio was 116.27%, compared with a reported
    ratio of 112.7% in January 2010;

    The class D O/C ratio was 110.32%, compared with a reported
    ratio of 106.93% in January 2010; and

    The class E O/C ratio was 105.96%, compared with a reported
    ratio of 102.71% in January 2010.

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.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

            http://standardandpoorsdisclosure-17g7.com

Rating And Creditwatch Actions

Ares NF CLO XIV Ltd.
                       Rating
Class              To          From
B                  AA+ (sf)    AA- (sf)/Watch Pos
C                  A+ (sf)     A- (sf)/Watch Pos
D                  BBB+ (sf)   BB+ (sf)/Watch Pos
E                  BB (sf)     B+ (sf)

Rating Affirmed

Ares NF CLO XIV Ltd.
Class              Rating
A                  AA+ (sf)


ARES IIIR/IVR: S&P Ups Rating on Class E Notes From 'CCC-' to 'BB'
------------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1, A-2, B, C, D, and E notes from Ares IIIR/IVR CLO Ltd., a U.S.
collateralized loan obligation (CLO) transaction managed by Ares
Management LLC. "At the same time, we removed the ratings on
the class A-1, A-2, B, C, D, and E notes from CreditWatch, where
we placed them with positive implications on Nov. 14, 2011," S&P
said.

"The upgrades mainly reflect the improved performance of the
transaction's underlying asset portfolio since we lowered our
ratings on all of the notes in March 2010 following the
application of our September 2009 collateralized debt obligation
(CDO) criteria. As of the January 2012 trustee report, the
transaction's collateral pool had $1.50 million of defaulted
assets. This was down from the $26.06 million of defaulted assets
noted in the February 2010 trustee report, which we referenced for
our March 2010 rating actions. Additionally, the trustee reported
$22.75 million in assets from obligors rated in the 'CCC' category
in January 2012, compared with $71.16 million in February 2010,"
S&P said.

"The upgrades also reflect an improvement in the
overcollateralization (O/C) available to support the notes since
our March 2010 rating actions," S&P said. The trustee reported the
O/C ratios in the January 2012 monthly report:

    The class A/B O/C ratio was 125.96%, compared with a reported
    ratio of 122.40% in February 2010;

    The class C O/C ratio was 116.68%, compared with a reported
    ratio of 113.22% in February 2010;

    The class D O/C ratio was 109.93%, compared with a reported
    ratio of 106.56% in February 2010; and

    The class E O/C ratio was 104.49%, compared with a reported
    ratio of 101.20% 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.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

             http://standardandpoorsdisclosure-17g7.com

Ratings Raised

Ares IIIR/IVR CLO Ltd.
                   Rating
Class         To           From
A-1           AA+ (sf)     AA- (sf)/Watch Pos
A-2           AA+ (sf)     AA- (sf)/Watch Pos
B             AA (sf)      A (sf)/Watch Pos
C             A (sf)       BBB+ (sf)/Watch Pos
D             BBB (sf)     BB- (sf)/Watch Pos
E             BB (sf)      CCC- (sf)/Watch Pos

Transaction Information
Issuer:             Ares IIIR/IVR CLO Ltd.
Co-issuer:          Ares IIIR/IVR CLO Corp.
Underwriter:        Deutsche Bank Securities Inc.
Collateral manager: Ares Management LLC
Trustee:            The Bank of New York Mellon
Transaction type:   Cash flow CDO


ARES XXI: S&P Raises Rating on Class D Notes From 'CCC-' to 'B+'
----------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class A-1, A-2, B, C, and D notes from Ares XXI CLO Ltd., a U.S.
collateralized loan obligation (CLO) transaction managed by Ares
CLO Management XXI L.P. "At the same time, we removed our ratings
on these classes from CreditWatch, where we placed them with
positive implications on Nov. 14, 2011," S&P said.

"The upgrades reflect improved performance we have observed in the
transaction's underlying asset portfolio since we last downgraded
the classes on Nov. 19, 2009. As of the Jan. 6, 2012, trustee
report, the transaction's asset portfolio had $4.74 million in
defaulted obligations and approximately $11.10 million in assets
from obligors rated in the 'CCC' range. These amounts are down
from $32.37 million in defaulted obligations and approximately
$40.70 million in assets from obligors rated in the 'CCC' range
noted in the Oct. 6, 2009, trustee report, which we used for our
November 2009 rating actions," S&P said.

"We also observed an increase in the overcollateralization (O/C)
available to support the rated notes," S&P said. The trustee
reported the O/C ratios in the Jan. 6, 2012 monthly report:

    The A O/C ratio was 120.06%, compared with a reported ratio of
    118.41% in October 2009;

    The B O/C ratio was 112.22%, compared with a reported ratio of
    110.68% in October 2009;

    The C O/C ratio was 107.19%, compared with a reported ratio of
    105.71% in October 2009; and

    The D O/C ratio was 103.32%, compared with a reported ratio of
    101.90% in October 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.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

             http://standardandpoorsdisclosure-17g7.com

Rating And Creditwatch Actions

Ares XXI CLO Ltd.
                       Rating
Class              To           From
A-1                AA+ (sf)     AA (sf)/Watch Pos
A-2                AA (sf)      A+ (sf)/Watch Pos
B                  A (sf)       BBB+ (sf)/Watch Pos
C                  BBB (sf)     B+ (sf)/Watch Pos
D                  B+ (sf)      CCC- (sf)/Watch Pos


ASHFORD CDO: S&P Raises Rating on Class B-1L Notes to 'CCC+'
------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
X, A-1LA, A-1LB, A-2L, A-3L, and B-1L notes from Ashford CDO II
Ltd., a U.S. collateralized debt obligation (CDO) transaction
predominantly backed by tranches from other CDOs of corporate
securities (CDO of corporate CDOs). The transaction is managed by
Babson Capital Management LLC. "At the same time, we affirmed our
rating on class B-2L notes," S&P said.

"The upgrades reflect an improved performance in the deal's
underlying asset portfolio since we downgraded the notes on
May 25, 2010. As of the Jan. 25, 2012 trustee report, the
transaction had $17.99 million in defaulted assets, compared
with $65.97 million noted in the Feb. 25, 2010 trustee report,
which we referenced for our May 2010 rating actions," S&P said.

"Additionally, there has been a paydown of $8.89 million to the A-
1LA notes since February 2010. The class X notes have interest and
principal payments per a schedule, senior in the transaction's
payment waterfall on each distribution date. The class X notes
have paid down $1.67 million during the same period," S&P said.

The transaction has also benefited from an increase in the
overcollateralization (O/C) available to support the rated notes.
The trustee reported the O/C ratios in the Jan. 25, 2012 monthly
report:

    The A/B O/C ratio was 112.09%, compared with a reported ratio
    of 93.55% in February 2010;

    The D O/C ratio was 90.65%, compared with a reported ratio of
    66.31% in February 2010; and

    The E O/C ratio was 84.99%, compared with a reported ratio of
     62.68% in February 2010.

The affirmation reflects the credit support available to the class
B-2L notes at the current rating level.

"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 said.

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

            http://standardandpoorsdisclosure-17g7.com

Rating Actions

Ashford CDO II Ltd.
                     Rating
Class            To          From
X                AA (sf)     A- (sf)
A-1LA            BBB (sf)    BBB- (sf)
A-1LB            BB+ (sf)    BB (sf)
A-2L             BB (sf)     B (sf)
A-3L             B+ (sf)     CCC (sf)
B-1L             CCC+ (sf)   CCC- (sf)

Rating Affirmed

Ashford CDO II Ltd.
Class         Rating
B-2L          CC (sf)

Transaction Information

Issuer:               Ashford CDO II Ltd.
Coissuer:             Ashford CDO II Corp.
Collateral manager:   Babson Capital Management LLC
Trustee:              The Bank of New York Mellon
Transaction type:     Cash flow CDO of CDO


ATRIUM III: S&P Affirms Ratings on 2 Classes of Notes at 'B+'
-------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1, A-2a, A-2b, and B notes from Atrium III, a collateralized
loan obligation (CLO) transaction managed by CSFB Alternative
Capital Inc. "We also affirmed our ratings on the class C, D-1,
and D-2 notes. At the same time, we removed all the ratings from
CreditWatch where we placed them with positive implications on
Nov. 14, 2011," S&P said.

"The upgrades reflect a paydown to the class A-1 notes since we
raised our ratings on the transaction in February 2011. Since that
time, the transaction has paid down the class A-1 by approximately
$152 million, reducing the balance to $218 million. As of the
Dec. 23, 2011 trustee report, the class A-1 notes had been paid
down to 58.45% of the original balance," S&P said.

"The affirmations reflect sufficient credit support available to
the notes at the current rating levels. We did not raise our
ratings on the class C, D-1, and D-2 notes primarily because the
transaction is subject to potential market value risks due to its
exposure to long-dated securities. According to the December 2011
trustee report, the transaction held approximately $58 million
(17%) in underlying collateral that matures after the legal final
maturity of the transaction. We understand that the maturity dates
of these underlying assets have been extended due to the
restructuring of the underlying loans," S&P said.

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.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

            http://standardandpoorsdisclosure-17g7.com

Rating And Creditwatch Actions

Atrium III
                          Rating
Class            To                    From
A-1              AAA (sf)              AA+ (sf)/Watch Pos
A-2a             AA+ (sf)              AA (sf)/Watch Pos
A-2b             AA+ (sf)              AA (sf)/Watch Pos
B                A+ (sf)               BBB+ (sf)/Watch Pos
C                BB+ (sf)              BB+ (sf)/Watch Pos
D-1              B+ (sf)               B+ (sf)/Watch Pos
D-2              B+ (sf)               B+ (sf)/Watch Pos

Transaction Information

Issuer:               Atrium III
Collateral manager:   CSFB Alternative Capital Inc.
Trustee:              Bank of New York Mellon
Transaction type:     Cash flow CLO


BACM 2008-LS1: Moody's Lowers Cl. A-J Notes Rating to 'Ba2'
-----------------------------------------------------------
Moody's Investors Service downgraded the ratings of eight classes,
confirmed two classes and affirmed 11 classes of Banc of America
Commercial Mortgage Inc., Commercial Mortgage Pass-Through
Certificates, Series 2008-LS1:

Cl. A-1A, Affirmed at Aa1 (sf); previously on Apr 28, 2010
Downgraded to Aa1 (sf)

Cl. A-2, Affirmed at Aaa (sf); previously on Mar 24, 2008
Definitive Rating Assigned Aaa (sf)

Cl. A-3, Affirmed at Aaa (sf); previously on Mar 24, 2008
Definitive Rating Assigned Aaa (sf)

Cl. A-4A, Affirmed at Aaa (sf); previously on Apr 28, 2010
Confirmed at Aaa (sf)

Cl. A-4B, Affirmed at Aa1 (sf); previously on Apr 28, 2010
Downgraded to Aa1 (sf)

Cl. A-4BF, Affirmed at Aa1 (sf); previously on Apr 28, 2010
Downgraded to Aa1 (sf)

Cl. A-SM, Affirmed at Aa3 (sf); previously on Apr 28, 2010
Downgraded to Aa3 (sf)

Cl. A-M, Downgraded to Baa1 (sf); previously on Jan 26, 2012 A1
(sf) Placed Under Review for Possible Downgrade

Cl. A-J, Downgraded to Ba2 (sf); previously on Jan 26, 2012 Baa2
(sf) Placed Under Review for Possible Downgrade

Cl. B, Downgraded to B1 (sf); previously on Jan 26, 2012 Ba1 (sf)
Placed Under Review for Possible Downgrade

Cl. C, Downgraded to B3 (sf); previously on Jan 26, 2012 Ba3 (sf)
Placed Under Review for Possible Downgrade

Cl. D, Downgraded to Caa1 (sf); previously on Jan 26, 2012 B3 (sf)
Placed Under Review for Possible Downgrade

Cl. E, Confirmed at Caa2 (sf); previously on Jan 26, 2012 Caa2
(sf) Placed Under Review for Possible Downgrade

Cl. F, Confirmed at Caa3 (sf); previously on Jan 26, 2012 Caa3
(sf) Placed Under Review for Possible Downgrade

Cl. G, Affirmed at Ca (sf); previously on Apr 28, 2010 Downgraded
to Ca (sf)

Cl. H, Downgraded to C (sf); previously on Apr 28, 2010 Downgraded
to Ca (sf)

Cl. J, Downgraded to C (sf); previously on Apr 28, 2010 Downgraded
to Ca (sf)

Cl. K, Downgraded to C (sf); previously on Apr 28, 2010 Downgraded
to Ca (sf)

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

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

Cl. XW, Affirmed at Aaa (sf); previously on Mar 24, 2008
Definitive Rating Assigned Aaa (sf)

RATINGS RATIONALE

The downgrades are due to higher than anticipated losses from
liquidated loans and an increase in expected losses for specially
serviced and troubled loans.

The confirmations 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 January 26, 2012, Moody's placed seven classes on review for
possible downgrade. This action concludes Moody's review.

Moody's rating action reflects a cumulative base expected loss of
10.4% of the current pooled balance compared to 10.2% at last
review. The deal has experienced $112 million of realized losses
compared to $34 million at last review. Moody's base expected loss
plus realized losses is 14.1% compared to 11.2% at last review.
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 extent of the
slowdown in growth in the current macroeconomic environment and
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 in
recovery and improvements in the office sector continue, with
fundamentals in Gateway cities outperforming their suburban
counterparts. However, office demand is closely tied to
employment, where fundamentals remain weak, so significant
improvement may be delayed. Performance in the retail sector has
been mixed with on-going rent deflation and leasing challenges.
Across all property sectors, the availability of debt capital
continues to improve with monetary policy expected to remain
supportive and interest rate hikes postponed. Moody's central
global macroeconomic scenario reflects an overall downward
revision of forecasts since last quarter, amidst ongoing fiscal
consolidation efforts, household and banking sector deleveraging,
persistently high unemployment levels, and weak housing markets
that will continue to constrain growth.

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

Moody's noted that on November 22, 2011, it released a Request for
Comment, in which the rating agency has requested market feedback
on potential changes to its rating methodology for Interest-Only
Securities. If the revised methodology is implemented as proposed
the rating on BACM 2008-LS1 Class XW may be negatively affected.
Please refer to Moody's request for Comment, titled "Proposal
Changing the Global Rating Methodology for Structured Finance
Interest-Only Securities," for further details regarding the
implications of the proposed methodology change on Moody's rating.

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 56 as compared to 60
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 April 22, 2011.

DEAL PERFORMANCE

As of the January 10, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 7% to $2.1 billion
from $2.35 billion at securitization. The Certificates are
collateralized by 217 mortgage loans ranging in size from less
than 1% to 7% of the pool, with the top ten loans representing 30%
of the pool. The pool does not contain any defeased loans or loans
with credit estimates.

Sixty-five 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.

Twenty-one loans have been liquidated from the pool resulting in a
$112 million loss (52% average loss severity). Twenty-five loans,
representing 14% of the pool, are currently in special servicing.
The largest specially serviced exposure is the Memphis and Orlando
Industrial Portfolio ($59 million -- 2.8% of the pool). This
portfolio consists of two cross-collateralized, cross-defaulted
loans that are secured by six industrial properties (three in
Memphis and three in Orlando). The Memphis loan is REO, while the
Orlando loan is over 90 days delinquent. The servicer has
recognized a combined $28 million appraisal reduction for this
portfolio. The remaining 23 specially serviced loans are secured
by a mix of commercial and multifamily properties. Moody's has
estimated a $132 million loss (46% expected loss based on a 92%
probability of default) for all of the specially serviced loans.
The servicer has recognized a $114 million aggregate appraisal
reduction for 20 of the 25 specially serviced loans.

Moody's has assumed a high default probability for 22 poorly
performing loans representing 10% of the pool and has estimated an
aggregate $38 million loss (19% expected loss based on a 50%
probability default) from these troubled loans.

Based on the most recent remittance statement, Classes F
through S have experienced cumulative interest shortfalls totaling
$8.4 million. Moody's anticipates that the pool will continue to
experience interest shortfalls because of the high exposure to
specially serviced and troubled loans. Interest shortfalls are
caused by special servicing fees, including workout and
liquidation fees, appraisal subordinate entitlement reductions
(ASERs) and extraordinary trust expenses.

Moody's was provided with full year 2010 and partial or full year
2011 operating results for 99% and 96% of the conduit loans,
respectively. The conduit portion of the pool excludes specially
serviced and troubled loans. Moody's weighted average conduit LTV
is 109%, which is the same as at last review. Moody's net cash
flow reflects a weighted average haircut of 11% to the most
recently available net operating income. Moody's value reflects a
weighted average capitalization rate of 9.3%.

Moody's actual and stressed conduit DSCRs are 1.33X and .96X,
respectively, compared to 1.36X and .97X at last review. Moody's
actual DSCR is based on Moody's net cash flow (NCF) and the loan's
actual debt service. Moody's stressed DSCR is based on Moody's NCF
and a 9.25% stressed rate applied to the loan balance.

The top three conduit loans represent 17% of the pool balance. The
largest loan is the COPT Office Portfolio Loan ($150 million -- 7%
of the pool), which is secured by 694,000 square feet (SF) of
office space in the Westfields Corporate Center. The loan's
sponsor, Corporate Office Properties, owns a total of nine
buildings totaling 1.5 million SF in Westfields Corporate Center,
which is located in Chantilly, Virginia. The portfolio is 93%
leased as of September 2011 compared to 87% at last review.
Moody's LTV and stressed DSCR are 132% and 0.74X, respectively,
which is the same as at last review.

The second largest loan is the 600 West Chicago Loan ($134 million
-- 6% of the pool), which is secured by a 1.6 million SF Class A
office complex located on the edge of River North in Chicago's
central business district. The loan is pari passu with CGCMT 2007-
C6 & MLMT 2007-C1. The collateral is the former Montgomery Ward &
Co. catalog building and is a landmarked asset. It also serves as
Groupon's headquarters. CommonWealth REIT acquired the property
for $390 million in September 2011. Moody's LTV and stressed DSCR
are 118% and 0.85X, respectively, compared to 121% and 0.83X at
last review.

The third largest loan is the Hallmark Building Loan ($64 million
-- 3% of the pool), which is secured by a 305,000 SF office
building located in Dulles, Virginia. The Dulles Hilton Hotel is
attached to the Hallmark Building, but it is not part of the
collateral. The property is current, but is on the watchlist due
to low DSCR. The property was 89% leased as of September 2011,
which is the same as at last review. This loan is included as one
of the 22 poorly performing loans that Moody's has identified as
troubled loans. Moody's LTV and stressed DSCR are 181% and 0.57X,
compared to 192% and 0.53X at last review.


BANC OF AMERICA: S&P Lowers Rating on Class H Cert. to 'D'
----------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on eight
classes of commercial mortgage pass-through certificates from Banc
of America Commercial Mortgage Trust 2008-1, a U.S. commercial
mortgage-backed securities (CMBS) transaction. "Concurrently, we
affirmed our ratings on eight other classes from the same
transaction," S&P said.

"The downgrades primarily reflect credit support erosion that
we anticipate will occur upon the eventual resolution of nine
($111.1 million, 9.0%) of the transaction's 11 ($120.1 million,
9.7%) specially serviced assets, as well as a reduction in the
liquidity support available to the affected classes due to
interest shortfalls. As of the Jan. 10, 2012 trustee remittance
report, the trust experienced a monthly interest shortfall of
$380,028, primarily due to interest not advanced on assets that
the master servicer had deemed nonrecoverable ($163,024),
appraisal subordinate entitlement reduction (ASER) amounts
($155,754), asset interest rate modifications ($31,194), and
special servicing fees ($27,135). Our analysis indicated that the
total anticipated monthly interest shortfalls will cause class H
and the classes subordinate to it to continue to experience
interest shortfalls for the foreseeable future and lead to a
reduction in the liquidity support available to the classes senior
to it. As a result of our analysis, we're lowering our rating on
class H to 'D (sf)'. We previously lowered our ratings on classes
J through Q to 'D (sf)'," S&P said.

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

"Our analysis of the transaction also included a review of the
credit characteristics of all of the remaining assets in the pool
and the transaction structure. Using servicer-provided financial
information, we calculated an adjusted debt service coverage (DSC)
of 1.40x and a loan-to-value (LTV) ratio of 114.5%. We further
stressed the loans' cash flows under our 'AAA' scenario to yield a
weighted average DSC of 0.81x and an LTV ratio of 164.1%. The
implied defaults and loss severity under the 'AAA' scenario
were 93.1% and 45.3%. The DSC and LTV calculations noted above
exclude nine ($111.1 million, 9.0%) of the transaction's 11
($120.1 million, 9.7%) specially serviced assets. We separately
estimated losses for these assets and included them in our 'AAA'
scenario implied default and loss severity figures," S&P said.

                   Credit Considerations

"As of the Jan. 10, 2012 trustee remittance report, 11
($120.1 million, 9.7%) assets in the pool were with the special
servicer, CW Capital Asset Management LLC (CW Capital). The
reported payment status of the specially serviced assets is: five
are real estate-owned (REO) ($50.9 million, 4.1%), two are in
foreclosure ($37.1 million, 3.0%), one is 90-plus days delinquent
($23.9 million, 1.9%), one is 60 days delinquent ($1.8 million,
0.2%), and two are 30 days delinquent ($9 million, 0.5%).
Appraisal reduction amounts (ARAs) totaling $49.7 million are
in effect for seven of the specially serviced assets," S&P said.

"The Pecos I-215 II - Sansone Pecos loan ($23.9 million, 1.9%) is
the ninth-largest loan in the pool and the largest specially
serviced asset. The loan is secured by the fee interest in an
office building totaling 121,201 sq. ft. in Henderson, Nev. The
loan was reported as 90-plus days delinquent and was transferred
to the special servicer on Nov. 16, 2011, due to imminent monetary
default. According to CW Capital, it is currently considering
various workout strategies. As of September 2011, the reported DSC
and occupancy were 0.93x and 82.1%. We expect a significant loss
upon the eventual resolution of this asset," S&P said.

"The Onyx Building loan ($17.9 million, 1.4%) is the second-
largest specially serviced asset. The loan is collaralized by an
office building totaling 261,468 sq. ft. in Southfield, Mich. The
loan was transferred to the special servicer on Jan. 14, 2011, due
to imminent monetary default. According to CW Capital, it is
pursuing foreclosure. Reported DSC was 0.13x as of September
2011. An ARA of $12.1 million is in effect against this asset. We
expect a significant loss upon the eventual resolution of this
asset," S&P said.

"The remaining nine specially serviced assets have balances that
individually represent less than 1.4% of the total pool balance.
ARAs totaling $37.6 million are in effect against six of these
assets. We estimated losses for seven of these assets, arriving at
a weighted average loss severity of 62.0%. CW Capital has
indicated that the remaining two loans are performing and were
in the process of being returned to the master servicer, Bank of
America N.A. (Bank of America)," S&P said.

                      Transaction Summary

"As of the Jan. 10, 2012 trustee remittance report, the total pool
balance was $1.24 billion, which is 97.8% of the pool balance at
issuance. The pool includes 100 loans and five REO assets, down
from 108 loans at issuance. Bank of America provided financial
information for 95.9% of the assets in the pool, the majority of
which was December 2010 (33.3%) or September 2011 data (56.8%),"
S&P said.

"We calculated a weighted average DSC of 1.30x for the assets in
the pool based on the servicer-reported figures. Our adjusted DSC
and LTV ratio were 1.40x and 114.5%. Our adjusted DSC and LTV
figures excluded nine ($111.1 million, 9.0%) of the transaction's
11 ($120.1 million, 9.7%) specially serviced assets. Recent
financial reporting information was available for five of the
excluded assets, which exhibited a weighted average reported DSC
of 0.76x. The transaction has experienced $9.3 million in
principal losses in connection with four assets. Thirty-one loans
($226.8 million, 18.3%) in the pool are on the master servicer's
watchlist. Twenty-seven loans ($242.9 million, 19.6%) have a
reported DSC of less than 1.10x, 21 ($202.2 million, 16.3%) of
which have a reported DSC of less than 1.00x," S&P said.

                    Summary of Top 10 Loans

"The top 10 loans have an aggregate outstanding balance of
$589.3 million (47.5%). Using servicer-reported numbers, we
calculated a weighted average DSC of 1.30x for the top 10 loans.
Our adjusted DSC and LTV ratio for the top 10 loans were 1.21x and
120.8%. The ninth-largest loan ($23.9 million, 1.9%) is with the
special servicer. In addition, two of the top 10 loans appear on
the master servicer's watchlist," S&P said.

"The Vineyard Gate Apartments loan ($27.6 million, 2.2%, eighth-
largest loan in the pool) is secured by a 280-unit multifamily
property in Roseville, Calif. The loan appears on the master
servicer's watchlist due to low reported DSC. Reported DSC was
0.99x and reported occupancy was 96.4% as of September 2011," S&P
said.

The Commonwealth Storage Facility loan ($22.7 million, 1.8%, 10th-
largest loan in the pool) is secured by an industrial property
totaling 692,190 sq. ft. in Suffolk, Va. The loan appears on the
master servicer's watchlist due to low reported DSC. Reported DSC
was 0.81x and reported occupancy was 66.6% as of September 2011.

Standard & Poor's stressed the assets in the pool according to its
current criteria. The resultant credit enhancement levels are
consistent with S&P's rating actions.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

          http://standardandpoorsdisclosure-17g7.com

Ratings Lowered

Banc of America Commercial Mortgage Trust 2008-1
Commercial mortgage pass-through certificates

                Rating
Class      To           From        Credit enhancement (%)
A-J        BB (sf)      BB+ (sf)                     13.32
B          BB- (sf)     BB (sf)                      12.17
C          B+ (sf)      BB- (sf)                     11.02
D          B (sf)       B+ (sf)                      10.12
E          B- (sf)      B+ (sf)                       9.23
F          CCC+ (sf)    B+ (sf)                       8.33
G          CCC- (sf)    CCC (sf)                      7.31
H          D (sf)       CCC- (sf)                     6.16

Ratings Affirmed

Banc of America Commercial Mortgage Trust 2008-1
Commercial mortgage pass-through certificates

Class    Rating                      Credit enhancement (%)
A-1      AAA (sf)                                     29.94
A-2      AAA (sf)                                     29.94
A-3      AAA (sf)                                     29.94
A-SB     AAA (sf)                                     29.94
A-4      A+ (sf)                                      29.94
A-1A     A+ (sf)                                      29.94
A-M      BBB+ (sf)                                    19.71
XW       AAA (sf)                                       N/A

N/A -- Not applicable.


BAYVIEW COMMERCIAL: Moody's Reviews Ratings for Possible Downgrade
------------------------------------------------------------------
Moody's Investors Service placed on review for possible downgrade
the ratings on 231 tranches in 23 securitizations of small
business loans issued by Bayview Commercial Asset Trusts and
Bayview Commercial Mortgage Pass-Through Trusts. The master
servicer is Wells Fargo Bank. Commercial real estate primarily
secures the loans. The largest property types in these deals are
multifamily, retail, mixed use, and office properties.

RATING RATIONALE

Three factor prompted the review actions: 1) decreases in credit
enhancement resulting from collateral losses, 2) continued high
delinquencies, and 3) interest shortfalls. Collateral losses have
continued to be fairly substantial, with severities increasing to
over 70% on liquidated loans in the past year. The losses have
eroded the amount of credit enhancement available to protect
bondholders from future collateral losses.

Despite loan liquidations, delinquency levels remain at prolonged
high levels, indicating that new delinquencies are still
occurring, which will lead to further losses. Over the past twelve
months, delinquencies 60 days or more past due, including
foreclosure and REO, have declined slightly for some deals but
have most recently increased again and have generally remained
between 15%-25% of the outstanding pool balances. Most deals have
had delinquencies levels consistently in this high range over the
last two years.

Additionally, substantial loan modifications of approximately 35%-
50% of the outstanding pool balances, in most cases involving
interest rate reductions, have decreased the collateral weighted
average coupon, contributing to interest shortfalls on notes in
nine deals. High levels of modified loans also pose risk because
modified loans tend to have a higher re-default rate than do non-
modified loans.

These review actions used a methodology that includes an analysis
of the loan collateral to arrive at a range of preliminary
estimated lifetime net losses. Moody's evaluated this range of net
losses against the available credit enhancement provided by
subordination and excess spread as well as a reserve account or
overcollateralization. In the actions, Moody's considered
sufficiency of coverage in light of the credit quality of the
collateral pool, industry, geographical and loan concentrations,
historical variability of losses experienced by the issuer, and
servicer quality.

The ratings for tranches issued by Bayview Commercial Asset Trusts
and Bayview Commercial Mortgage Pass-Through Trusts were assigned
in line with Moody's existing methodology described in the
preceding paragraph. Moody's noted that on November 22, 2011, it
released a Request for Comment, in which the rating agency has
requested market feedback on potential changes to its rating
methodology for interest-only securities. If the revised
methodology is implemented as proposed, the ratings on interest-
only tranches may be negatively affected. Please refer to Moody's
Request for Comment, titled "Proposal Changing the Global Rating
Methodology for Structured Finance Interest-Only Securities," for
further details regarding the implications of the proposed
methodology changes on Moody's ratings.

During the review period, Moody's will evaluate whether or not the
available credit enhancement for each tranche adequately protects
investors against future collateral losses for a given rating
based on Moody's revised expected losses. Moody's will project
expected losses on the underlying pools of loans using delinquency
roll rates and an estimate of recoveries. The expected net losses
will incorporate a different likelihood of re-defaults on modified
loans as compared with the likelihood of defaults on non-modified
loans. Moody's will also investigate the impact of the interest
shortfalls, including exploring the nature of the legal promise
and likelihood of ultimate recovery.

Primary sources of assumption uncertainty are the general economic
environment, commercial property values, and the ability of small
businesses to recover from the recession.

Other methodologies and factors that Moody's may have considered
in the process of rating these transactions appear on Moody's
website. Further information on Moody's analysis of this
transaction is available on www.moodys.com.

The complete rating actions are as follows:

Issuer: Bayview Commercial Asset Trust 2003-2

Cl. IO, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Nov 6, 2003 Assigned Aaa (sf)

Cl. A, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Nov 6, 2003 Assigned Aaa (sf)

Cl. M-1, A2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to A2 (sf)

Cl. M-2, Baa3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Confirmed at Baa3 (sf)

Cl. B, B1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Upgraded to B1 (sf)

Issuer: BayView Commercial Aset Trust 2004-1

Cl. M-1, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Upgraded to Aaa (sf)

Cl. M-2, A1 (sf) Placed Under Review for Possible Downgrade;
previously on Oct 23, 2007 Upgraded to A1 (sf)

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

Issuer: BayView Commercial Asset Trust 2004-2

Cl. M-1, Aa2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Aa2 (sf)

Cl. M-2, Baa2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Baa2 (sf)

Cl. B-1, Ba3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba3 (sf)

Issuer: Bayview Commercial Asset Trust 2004-3

Cl. M-1, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Upgraded to Aaa (sf)

Cl. M-2, A1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Upgraded to A1 (sf)

Cl. B-1, Baa2 (sf) Placed Under Review for Possible Downgrade;
previously on Dec 22, 2004 Assigned Baa2 (sf)

Issuer: Bayview Commercial Asset Trust 2005-1

Cl. IO, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Mar 1, 2005 Assigned Aaa (sf)

Cl. A-1, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Mar 1, 2005 Assigned Aaa (sf)

Cl. A-2, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Mar 1, 2005 Assigned Aaa (sf)

Cl. M-1, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Upgraded to Aaa (sf)

Cl. M-2, Aa1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Upgraded to Aa1 (sf)

Cl. B-1, A1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Upgraded to A1 (sf)

Cl. B-2, Baa1 (sf) Placed Under Review for Possible Downgrade;
previously on Mar 1, 2005 Assigned Baa1 (sf)

Issuer: Bayview Commercial Asset Trust 2005-2

Cl. IO, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Jun 29, 2005 Assigned Aaa (sf)

Cl. A-1, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Jun 29, 2005 Assigned Aaa (sf)

Cl. A-2, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Jun 29, 2005 Assigned Aaa (sf)

Cl. M-1, Aa3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Aa3 (sf)

Cl. M-2, A2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to A2 (sf)

Cl. M-3, A3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to A3 (sf)

Cl. M-4, Baa1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Baa1 (sf)

Cl. M-5, Baa3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Baa3 (sf)

Cl. M-6, Ba2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba2 (sf)

Cl. B-1, Ba3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba3 (sf)

Cl. B-2, B2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B2 (sf)

Issuer: BayView Commercial Asset Trust 2005-4

Cl. IO, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Dec 22, 2005 Assigned Aaa (sf)

Cl. A-1, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Dec 22, 2005 Assigned Aaa (sf)

Cl. A-2, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Dec 22, 2005 Assigned Aaa (sf)

Cl. M-1, Aa3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Aa3 (sf)

Cl. M-2, A1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to A1 (sf)

Cl. M-3, A3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to A3 (sf)

Cl. M-4, Baa1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Baa1 (sf)

Cl. M-5, Baa3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Baa3 (sf)

Cl. M-6, Ba2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba2 (sf)

Cl. B-1, Ba3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba3 (sf)

Cl. B-2, B1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B1 (sf)

Issuer: BayView Commercial Asset Trust 2006-1

Cl. IO, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Mar 8, 2006 Assigned Aaa (sf)

Cl. A-1, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Mar 8, 2006 Assigned Aaa (sf)

Cl. A-2, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Mar 8, 2006 Assigned Aaa (sf)

Cl. M-1, Aa1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Confirmed at Aa1 (sf)

Cl. M-2, Aa2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Confirmed at Aa2 (sf)

Cl. M-3, Aa3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Confirmed at Aa3 (sf)

Cl. M-4, A1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Confirmed at A1 (sf)

Cl. M-5, A2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Confirmed at A2 (sf)

Cl. M-6, A3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Confirmed at A3 (sf)

Cl. B-1, Baa2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Baa2 (sf)

Cl. B-2, Ba1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba1 (sf)

Issuer: Bayview Commercial Asset Trust 2006-2

Cl. IO, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Jun 1, 2006 Assigned Aaa (sf)

Cl. A-1, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Jun 1, 2006 Assigned Aaa (sf)

Cl. A-2, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Jun 1, 2006 Assigned Aaa (sf)

Cl. M-1, Aa2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Aa2 (sf)

Cl. M-2, Aa3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Aa3 (sf)

Cl. M-3, A2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to A2 (sf)

Cl. M-4, A3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to A3 (sf)

Cl. M-5, Baa2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Baa2 (sf)

Cl. M-6, Ba1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba1 (sf)

Cl. B-1, Ba2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba2 (sf)

Cl. B-2, Ba3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba3 (sf)

Issuer: Bayview Commercial Asset Trust 2006-3

Cl. IO, Aa1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Aa1 (sf)

Cl. A-1, Aa1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Aa1 (sf)

Cl. A-2, Aa1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Aa1 (sf)

Cl. M-1, A2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to A2 (sf)

Cl. M-2, Baa1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Baa1 (sf)

Cl. M-3, Baa3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Baa3 (sf)

Cl. M-4, Ba1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba1 (sf)

Cl. M-5, Ba2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba2 (sf)

Cl. M-6, Ba3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba3 (sf)

Cl. B-1, B2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B2 (sf)

Cl. B-2, B3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B3 (sf)

Issuer: Bayview Commercial Asset Trust 2006-4

Cl. IO, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Nov 14, 2006 Assigned Aaa (sf)

Cl. A-1, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Nov 14, 2006 Assigned Aaa (sf)

Cl. A-2, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Nov 14, 2006 Assigned Aaa (sf)

Cl. M-1, A2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to A2 (sf)

Cl. M-2, Baa1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Baa1 (sf)

Cl. M-3, Baa2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Baa2 (sf)

Cl. M-4, Ba1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba1 (sf)

Cl. M-5, Ba2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba2 (sf)

Cl. M-6, Ba3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba3 (sf)

Cl. B-1, B2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B2 (sf)

Cl. B-2, B3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B3 (sf)

Issuer: Bayview Commercial Asset Trust 2007-1

Cl. SIO, Aa3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Aa3 (sf)

Cl. IO, Aa3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Aa3 (sf)

Cl. A-1, Aa3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Aa3 (sf)

Cl. A-2, Aa3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Aa3 (sf)

Cl. M-1, Baa2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Baa2 (sf)

Cl. M-2, Ba1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba1 (sf)

Cl. M-3, Ba2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba2 (sf)

Cl. M-4, Ba3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba3 (sf)

Cl. M-5, B1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B1 (sf)

Cl. M-6, B3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B3 (sf)

Cl. B-1, Caa1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Caa1 (sf)

Cl. B-2, Caa2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Caa2 (sf)

Issuer: Bayview Commercial Asset Trust 2007-2

Cl. IO, A1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to A1 (sf)

Cl. A-1, A1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to A1 (sf)

Cl. A-2, A1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to A1 (sf)

Cl. M-1, Baa3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Baa3 (sf)

Cl. M-2, Ba2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba2 (sf)

Cl. M-3, Ba3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba3 (sf)

Cl. M-4, B1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B1 (sf)

Cl. M-5, B2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B2 (sf)

Cl. M-6, Caa1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Caa1 (sf)

Cl. B-1, Caa2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Caa2 (sf)

Cl. B-2, Caa3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Caa3 (sf)

Issuer: Bayview Commercial Asset Trust 2007-3

Cl. SIO, Aa2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Aa2 (sf)

Cl. IO, Aa2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Aa2 (sf)

Cl. A-1, Aa2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Aa2 (sf)

Cl. A-2, Aa2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Aa2 (sf)

Cl. M-1, A3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to A3 (sf)

Cl. M-2, Baa2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Baa2 (sf)

Cl. M-3, Baa3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Baa3 (sf)

Cl. M-4, Ba2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba2 (sf)

Cl. M-5, Ba3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba3 (sf)

Cl. M-6, B1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B1 (sf)

Cl. B-1, B2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B2 (sf)

Cl. B-2, B3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B3 (sf)

Issuer: Bayview Commercial Asset Trust 2007-4

Cl. IO, A3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to A3 (sf)

Cl. A-1, A3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to A3 (sf)

Cl. A-2, A3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to A3 (sf)

Cl. M-1, Ba2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba2 (sf)

Cl. M-2, B1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B1 (sf)

Cl. M-3, B2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B2 (sf)

Cl. M-4, B3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B3 (sf)

Cl. M-5, Caa1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Caa1 (sf)

Cl. M-6, Caa2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Caa2 (sf)

Cl. B-1, Caa3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Caa3 (sf)

Cl. B-2, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ca (sf)

Issuer: Bayview Commercial Asset Trust 2007-5

Cl. IO, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Oct 1, 2007 Assigned Aaa (sf)

Cl. A-2, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Oct 1, 2007 Assigned Aaa (sf)

Cl. A-3, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Oct 1, 2007 Assigned Aaa (sf)

Cl. A-4, B1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B1 (sf)

Cl. M-1, B3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B3 (sf)

Cl. M-2, Caa1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Caa1 (sf)

Cl. M-3, Caa2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Caa2 (sf)

Cl. M-4, Caa3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Caa3 (sf)

Cl. M-5, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ca (sf)

Cl. M-6, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ca (sf)

Cl. B-1, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ca (sf)

Cl. B-2, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ca (sf)

Issuer: Bayview Commercial Asset Trust 2007-6

Cl. IO, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Dec 5, 2007 Assigned Aaa (sf)

Cl. A-1, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Dec 5, 2007 Assigned Aaa (sf)

Cl. A-2, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Dec 5, 2007 Assigned Aaa (sf)

Cl. A-3A, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Dec 5, 2007 Assigned Aaa (sf)

Cl. A-3B, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Dec 5, 2007 Assigned Aaa (sf)

Cl. A-4A, Ba1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba1 (sf)

Cl. A-4B, Ba1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba1 (sf)

Cl. M-1, B2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B2 (sf)

Cl. M-2, B3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B3 (sf)

Cl. M-3, Caa1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Caa1 (sf)

Cl. M-4, Caa2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Caa2 (sf)

Cl. M-5, Caa3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Caa3 (sf)

Cl. M-6, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ca (sf)

Cl. B-1, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ca (sf)

Cl. B-2, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Confirmed at Ca (sf)

Issuer: Bayview Commercial Asset Trust 2008-1

Cl. IO, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Jan 7, 2008 Assigned Aaa (sf)

Cl. A-2A, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Jan 7, 2008 Assigned Aaa (sf)

Cl. A-2B, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Jan 7, 2008 Assigned Aaa (sf)

Cl. A-3, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Jan 7, 2008 Assigned Aaa (sf)

Cl. A-4, A2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to A2 (sf)

Cl. M-1, Ba2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba2 (sf)

Cl. M-2, Ba3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba3 (sf)

Cl. M-3, B1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B1 (sf)

Cl. M-4, B2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B2 (sf)

Cl. M-5, B3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B3 (sf)

Cl. M-6, Caa1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Caa1 (sf)

Cl. B-1, Caa2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Caa2 (sf)

Cl. B-2, Caa3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Caa3 (sf)

Issuer: Bayview Commercial Asset Trust 2008-2

Cl. SIO, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Mar 5, 2008 Assigned Aaa (sf)

Cl. IO, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Mar 5, 2008 Assigned Aaa (sf)

Cl. A-1, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Mar 5, 2008 Assigned Aaa (sf)

Cl. A-2, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Mar 5, 2008 Assigned Aaa (sf)

Cl. A-3, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Mar 5, 2008 Assigned Aaa (sf)

Cl. A-4A, A3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to A3 (sf)

Cl. A-4B, A3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to A3 (sf)

Cl. M-1, Ba3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba3 (sf)

Cl. M-2, B1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B1 (sf)

Cl. M-3, B2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B2 (sf)

Cl. M-4, B3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B3 (sf)

Cl. M-5, Caa1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Caa1 (sf)

Cl. M-6, Caa2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Caa2 (sf)

Cl. B-1, Caa3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Caa3 (sf)

Cl. B-2, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ca (sf)

Issuer: Bayview Commercial Asset Trust 2008-3

Cl. SIO, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Apr 28, 2008 Assigned Aaa (sf)

Cl. IO, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Apr 28, 2008 Assigned Aaa (sf)

Cl. A-1, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Apr 28, 2008 Assigned Aaa (sf)

Cl. A-2, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Apr 28, 2008 Assigned Aaa (sf)

Cl. A-3, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Apr 28, 2008 Assigned Aaa (sf)

Cl. A-4, A2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to A2 (sf)

Cl. M-1, Baa3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Baa3 (sf)

Cl. M-2, Ba2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba2 (sf)

Cl. M-3, Ba3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba3 (sf)

Cl. M-4, B2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B2 (sf)

Cl. M-5, B3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B3 (sf)

Cl. M-6, Caa1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Caa1 (sf)

Cl. B-1, Caa2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Caa2 (sf)

Cl. B-2, Caa3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Caa3 (sf)

Issuer: Bayview Commercial Asset Trust 2008-4

Cl. SIO, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Jul 7, 2008 Assigned Aaa (sf)

Cl. A-1, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Jul 7, 2008 Assigned Aaa (sf)

Cl. A-2, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Jul 7, 2008 Assigned Aaa (sf)

Cl. A-3, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Jul 7, 2008 Assigned Aaa (sf)

Cl. A-4, Aa3 (sf) Placed Under Review for Possible Downgrade;
previously on Feb 23, 2009 Downgraded to Aa3 (sf)

Cl. M-1, Baa2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Baa2 (sf)

Cl. M-2, Baa3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Baa3 (sf)

Cl. M-3, Ba1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba1 (sf)

Cl. M-4, Ba2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Confirmed at Ba2 (sf)

Cl. M-5, Ba3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Confirmed at Ba3 (sf)

Cl. M-6, B1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Confirmed at B1 (sf)

Cl. B-1, B3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B3 (sf)

Cl. B-2, Caa1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Caa1 (sf)

Issuer: BayView Commercial Mortgage Pass-Through Trust 2006-SP1

Cl. M-1, Aa1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Upgraded to Aa1 (sf)

Cl. M-2, Aa2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Upgraded to Aa2 (sf)

Cl. M-3, A2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 6, 2006 Assigned A2 (sf)

Cl. M-4, Baa1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Baa1 (sf)

Cl. B-1, Ba1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba1 (sf)

Cl. B-2, Ba3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba3 (sf)

Issuer: Bayview Commercial Mortgage Pass-Through Trust 2006-SP2

Cl. IO, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Dec 20, 2006 Assigned Aaa (sf)

Cl. A, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Dec 20, 2006 Assigned Aaa (sf)

Cl. M-1, Aa1 (sf) Placed Under Review for Possible Downgrade;
previously on Dec 20, 2006 Assigned Aa1 (sf)

Cl. M-2, Aa2 (sf) Placed Under Review for Possible Downgrade;
previously on Dec 20, 2006 Assigned Aa2 (sf)

Cl. M-3, A1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to A1 (sf)

Cl. M-4, Baa1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Baa1 (sf)

Cl. M-5, Baa2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Baa2 (sf)

Cl. M-6, Ba1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba1 (sf)

Cl. B-1, Ba3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to Ba3 (sf)

Cl. B-2, B1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 13, 2011 Downgraded to B1 (sf)

REGULATORY DISCLOSURES

Although the following credit ratings have been issued in a non-EU
country which has not been recognized as endorsable at this date,
these credit ratings are deemed "EU qualified by extension" and
may still be used by financial institutions for regulatory
purposes until 30 April 2012. Further information on the EU
endorsement status and on the Moody's office that has issued a
particular Credit Rating is available on www.moodys.com.

Issuer: BayView Commercial Aset Trust 2004-1

Issuer: Bayview Commercial Asset Trust 2003-2

Issuer: BayView Commercial Asset Trust 2004-2

Issuer: Bayview Commercial Asset Trust 2004-3

Issuer: Bayview Commercial Asset Trust 2005-1

Issuer: Bayview Commercial Asset Trust 2005-2

Issuer: BayView Commercial Asset Trust 2005-4

Issuer: BayView Commercial Asset Trust 2006-1

Issuer: Bayview Commercial Asset Trust 2006-2

Issuer: Bayview Commercial Asset Trust 2006-3

Issuer: Bayview Commercial Asset Trust 2006-4

Issuer: Bayview Commercial Asset Trust 2007-1

Issuer: Bayview Commercial Asset Trust 2007-2

Issuer: Bayview Commercial Asset Trust 2007-3

Issuer: Bayview Commercial Asset Trust 2007-4

Issuer: Bayview Commercial Asset Trust 2007-5

Issuer: Bayview Commercial Asset Trust 2007-6

Issuer: Bayview Commercial Asset Trust 2008-1

Issuer: Bayview Commercial Asset Trust 2008-2

Issuer: Bayview Commercial Asset Trust 2008-3

Issuer: Bayview Commercial Asset Trust 2008-4

Issuer: BayView Commercial Mortgage Pass-Through Trust 2006-SP1

Issuer: Bayview Commercial Mortgage Pass-Through Trust 2006-SP2


BLACKROCK II: S&P Raises Ratings on 2 Classes of Notes to 'BB+'
---------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on five
classes of notes from BlackRock Senior Income Series II, a
collateralized loan obligation (CLO) transaction managed by
Blackrock Financial Management Inc., and removed them from
CreditWatch with positive implications. "In addition, we
affirmed our rating on one other class from the same
transaction and removed it from CreditWatch positive,"
S&P said.

"The upgrades reflect improved performance we have observed in the
deal's underlying asset portfolio since our December 2009 rating
actions, when we downgraded six of the notes. As of the December
2011 trustee report, the transaction held $2.3 million in
defaulted assets, down from the $10.7 million noted in the
September 2009 trustee report, which we referenced for our
December 2009 rating actions. Also, as of December 2011, the
transaction held $9.3 million in assets from underlying obligors
with ratings in the 'CCC' range, compared with $53.5 million in
September 2009," S&P said.

The reinvestment period ended in May 2011, and the class A-1 and
A-2 notes have paid down to 81.4% and 79.2% of their original
balances. The paydowns to the class A notes and the improvement in
asset credit quality has helped boost the transaction's
overcollateralization (O/C) ratios, which all have increased since
September 2009:

    The class A/B O/C ratio is 125.40%, compared with 117.08%;
    The class C O/C ratio is 113.24%, compared with 107.51%; and
    The class D O/C ratio is 105.88%, compared with 101.55%.

"Also, when we applied the largest obligor test, one of the
supplement tests, to the class D-1 and D-2 notes, the transaction
was able to withstand the specified combination of underlying
asset defaults at the 'BB (sf)' rating level," S&P said.

"We affirmed our rating on class C to reflect the availability of
credit support at the current rating level," S&P said.

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

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

             http://standardandpoorsdisclosure-17g7.com

Rating And Creditwatch Actions

Blackrock Senior Income Series II
                           Rating
Class                   To           From
A-1                     AAA (sf)     AA+ (sf)/Watch Pos
A-2                     AAA (sf)     AA+ (sf)/Watch Pos
B                       AA+ (sf)     AA (sf)/Watch Pos
C                       BBB+ (sf)    BBB+ (sf)/Watch Pos
D-1                     BB+ (sf)     CCC+ (sf)/Watch Pos
D-2                     BB+ (sf)     CCC+ (sf)/Watch Pos


BSCMS COMMERCIAK: Fitch Affirms Rating on Six Certificate Classes
-----------------------------------------------------------------
Fitch Ratings has affirmed six and downgraded eight classes of
BSCMS Commercial Mortgage Trust 2004-TOP16, commercial mortgage
pass-through certificates.

The downgrades are due to an increase in Fitch expected losses and
the recent transfer of four loans to special servicing.  Fitch
modeled losses of 2.89% of the outstanding pool.  The expected
losses of the original pool are at 2.15%, which includes 0.65% to
date.  Current cumulative interest shortfalls totaling $384,448
are affecting classes O and P.

As of the February 2012 distribution date, the pool's certificate
balance has paid down 25% to $859.3 million from $1.156 billion.
Fitch identified 19 (22.4%) Fitch Loans of Concern, of which four
(1.7%) are specially serviced with a status of 60 or 90 days
delinquent.  In addition, there are 10 (11.3%) defeased loans
within the pool, of which three (7.4%) are within the top 15.

The largest contributor to expected losses is a loan (0.86%)
secured by a 51,311 square feet (SF) unanchored retail center in
Duluth, GA.  The loan transferred to special servicing in October
2011 due to monetary default due to declining performance at the
property.  The last reported occupancy and debt service coverage
ratio (DSCR) on the property was 67.5% and 0.47 times (x),
respectively, as of March 2011.  The Special Servicer is
negotiating with the borrower while pursuing all right and
remedies to protect the trust.

The second largest contributor to expected losses is
collateralized by a 73,547 SF anchored mixed-use retail and office
center located in Foster City, CA.  The loan was special serviced
until April 2011 when it was modified and returned to the master
servicer as a corrected mortgage loan.  The modification included
a 12-month extension to the new maturity of July 2015 and
interest-only payments for the remaining term of the loan.  The
Master Servicer reports that as of third-quarter 2011 the
property's occupancy and DSCR was 76.9% and 0.92x respectively.

The third largest contributor to Fitch expected losses is a loan
(0.41%) secured by a 43,927 SF suburban office building located in
Fort Washington, PA. The most recent occupancy reported by the
Master Servicer is 56.4% as of June 2011, which is down from 64%
as of year-end 2010.  In addition, the largest tenant, Temple
University (35%), is considering downsizing their current space.
The Master Servicer also reports that the occupancy has caused a
decrease in DSCR to 0.56x for the same period.

Fitch downgrades these classes, revises Outlooks and assigns
Recovery Estimates (REs):

  -- $15.8 million class E to 'BBBsf' from 'A-sf'; Outlook to
     Stable from Negative;
  -- $10.1 million class F to 'BBsf' from 'BBB+sf'; Outlook to
     Stable from Negative;
  -- $11.5 million class G to 'BBsf' from 'BBB-sf'; Outlook
     Negative;
  -- $10.1 million class H to 'CCCsf' from 'Bsf'; RE 55%;
  -- $2.8 million class J to 'CCCsf' from 'Bsf'; RE 0%;
  -- $5.7 million class L to 'CCsf' from 'CCCsf'; RE 0%;
  -- $1.4 million class M to 'Csf' from 'CCCsf'; RE 0%;
  -- $1.4 million class N to 'Csf' from 'CCsf'; RE 0%.

Fitch affirms these classes and assigns Recovery Estimates (REs):

  -- $70.7 million class A-5 at 'AAAsf'; Outlook Stable;
  -- $676 million class A-6 at 'AAAsf'; Outlook Stable;
  -- $20.2 million class B at 'AA+sf'; Outlook Stable;
  -- $13 million class C at 'AAsf'; Outlook Stable;
  -- $13 million class D at 'Asf'; Outlook Stable;
  -- $4.3 million class K at 'CCCsf'; RE 0%.

Fitch does not rate class P.

Classes A-1, A-2, A-3 and A-4 have paid in full.  Class O will
remain at 'D' with a Recovery Estimate of 0% due to incurred
losses.


CALIFORNIA COUNTY: S&P Ups Ratings on 2 Classes of Notes From 'B-'
------------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on
California County Tobacco Securitization Agency's (Kern County
Tobacco Funding's) class 2002A, 2002B (2029), and 2002B (2037)
notes and Rockland Tobacco Asset Securitization Corp.'s class
2025, 2035, and 2043 notes. Both transactions are settlement-
backed securitizations backed by payments from participating
tobacco manufacturers under the master settlement agreement.

"In our January 2012 analyses of these transactions, we used the
incorrect percentages of tobacco settlement payments that the two
counties pledged to their transaction, which affected the ratings
on these six classes. The rating actions correct this," S&P said.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

           http://standardandpoorsdisclosure-17g7.com

Ratings Corrected

California County Tobacco Securitization Agency (Kern County
Tobacco Funding Corp.)
$105.245 mil tobacco settlement asset-backed bonds

Class    Maturity   Sale amount        Rating
                       (mil. $)     To           From
2002B    06/01/29         27.88     BBB (sf)     B (sf)
2002B    06/01/37         29.01     BBB (sf)     B- (sf)
2002A    06/01/43         40.96     BBB (sf)     B- (sf)

Rockland Tobacco Asset Securitization Corp.
$47.75 mil tobacco settlement asset backed bonds series 2001

Class    Maturity   Sale amount        Rating
                       (mil. $)     To           From
2025     08/15/25         12.01     BBB (sf)     BB+ (sf)
2035     08/15/35         15.23     BBB (sf)     B (sf)
2043     08/15/43         18.62     BBB (sf)     B (sf)

Other Ratings

Rockland Tobacco Asset Securitization Corp.
$47.75 mil tobacco settlement asset backed bonds series 2001

Class    Maturity   Sale amount        Rating
                       (mil. $)     To           From
2012     08/15/12          0.34     BBB (sf)     BBB (sf)

2013     08/15/13          0.38     BBB (sf)     BBB (sf)


CALLIDUS DEBT: S&P Raises Rating on Class E Notes to 'BB'
---------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A, B, C, D, and E notes from Callidus Debt Partners CLO Fund VII
Ltd., a U.S. collateralized loan obligation (CLO) transaction
managed by GSO/Blackstone Debt Funds Management. "At the same
time, we removed the ratings from CreditWatch, where we placed
them with positive implications on Nov. 14, 2011," S&P said.

"The upgrades mainly reflect the improved credit performance of
the transaction's underlying asset portfolio since we lowered our
ratings on all of the notes in January 2010, following the
application of our September 2009 collateralized debt obligation
(CDO) criteria. As of the January 2012 trustee report, the
transaction's collateral pool had $2.97 million of defaulted
assets. This was down from the $6.58 million of defaulted assets
noted in the December 2009 trustee report, which we referenced
for our January 2010 rating actions. Additionally, the trustee
reported $19.76 million in assets from obligors rated in the 'CCC'
category in January 2012, compared with $35.41 million in December
2009," S&P said.

The upgrades also reflect an improvement in the
overcollateralization (O/C) available to support the notes since
S&P's January 2010 rating actions. The trustee reported the ing
O/C ratios in the January 2012 monthly report:

   The class A/B O/C ratio was 125.02%, compared with a reported
   ratio of 121.12% in December 2009;

   The class C O/C ratio was 116.76%, compared with a reported
   ratio of 113.11% in December 2009;

   The class D O/C ratio was 112.37%, compared with a reported
   ratio of 108.86% in December 2009; and

   The class E O/C ratio was 107.90%, compared with a reported
   ratio of 104.53% in December 2009.

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.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

      http://standardandpoorsdisclosure-17g7.com

Ratings Raised And Removed From Creditwatch Positive

Callidus Debt Partners CLO Fund VII Ltd.
                   Rating
Class         To           From
A             AA+ (sf)     AA- (sf)/Watch Pos
B             AA (sf)      A+ (sf)/Watch Pos
C             A- (sf)      BBB+ (sf)/Watch Pos
D             BBB (sf)     BB+ (sf)/Watch Pos
E             BB (sf)      B+ (sf)/Watch Pos

Transaction Information
Issuer:             Callidus Debt Partners CLO Fund VII Ltd.
Coissuer:           Callidus Debt Partners CLO Fund VII Inc.
Underwriter:        Lehman Bros. Inc.
Collateral manager: GSO/Blackstone Debt Funds Management
Trustee:            Citibank N.A.
Transaction type:   Cash flow CDO


CARLYLE DAYTONA: S&P Keeps 'CCC-' Class B-2L Note Rating on Watch
-----------------------------------------------------------------
Standard & Poor's Ratings Services corrected its rating on the
class C-2 notes from Carlyle Daytona CLO Ltd. by lowering it to
'AA+ (sf)' from 'AAA (sf)'

"Due to an error, we did not lower our rating on the class C-2
notes, which are backed by U.S. treasury strips, to 'AA+ (sf)'
when we lowered 154 other U.S. structured credit ratings on
Aug. 10, 2011, after lowering of the long-term sovereign credit
rating on the United States of America to 'AA+'. The rating action
corrects this," S&P said.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

           http://standardandpoorsdisclosure-17g7.com

Rating Corrected

Carlyle Daytona CLO Ltd.
                      Rating
Class            To           From
C-2              AA+ (sf)     AAA (sf)

Ratings Unaffected

Carlyle Daytona CLO Ltd.

Class           Rating
X               AAA (sf)
A-1L            AA+ (sf)
A-1LV           AA+ (sf)
A-2L            AA- (sf)/Watch Pos
A-3L            BBB+ (sf)/Watch Pos
B-1L            BB+ (sf)/Watch Pos
B-2L            CCC- (sf)/Watch Pos


CD COMMERCIAL: Fitch Puts Three Note Classes on Watch Negative
--------------------------------------------------------------
Fitch Ratings has placed five classes of CD Commercial Mortgage
Trust 2007-CD4 on Rating Watch Negative.

Classes A-MFX through C have been placed on Rating Watch Negative
based on an increase in Fitch expected losses following a
preliminary review of the transaction's 49 specially serviced
loans, six of which are within the top 15 loans in the pool.
Fitch's preliminary review incorporated updated valuations
obtained by the special servicer since Fitch's last rating action.

The largest contributor to expected losses is the Riverton
Apartments.  The Real Estate Owned (REO) asset is secured by a
class B, rent-stabilized multifamily housing project, consisting
of 1,228 units, located in Harlem, NY.

Fitch expects to resolve the Rating Watch status within the next
several months following a complete review of the transaction
including updated performance data for performing loans.  Fitch
expects significant paydown in the next few months due to loan
maturities which may offset some expected losses and allow more
senior classes to be removed from Rating Watch Negative.

Fitch has placed these classes on Rating Watch Negative:

  -- $595 million class A-MFX 'AAAsf';
  -- $65 million class A-MFL 'AAAsf';
  -- $585.7 million class A-J 'Bsf';
  -- $41.2 million class B 'B-sf';
  -- $90.7 million class C 'B-sf'.


CITICORP MORTGAGE: Moody's Lowers Rating of Cl. IIA-1 Notes to Ba1
------------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of eight
tranches and upgraded the ratings of two tranches from two RMBS
transactions issued by Citicorp Mortgage Securities Trust and PHH
Mortgage Trust.

Complete rating actions are:

Issuer: Citicorp Mortgage Securities Trust, Series 2007-8

Cl. IIA-1, Downgraded to Ba1 (sf); previously on Jul 15, 2011
Upgraded to Baa2 (sf)

Cl. IIA-IO, Downgraded to Ba1 (sf); previously on Jul 15, 2011
Upgraded to Baa2 (sf)

Cl. IIIA-1, Upgraded to Ba3 (sf); previously on Jun 4, 2010
Downgraded to B2 (sf)

Cl. IIIA-IO, Upgraded to Ba3 (sf); previously on Jun 4, 2010
Downgraded to B2 (sf)

Issuer: PHH Mortgage Trust, Series 2008-CIM2

Cl. 1-A-1, Downgraded to Baa3 (sf); previously on Jul 18, 2011
Downgraded to Baa1 (sf)

Cl. 2-A-1, Downgraded to Baa3 (sf); previously on Jul 18, 2011
Downgraded to Baa1 (sf)

Cl. 4-A-1, Downgraded to Baa3 (sf); previously on May 19, 2010
Downgraded to Aa3 (sf)

Cl. 4-A-X, Downgraded to Baa3 (sf); previously on May 19, 2010
Downgraded to Aa3 (sf)

Cl. A-PO, Downgraded to Baa3 (sf); previously on Jul 18, 2011
Downgraded to Baa1 (sf)

Cl. A-X, Downgraded to Baa3 (sf); previously on Jul 18, 2011
Downgraded to Baa1 (sf)

RATINGS RATIONALE

The collateral backing these transactions consists primarily of
first-lien, fixed and adjustable-rate prime jumbo residential
mortgage loans. The actions are a result of the recent performance
review and reflect Moody's updated loss expectations on prime
jumbo pools issued from 2005 to 2008.

The methodologies used in these ratings were "Moody's Approach to
Rating US Residential Mortgage-Backed Securities" published in
December 2008, and "2005 -- 2008 US RMBS Surveillance Methodology"
published in July 2011.

To assess the rating implications of the updated loss levels on
prime jumbo RMBS, each individual pool was run through a variety
of scenarios in the Structured Finance Workstation(R) (SFW), the
cash flow model developed by Moody's Wall Street Analytics. This
individual pool level analysis incorporates performance variances
across the different pools and the structural features of the
transaction including priorities of payment distribution among the
different tranches, average life of the tranches, current balances
of the tranches and future cash flows under expected and stressed
scenarios. The scenarios include ninety-six different combinations
comprising of six loss levels, four loss timing curves and four
prepayment curves. The volatility in losses experienced by a
tranche due to extended foreclosure timelines by servicers is
taken into consideration when assigning ratings.

The above mentioned approach is adjusted slightly when estimating
losses on pools left with a small number of loans to account for
the volatile nature of small pools. Even if a few loans in a small
pool become delinquent, there could be a large increase in the
overall pool delinquency level due to the concentration risk. To
project losses on pools with fewer than 100 loans, Moody's first
estimates a "baseline" average rate of new delinquencies for the
pool that varies from 10% to 21% on average. The baseline rates
are higher than the average rate of new delinquencies for larger
pools for the respective vintages.

Once the baseline rate is set, further adjustments are made based
on 1) the number of loans remaining in the pool and 2) the level
of current delinquencies in the pool. The fewer the number of
loans remaining in the pool, the higher the volatility in
performance. Once the loan count in a pool falls below 75, the
rate of delinquency is increased by 1% for every loan less than
75. For example, for a pool with 74 loans with a base rate of new
delinquency of 10.00%, the adjusted rate of new delinquency would
be 10.10%. In addition, if current delinquency levels in a small
pool is low, future delinquencies are expected to reflect this
trend. To account for that, the rate calculated above is
multiplied by a factor ranging from 0.2 to 2.0 for current
delinquencies ranging from less than 2.5% to greater than 80%
respectively. Delinquencies for subsequent years and ultimate
expected losses are projected using the approach described in the
"2005 -- 2008 US RMBS Surveillance Methodology" publication.

The above methodology only applies to pools with at least 40 loans
and a pool factor of greater than 5%. Moody's may withdraw its
rating when the pool factor drops below 5% and the number of loans
in the pool declines to 40 loans or lower unless specific
structural features allow for a monitoring of the transaction
(such as a credit enhancement floor).

Moody's noted that on November 22, 2011, it released a Request for
Comment, in which the rating agency has requested market feedback
on potential changes to its rating methodology for Interest-Only
Securities. If the revised methodology is implemented as proposed
the rating on Citicorp Mortgage Securities Trust Series 2007-8
Class IIA-IO, PHH Mortgage Trust Series 2008-CIM2 Class 4-A-X, and
PHH Mortgage Trust Series 2008-CIM2 Class A-X will have a negative
impact. The rating on Citicorp Mortgage Securities Trust Series
2007-8 Class IIIA-IO will have a neutral impact. Please refer to
Moody's request for Comment, titled "Proposal Changing the Global
Rating Methodology for Structured Finance Interest-Only
Securities," for further details regarding the implications of the
proposed methodology change on Moody's rating.

The primary source of assumption uncertainty is the current
macroeconomic environment, in which unemployment levels remain
high, and weakness persists in the housing market. Moody's now
projects house price index to reach a bottom in early 2012, with a
3% remaining decline in 2012, and unemployment rate to start
declining, albeit slowly, as the year progresses.


CITYSCAPE HOME: Moody's Withdraws Ratings of $6MM Subprime RMBS
---------------------------------------------------------------
Moody's Investors Service has withdrawn the rating of $6 million
of pre-2000 subprime RMBS from various issuers. These tranches are
backed by pools of mortgage loans with a pool factor less than 5%
and containing less than or equal to 40 loans.

Complete rating actions are:

Issuer: Cityscape Home Equity Loan Trust 1996-2

A-5, Current rating Aa3 (sf); previously on Nov 12, 2009 Confirmed
at Aa3 (sf)

Underlying Rating: Withdrawn (sf); previously on Mar 14, 2011
Downgraded to Ca (sf)

Financial Guarantor: Assured Guaranty Municipal Corp (Confirmed at
Aa3, Outlook Negative on Nov 12, 2009)

Issuer: ContiMortgage Home Equity Loan Trust 1995-02

A-5, Withdrawn (sf); previously on Mar 7, 2011 Downgraded to Caa3
(sf)

Underlying Rating: Withdrawn (sf); previously on Mar 7, 2011
Downgraded to Caa3 (sf)

Financial Guarantor: Financial Guaranty Insurance Company (Insured
Rating Withdrawn Mar 25, 2009)

Issuer: Delta Funding Home Equity Loan Trust 1995-2

S, Current rating B3 (sf) on Review for Possible Downgrade;
previously on Dec 19, 2011 B3 (sf) Placed Under Review for
Possible Downgrade

Underlying Rating: Withdrawn (sf); previously on Mar 7, 2011
Downgraded to Caa3 (sf)

Financial Guarantor: MBIA Insurance Corporation (B3 placed on
review for possible downgrade on Dec 19, 2011)

A-5, Current rating B3 (sf) on Review for Possible Downgrade;
previously on Dec 19, 2011 B3 (sf) Placed Under Review for
Possible Downgrade

Underlying Rating: Withdrawn (sf); previously on Mar 7, 2011
Downgraded to Caa3 (sf)

Financial Guarantor: MBIA Insurance Corporation (B3 placed on
review for possible downgrade on Dec 19, 2011)

Issuer: EquiVantage Home Equity Loan Trust 1996-2

A-4, Withdrawn (sf); previously on Mar 21, 2011 Downgraded to Baa1
(sf)

Underlying Rating: Withdrawn (sf); previously on Mar 21, 2011
Downgraded to Baa1 (sf)

Financial Guarantor: Financial Guaranty Insurance Company (Insured
Rating Withdrawn Mar 25, 2009)

Issuer: EquiVantage Home Equity Loan Trust 1996-3

A-3, Withdrawn (sf); previously on Jun 6, 2008 Upgraded to A1 (sf)

Underlying Rating: Withdrawn (sf); previously on May 23, 2008
Assigned A1 (sf)

Financial Guarantor: Financial Guaranty Insurance Company (Insured
Rating Withdrawn Mar 25, 2009)

Issuer: EquiVantage Home Equity Loan Trust 1996-4

A, Withdrawn (sf); previously on Mar 21, 2011 Downgraded to Baa3
(sf)

Underlying Rating: Withdrawn (sf); previously on Mar 21, 2011
Downgraded to Baa3 (sf)

Financial Guarantor: Financial Guaranty Insurance Company (Insured
Rating Withdrawn Mar 25, 2009)

Issuer: EquiVantage Home Equity Loan Trust 1997-1

A-3, Withdrawn (sf); previously on Mar 21, 2011 Confirmed at Baa1
(sf)

Underlying Rating: Withdrawn (sf); previously on Mar 21, 2011
Confirmed at Baa1 (sf)

Financial Guarantor: Financial Guaranty Insurance Company (Insured
Rating Withdrawn Mar 25, 2009)

A-4, Withdrawn (sf); previously on Mar 21, 2011 Confirmed at Baa1
(sf)

Underlying Rating: Withdrawn (sf); previously on Mar 21, 2011
Confirmed at Baa1 (sf)

Financial Guarantor: Financial Guaranty Insurance Company (Insured
Rating Withdrawn Mar 25, 2009)

A-5, Withdrawn (sf); previously on Mar 21, 2011 Confirmed at Baa1
(sf)

Underlying Rating: Withdrawn (sf); previously on Mar 21, 2011
Confirmed at Baa1 (sf)

Financial Guarantor: Financial Guaranty Insurance Company (Insured
Rating Withdrawn Mar 25, 2009)

Issuer: Lehman Home Equity Loan Trust 1998-1

X, Withdrawn (sf); previously on Feb 10, 1998 Assigned Aaa (sf)

R, Withdrawn (sf); previously on Feb 10, 1998 Assigned Aaa (sf)

A-1, Withdrawn (sf); previously on Feb 10, 1998 Assigned Aaa (sf)

RATINGS RATIONALE

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

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


COLTS 2007-1: S&P Raises Rating on Classes E Notes to 'B+'
----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class A, B, C, D, and E notes from CoLTS 2007-1 Ltd., a U.S.
collateralized loan obligation (CLO) transaction managed by Ares
Management LLC. "At the same time, we removed our ratings on the
class A, B, C, and D notes from CreditWatch, where we placed them
with positive implications on Nov. 14, 2011," S&P said.

"The upgrades reflect a paydown to the class A notes, as well
as improved performance we have observed in the transaction's
underlying asset portfolio since we last downgraded the classes
on Feb. 4, 2010. As of the Jan. 6, 2012 trustee report, the
transaction's asset portfolio had $27.55 million in defaulted
obligations and approximately $18.82 million in assets from
obligors rated in the 'CCC' range. This was an increase from
$21.88 million in defaulted obligations and a decrease from
approximately $57.35 million in assets from obligors rated in the
'CCC' range noted in the Dec. 4, 2009 trustee report, which we
used for our February 2010 rating actions. In addition, the class
A note balance decreased by $100.23 million over that same
time period, leaving them at approximately 61.45% of their
original balance," S&P said.

"We also observed an increase in the overcollateralization (O/C)
available to support the rated notes," S&P said. The trustee
reported the O/C ratios in the Jan. 6, 2012 monthly report:

    The A/B O/C ratio was 156.48%, compared with a reported ratio
    of 131.02% in December 2009;

    The C O/C ratio was 128.29%, compared with a reported ratio of
    114.76% in December 2009;

    The D O/C ratio was 117.10%, compared with a reported ratio of
    107.67% in December 2009; and

    The E O/C ratio was 107.28%, compared with a reported ratio of
    101.12% 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.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

              http://standardandpoorsdisclosure-17g7.com

Rating And Creditwatch Actions

CoLTS 2007-1 Ltd.
                        Rating
Class              To           From
A                  AAA (sf)     AA+ (sf)/Watch Pos
B                  AAA (sf)     AA- (sf)/Watch Pos
C                  AA- (sf)     BBB (sf)/Watch Pos
D                  BBB+ (sf)    B+ (sf)/Watch Pos
E                  B+ (sf)      CCC- (sf)


COLUMBUSNOVA CLO: S&P Affirms 'BB' Rating on Class E Notes
----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class B, C, and D notes from ColumbusNova CLO Ltd. 2007-I, a U.S.
collateralized loan obligation (CLO) transaction managed by
Collumbus Nova Credit Investment Management LLC. "At the same
time, we removed the lowered ratings from CreditWatch, where we
placed them with positive implications on Nov. 14, 2011. In
addition, we affirmed our ratings on the class A-1 and class E
notes from the same transaction," S&P said.

"The transaction is within its reinvestment period (ending May
2013) and its underlying portfolio's credit performance has
improved since our December 2009 rating actions, following the
application of our September 2009 corporate collateralized debt
obligation (CDO) criteria," S&P said.

"The trustee reports only one defaulted asset with a $860,486
par balance in the January 2012 monthly report, down from a
$19.56 million total par balance in the November 2009 report,
which we used for our analysis in our December 2009 rating
actions. Since that time, the transaction has sold many of its
defaulted assets at higher prices than the assumed recovery
rates," S&P said.

"In addition, the transaction is currently passing its class D
overcollateralization (O/C) test and its interest reinvestment
test, both which were failing in November 2009. The failure of the
class D O/C test in the past resulted in some paydowns to the
class A-1 notes. The interest reinvestment test is measured at the
class E O/C level. Failure during the reinvestment period diverts
available interest proceeds towards reinvestment until the test
passes. However, the amount that can be diverted is restricted
to 75% of the available interest proceeds. The interest
reinvestment test result is 104.70% as of January 2012, compared
to 100.87% in November 2009 (with a 102.40% minimum requirement),"
S&P said.

"In addition, the credit quality of the underlying asset portfolio
has also improved during this time. Based on the January 2012
monthly trustee report, the transaction has an $8.8 million
par balance of assets rated in the 'CCC' category, down from
$44.9 million in November 2009. As per the transaction documents,
the trustee haircuts the portion of 'CCC' rated collateral that is
in excess of the limit specified in the indenture. Due to the
lower level of 'CCC' assets, the trustee did not haircut the O/C
numerator in the January 2012 monthly report; the haircut was
$10.10 million in the November 2009 monthly report," S&P said.

The factors contributed to increased O/C ratios. The trustee
reported the O/C ratios in the January 2012 monthly report:

   The class A/B O/C ratio was 119.91%, compared with a reported
   ratio of 115.30% in November 2009;

   The class C O/C ratio was 113.49%, compared with a reported
   ratio of 109.28% in November 2009; and

   The class D O/C ratio test was 108.30%, compared with a
   reported ratio of 104.32% in November 2009 (with a 104.90%
   minimum requirement).

"We raised our ratings on the class B, C, and D notes due to an
increase in the credit support available to them and removed them
from CreditWatch. The affirmations on the class A-1 and E notes
reflect our opinion that the credit support available at the
current rating level is sufficient," 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.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

      http://standardandpoorsdisclosure-17g7.com

Rating And Creditwatch Actions

ColumbusNova CLO Ltd. 2007-I
                        Rating
Class              To           From
B                  AA (sf)      AA- (sf)/Watch Pos
C                  A (sf)       A- (sf)/Watch Pos
D                  BBB (sf)     BBB- (sf)/Watch Pos

Ratings Affirmed

ColumbusNova CLO Ltd. 2007-I
Class              Rating
A-1                AA+ (sf)
E                  BB (sf)


COMMODORE CDO: Fitch Affirms Junk Rating on Three Note Classes
--------------------------------------------------------------
Fitch Ratings has affirmed the ratings on three classes of notes
issued by Commodore CDO I, Ltd./Corp. (Commodore I):

  -- $9,662,192 Class A at 'BBsf', Outlook revised to Stable from
     Negative;
  -- $42,750,000 Class B at 'Csf';
  -- $17,550,000 Class C at 'Csf'.

This review was conducted under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Structured Finance Portfolio Credit Model (SF PCM) for
projecting future default levels for the underlying portfolio.
These default levels were then compared to the breakeven levels
generated by Fitch's cash flow model of the CDO under various
default timing and interest rate stress scenarios, as described in
the report 'Global Criteria for Cash Flow Analysis in CDOs'.
Fitch also considered additional qualitative factors in its
analysis, to conclude the rating affirmations for the rated notes.

Since the last rating action in February 2011, the credit
quality of the collateral has deteriorated with approximately
15.8% of the portfolio downgraded a weighted average of two
notches.  Approximately 90.1% of the portfolio has a Fitch derived
rating below investment grade and 56.8% is considered to be
defaulted by the trustee, compared to 84.7% and 46%, respectively,
at last review.

The class A notes are affirmed due to the deterioration of the
underlying collateral being offset by the amortization of the
notes.  The class has received approximately $4.9 million, or
33.8% of its previous balance, in principal redemptions since the
last review.  Although the notes are passing at rating hurdles
higher than its current rating in the cash flow model, Fitch
believes an affirmation better reflects the transaction's
performance given the concentration risks of the remaining
amortizing portfolio.

Fitch has revised the Outlook to Stable from Negative due to the
significant cushion in the cash flow modeling results that should
mitigate potential further deterioration in the portfolio.

The class B notes are receiving timely interest distributions,
since they precede the failing class B overcollateralization test
in the distribution waterfall.  However, the breakeven for this
class is below SF PCM's 'CCC' default level; therefore, Fitch
compared the class's credit enhancement level to the expected
losses from distressed and defaulted assets in the portfolio
(rated 'CCsf' or lower).  Since the expected losses exceed the
class's credit enhancement level, the class is affirmed at 'Csf',
indicating that default appears inevitable at or prior to
maturity.

The class C notes are currently undercollateralized, indicating
that default appears inevitable for the class at or prior to
maturity.

Commodore I is a cash flow structured finance collateralized debt
obligation (CDO) that closed on Feb. 26, 2002.  The portfolio is
monitored by Fischer Francis Trees & Watts, Inc. and is composed
of 51% asset-backed securities, 35.7% residential mortgage-backed
securities, and 13.3% commercial mortgage-backed securities from
1997 through 2005 vintage transactions.


CSAM FUNDING: S&P Says Asset Had $32.61MM in 'CCC' Rated Obligs
---------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
B-1 and B-2 notes from CSAM Funding I, a U.S. collateralized loan
obligation (CLO) transaction managed by CSFB Alternative Capital
Inc. "At the same time, we removed them from CreditWatch, where we
had placed them with positive implications on Nov. 14, 2011. We
also affirmed our ratings on the class A-1 and A-2 notes," S&P
saud.

"The upgrades reflect a paydown to the class A-1 and A-2 notes
and the improved performance we have observed in the deal's
underlying asset portfolio since our March 24, 2011, rating
actions. As of the Jan. 23, 2012, trustee report, the class A-1
and A-2 notes have paid down $3.39 million and $181.96 million.
The transaction's asset portfolio had $32.61 million in 'CCC'
category rated obligations and $23.18 million in defaulted
obligations as of Jan. 23, 2012, which is a decrease from
$50.17 million in 'CCC' category rated obligations and
$26.60 million in defaulted obligations noted in the Feb. 23,
2011 trustee report," S&P said.

"We affirmed our ratings on the class A-1 and A-2 notes to reflect
our view that the credit support available is commensurate with
the current ratings," S&P said.

"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.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

             http://standardandpoorsdisclosure-17g7.com

Rating And Creditwatch Actions

CSAM Funding I
                        Rating
Class              To           From
B-1                AA+ (sf)     A+ (sf)/Watch Pos
B-2                AA+ (sf)     A+ (sf)/Watch Pos

Ratings Affirmed

CSAM Funding I
Class              Rating
A-1                AAA (sf)
A-2                AAA (sf)


CRYSTAL RIVER: Moody's Affirms Rating of Cl. A Notes at 'C'
-----------------------------------------------------------
Moody's has affirmed the ratings of all classes of Notes issued by
Crystal River Resecuritization 2006-1, Ltd. The affirmations are
due to the key transaction parameters performing within levels
commensurate with the existing ratings levels. The rating action
is the result of Moody's on-going surveillance of commercial real
estate collateralized debt obligation (CRE CDO) and Re-Remic
transactions.

Moody's rating actions:

Cl. A, Affirmed at C (sf); previously on April 12, 2011 Downgraded
to C (sf)

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

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

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

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

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

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

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

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

RATINGS RATIONALE

Crystal River Resecuritization 2006-1, Ltd., is a static cash CRE
CDO transaction backed by a portfolio of commercial mortgage
backed securities (CMBS) (100.0% of the pool balance). As of the
January 23, 2012 Trustee report, the aggregate Note balance of
the transaction, including preferred shares, has decreased to
$388.4 million from $390.03 million at issuance, with the paydown
directed to the Class A Notes. An Event of Default occurred on
April 22, 2010 as a result of non-payment of interest to the Class
B Notes.

There are 54 assets with a par balance of $280.4 million (91.4% of
the current pool balance) that are considered Defaulted Securities
as of the January 23, 2012 Trustee report. While there have been
realized losses to date on the underlying collateral, Moody's does
expect significant losses to occur on the Defaulted Securities
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 9,479 compared to 9,523 at last review. The
distribution of current ratings and credit estimates is as
follows: B1-B3 (3.4% compared to 3.9% at last review), and Caa1-C
(96.6% compared to 96.1% at last review).

WAL acts to adjust the probability of default of the collateral in
the pool for time. Moody's modeled to a WAL of 7.7 years compared
to 7.4 years at last review.

WARR is the par-weighted average of the mean recovery values for
the collateral assets in the pool. Moody's modeled a fixed WARR of
0.2%, the same as that 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 99.9%, the same as that 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. However, in the light of the
performance indicators noted above, Moody's believes that it is
unlikely that the ratings announced are sensitive to further
change.

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 extent of the
slowdown in growth in the current macroeconomic environment and
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 in
recovery and improvements in the office sector continue, with
fundamentals in Gateway cities outperforming their suburban
counterparts. However, office demand is closely tied to
employment, where fundamentals remain weak, so significant
improvement may be delayed. Performance in the retail sector has
been mixed with on-going rent deflation and leasing challenges.
Across all property sectors, the availability of debt capital
continues to improve with monetary policy expected to remain
supportive and interest rate hikes postponed. Moody's central
global macroeconomic scenario reflects an overall downward
revision of forecasts since last quarter, amidst ongoing fiscal
consolidation efforts, household and banking sector deleveraging,
persistently high unemployment levels, and weak housing markets
that will continue to constrain growth.

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.


CTX CDO: Moody's Lowers Rating of Cl. A Notes to 'C'
----------------------------------------------------
Moody's has downgraded the ratings of one class of Notes and
affirmed the ratings of nine classes of Notes issued by CTX CDO I,
Ltd. due to increased realized losses on the underlying reference
collateral. The affirmations are due to the key transaction
parameters performing within levels commensurate with the existing
ratings levels. The rating action is the result of Moody's on-
going surveillance of commercial real estate collateralized debt
obligation (CRE CDO) and Re-remic transactions.

Moody's rating actions:

Cl. A, Downgraded to C (sf); previously on February 10, 2010
Downgraded to Ca (sf)

Cl. B, Affirmed at C (sf); previously on February 10, 2010
Downgraded to C (sf)

Cl. C, Affirmed at C (sf); previously on February 10, 2010
Downgraded to C (sf)

Cl. D, Affirmed at C (sf); previously on February 10, 2010
Downgraded to C (sf)

Cl. E, Affirmed at C (sf); previously on February 10, 2010
Downgraded to C (sf)

Cl. F, Affirmed at C (sf); previously on February 10, 2010
Downgraded to C (sf)

Cl. G, Affirmed at C (sf); previously on February 10, 2010
Downgraded to C (sf)

Cl. H, Affirmed at C (sf); previously on February 10, 2010
Downgraded to C (sf)

Cl. J, Affirmed at C (sf); previously on November 13, 2009
Downgraded to C (sf)

Cl. K, Affirmed at C (sf); previously on November 13, 2009
Downgraded to C (sf)

RATINGS RATIONALE

CTX CDO I Ltd. is a currently static hybrid CRE CDO transaction
backed by a portfolio of cash collateral (10% of the pool balance)
and synthetic credit default swaps (90%). The collateral and
reference obligations include commercial mortgage backed
securities (CMBS) (94.0% of the pool balance), CRE CDO (2.7%) and
real estate investment trust (REIT) debt (3.3%). The occurrence of
an Event of Default in February 2010 ceased the reinvestment
feature of this transaction (originally ending in June 2012). As
of the December 27, 2011 Note Valuation report, the aggregate
Note balance of the transaction, including the Super Senior
Swap and preferred shares, has decreased to $494.3 million from
$500.0 million at issuance, with the notional reduction on the
Super Senior Swap.

There are 33 reference collateral with a par balance of
$327.1 million (72.0% of the current pool balance) that are
considered Defaulted Securities as of the December 27, 2011 Note
Valuation report report. While there have been realized losses on
the underlying collateral, Moody's does expect significant losses
to occur on the Defaulted Securities 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 reference collateral. The bottom-dollar WARF is a measure of
the default probability within a collateral pool. Moody's modeled
a bottom-dollar WARF of 8,386 compared to 8,270 at last review.
The distribution of current ratings and credit estimates is as
follows: Baa1-Baa3 (3.3% compared to 3.0% at last review), Ba1-Ba3
(2.2% compared to 2.0% at last review), B1-B3 (3.3% compared to
4.0% at last review), and Caa1-C (91.2% compared to 91.0% at last
review).

WAL acts to adjust the probability of default of the reference
collateral in the pool for time. Moody's modeled to a WAL of 6.1
years compared to 5.5 yearsat last review.

WARR is the par-weighted average of the mean recovery values for
the reference collateral in the pool. Moody's modeled a fixed WARR
of 1.9% compared to 1.6% at last review.

MAC is a single factor that describes the pair-wise asset
correlation to the default distribution among the instruments
within the reference collateral (i.e. the measure of diversity).
Moody's modeled a MAC of 0.0% compared to 99.9% 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. However, in the light of the
performance indicators noted above, Moody's believes that it is
unlikely that the ratings announced are sensitive to further
change.

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 extent of the
slowdown in growth in the current macroeconomic environment and
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 in
recovery and improvements in the office sector continue, with
fundamentals in Gateway cities outperforming their suburban
counterparts. However, office demand is closely tied to
employment, where fundamentals remain weak, so significant
improvement may be delayed. Performance in the retail sector has
been mixed with on-going rent deflation and leasing challenges.
Across all property sectors, the availability of debt capital
continues to improve with monetary policy expected to remain
supportive and interest rate hikes postponed. Moody's central
global macroeconomic scenario reflects an overall downward
revision of forecasts since last quarter, amidst ongoing fiscal
consolidation efforts, household and banking sector deleveraging,
persistently high unemployment levels, and weak housing markets
that will continue to constrain growth.

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.


E*TRADE ABS: Fitch Affirms Rating on Five Note Classes
------------------------------------------------------
Fitch Ratings has affirmed five classes of notes issued by E*Trade
ABS CDO I, Ltd. (E*Trade I):

  -- $6,600,000 class A-2 notes at 'Bsf', Outlook Negative;
  -- $25,000,000 class B notes at 'Csf';
  -- $11,596,848 class C-1 notes at 'Csf';
  -- $4,695,725 class C-2 notes at 'Csf';
  -- $5,331,081 composite securities at 'Csf'.

This review was conducted under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Structured Finance Portfolio Credit Model (SF PCM) for
projecting future default levels for the underlying portfolio.
The transaction was not reviewed within a cash flow model
framework because the effect of structural features and principal
collections leaking to pay interest obligations is expected to be
minimal going forward.  Therefore, Fitch considered the SF PCM
output and additional qualitative factors into its analysis to
conclude the rating affirmations for the notes.

Since the last rating action in February 2011, the credit quality
of the collateral has deteriorated with approximately 29.5% of
the portfolio downgraded a weighted average of 3.7 notches.
Approximately 92.4% of the portfolio has a Fitch derived rating
below investment grade and 75% has a rating in the 'CCC' rating
category or lower, compared to 90.7% and 62.6%, respectively, at
last review.

The class A-2 notes have received $3 million in principal
repayment since the last review, which has increased credit
enhancement (CE) to offset the deterioration in the underlying
portfolio.  Comparing the class A-2 CE to the SF PCM rating loss
rate (RLR) output indicates the class has cushion to the 'Bsf'
rating stress. However, the class A-2 notes are affirmed because
the portfolio continues to deteriorate and is becoming
increasingly concentrated with 23 assets remaining.  Approximately
35% of the assets are not paying interest so principal is still
needed to cover a small portion of class B interest even after the
interest rate hedge expired in October 2011.  The amount is not
expected to be substantial, but will erode some of the CE cushion
to the 'Bsf' RLR.

The Outlook remains Negative for the class A-2 notes because the
portfolio is highly concentrated and susceptible to adverse
selection.

The class B and C notes and the composite securities are
undercollateralized by the par balance of the remaining portfolio,
indicating default remains inevitable for these classes at or
prior to maturity.

E*Trade I is a static structured finance collateralized debt
obligation (SF CDO) that closed on Sept. 26, 2002.  The initial
portfolio was selected by E*Trade Global Asset Management, Inc.
and is now monitored by Vertical Capital, LLC.  The portfolio is
comprised of residential mortgage-backed securities (52.4%), SF
CDOs (24.8%), commercial mortgage-backed securities (20.4%) and
commercial asset-backed securities (2.4%) from 2001 and 2002
vintage transactions.


FFCA SECURED: Fitch Downgrades Rating on Class E Notes to 'Dsf'
---------------------------------------------------------------
Fitch Ratings downgrades the class E notes in FFCA Secured
Franchise Loan Trust series 2000-1 to 'Dsf', as the bonds have
incurred a principal write-down.  The class E notes were
previously rated 'Csf', indicating that a default was imminent.

Today's action is limited to the class E notes only.  The
remaining notes in the transaction were not reviewed as part of
this current review.  Fitch will review the entire transaction
within the next six months.  The downgrade of the class E note to
'Dsf' was part of Fitch's ongoing surveillance process, and the
agency will continue to monitor the transaction for additional
defaults.


FIRST ALLIANCE: Moody's Downgrades Rating of Cl. A-3 Notes to 'B3'
------------------------------------------------------------------
Moody's has downgraded one tranche from one wrapped transaction
issued by First Alliance Mortgage. The securities are supported by
insurance policies issued by MBIA Insurance Corporation (B3 on
review for downgrade).

Moodys withdrew the underlying ratings that reflect the intrinsic
credit quality of the securities in the absence of the guarantee.
These securities were backed by a pool of mortgage loans with a
pool factor less than 5% and containing fewer than 40 loans.

The current rating on the securities reflects the guarantee
provided by MBIA Insurance Corporation.

Complete rating actions are:

Issuer: First Alliance Mortgage Loan Trust 1998-3

A-3, Downgraded to B3 (sf) and Placed Under Review for Possible
Downgrade; previously on Mar 7, 2011 Downgraded to Baa2 (sf)

Financial Guarantor: MBIA Insurance Corporation (B3 placed on
review for possible downgrade on Dec 19, 2011)

RATINGS RATIONALE

For securities insured by a financial guarantor, the rating on the
securities is the higher of (i) the guarantor's financial strength
rating and (ii) the current underlying rating (i.e., absent
consideration of the guaranty) on the security. As the underlying
ratings are withdrawn, the securities assume the MBIA Insurance
Corporation financial strength rating of B3, on review for
downgrade.

Moody's current RMBS surveillance methodologies apply to pools
with at least 40 loans and a pool factor of greater than 5%. As a
result, Moody's may withdraw its underlying rating when the pool
factor drops below 5% and the number of loans in the pool declines
to 40 loans or lower unless specific structural features allow for
a monitoring of the transaction (such as a credit enhancement
floor or pool insurance). Other methodologies and factors that may
have been considered for the rating(s) can also be found at
www.moodys.com in the Rating Methodologies sub-directory under the
Research & Ratings tab.

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


FIRST UNION-LEHMAN: S&P Cuts Rating on Class J Certs. to 'D'
------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on seven
classes of commercial mortgage pass-through certificates from
three U.S. commercial mortgage-backed securities (CMBS)
transactions due to interest shortfalls.

"The downgrades reflect current and potential interest
shortfalls. We lowered our ratings on six of these classes to 'D
(sf)' because we expect the accumulated interest shortfalls to
remain outstanding for the foreseeable future. The classes that we
downgraded to 'D (sf)' have had accumulated interest shortfalls
outstanding between three and seven months," S&P said. The
recurring interest shortfalls for the certificates are primarily
due to one or more of the factors:

   Appraisal subordinate entitlement reduction (ASER) amounts in
   effect for specially serviced loans;

   The lack of servicer advancing for loans where the servicer has
   made nonrecoverable advance declarations;

   Special servicing fees; and

   Interest rate reductions or deferrals resulting from loan
   modifications.

"Standard & Poor's analysis primarily considered the ASER amounts
based on appraisal reduction amounts (ARAs) calculated using
recent Member of the Appraisal Institute (MAI) appraisals. We also
considered servicer nonrecoverable advance declarations and
special servicing fees that are likely, in our view, to cause
recurring interest shortfalls," S&P said.

"The servicer implements ARAs and resulting ASER amounts in
accordance with each transaction's terms. Typically, these terms
call for the automatic implementation of an ARA equal to 25% of
the stated principal balance of a loan when a loan is 60 days past
due and an appraisal, or other valuation, is not available within
a specified timeframe. We primarily considered ASER amounts based
on ARAs calculated from MAI appraisals when deciding which classes
from the affected transactions to downgrade to 'D (sf)' because
ARAs based on a principal balance haircut are highly subject to
change, or even reversal, once the special servicer obtains the
MAI appraisals," S&P said.

Servicer nonrecoverable advance declarations can prompt shortfalls
due to a lack of debt service advancing, the recovery of
previously made advances deemed nonrecoverable, or the failure to
advance trust expenses when nonrecoverable declarations have been
determined. Trust expenses may include, but are not limited to,
property operating expenses, property taxes, insurance payments,
and legal expenses.

"We detail the seven downgraded classes from the three U.S. CMBS
transactions," S&P said.

             First Union-Lehman Bros. Commercial
                  Mortgage Trust Series 1997-C1

"We lowered our rating on the class J certificate from First
Union-Lehman Bros. Commercial Mortgage Trust's series 1997-C1 to
'D (sf)' to reflect accumulated interest shortfalls outstanding
for three months. The accumulated interest shortfalls resulted
primarily from reimbursement of the master servicer's advances
($157,457) and interest rate reduction from loan modification
($6,015) on the sole loan with the special servicer, The Quality
Inn Petaluma loan ($2.5 million, 4.0%). According to the master
servicer, Wells Fargo Bank N.A., it plans to recoup the remaining
outstanding advances on the loan ($43,350) in February 2012. As of
the Jan. 18, 2012 trustee remittance report, the reported monthly
interest shortfalls totaled $163,997 and the shortfalls affected
all of the classes subordinate to and including class H," S&P
said.

                 JPMorgan Chase Commercial Mortgage
                  Securities Corp. Series 2001-A

"We lowered our ratings on the class D, E, and F certificates from
JPMorgan Chase Commercial Mortgage Securities Corp.'s series 2001-
A. We downgraded classes E and F to 'D (sf)' and class D to 'CCC-
(sf)' to reflect accumulated interest shortfalls outstanding
primarily due to interest not advanced ($137,552) on the sole
remaining asset in the trust and with the special servicer, the
Southgate USA asset ($20.4 million), according to the Jan. 17,
2012, trustee remittance report. Classes E and F have accumulated
interest shortfalls outstanding for seven months, while class D
shorted interest for three months. If class D continues to
experience interest shortfalls in the near term, we may lower the
rating to 'D (sf)'," S&P said.

           PNC Mortgage Acceptance Corp. Series 2000-C2

"We lowered our ratings on the class J, K, and L certificates to
'D (sf)' from PNC Mortgage Acceptance Corp.'s series 2000-C2 to
reflect accumulated interest shortfalls outstanding between six
and seven months. The interest shortfalls were primarily from ASER
amounts related to four ($30.7 million, 27.7%) of the six assets
($41.3 million, 37.3%) that are currently with the special
servicer (C-III Asset Management LLC),  special servicing fees
($8,909), and interest rate reduction due to loan modifications
($49,207). As of the Jan. 12, 2012, trustee remittance report,
ARAs totaling $11.7 million were in effect for four assets and the
total reported monthly ASER amount on these assets was $85,858.
The reported monthly interest shortfalls totaled $250,544 and have
affected all of the classes subordinate to and including class J,"
S&P said.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

              http://standardandpoorsdisclosure-17g7.com

Ratings Lowered

First Union-Lehman Bros. Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 1997-C1

                              Credit        Reported
          Rating         enhancement   interest shortfalls ($)
Class  To        From            (%)     Current  Accumulated
J      D (sf)    CCC+ (sf)         0      76,151      228,453

JPMorgan Chase Commercial Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2001-A

                              Credit        Reported
          Rating         enhancement   interest shortfalls ($)
Class  To         From            (%)     Current  Accumulated
D      CCC- (sf)  BB (sf)       68.91      40,782      122,346
E      D (sf)     B- (sf)       52.16      22,760      161,589
F      D (sf)     CCC- (sf)     27.03      34,140      242,383

PNC Mortgage Acceptance Corp.
Commercial mortgage pass-through certificates series 2000-C2

                              Credit        Reported
          Rating         enhancement   interest shortfalls ($)
Class  To         From            (%)     Current  Accumulated
J      D (sf)     BB (sf)      35.86        44,434     809,931
K      D (sf)     B- (sf)      28.58        41,835     251,008
L      D (sf)     CCC- (sf)    21.30        41,835     269,874


FOREST CREEK: S&P Affirms Rating on Class B-2L Notes at 'CCC-'
--------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-4L and B-1L notes from Forest Creek CLO Ltd., a collateralized
loan obligation (CLO) transaction managed by Deerfield Capital
Management LLC, and removed them from CreditWatch with positive
implications. "At the same time, we affirmed our ratings on the
class A-1LB, A-2L, A-3L, and B-2L notes and removed the rating on
the B-2L notes from CreditWatch positive," S&P said.

"The upgrades reflect an improvement in the credit profile of the
assets and the overcollateralization available to support the
notes since our February 2011 rating actions, when we raised our
ratings on five of the notes. As of the Jan. 3, 2012, trustee
report, the transaction held $4.4 million in defaulted assets.
This was down from the $9.4 million in defaulted assets noted in
the January 2011 trustee report, which we referenced for our
February 2011 rating actions. Also, as of Jan. 2012, the
transaction held $9.7 million in assets from underlying obligors
with ratings in the 'CCC' range, compared with $22.0 million in
January 2011," S&P said.

Since January 2011, the class A-1LA notes have paid down
in full. The A-1LB notes have paid down to $5.9 million from
$32.7 million and the A-2L notes have paid down to $10.6 million
from $16.2 million.  The improvement in asset credit quality and
the significant paydowns to the class A-1L and A-2L notes have
benefited the transaction's overcollateralization (O/C) ratios,
which all have increased since January 2011:

    The senior class A O/C ratio is 228.8%, compared with 135.8%;
    The class A O/C ratio is 149.8%, compared with 116.8%;
    The class B-1L O/C ratio is 113.0%, compared with 103.3%; and
    The class B-2L O/C ratio is 101.7%, compared with 98.2%.

"Despite the increase in O/C ratios, the class B-2L O/C test
continues to fail as of January 2012. The B-1L and B-2L notes
maintain accrued deferred interest balances since deferred
interest is paid after the B-2L O/C test in the priority of
payments," S&P said.

"We affirmed our ratings on the class A-1LB, A-2L, A-3L, and B-2L
notes to reflect the availability of credit support at the current
rating levels," S&P said.

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

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

          http://standardandpoorsdisclosure-17g7.com

Rating And Creditwatch Actions

Forest Creek CLO Ltd.
                              Rating
Class                   To           From
A-4L                    AAA (sf)     AA- (sf)/Watch Pos
B-1L                    BB (sf)      CCC+ (sf)/Watch Pos
B-2L                    CCC- (sf)    CCC- (sf)/Watch Pos

Ratings Affirmed

Forest Creek CLO Ltd.
Class                   Rating
A-1LB                   AAA (sf)
A-2L                    AAA (sf)
A-3L                    AAA (sf)


FRANKLIN AUTO: S&P Raises Rating on Class D Notes to 'BB+'
----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
B, C, and D notes from Franklin Auto Trust 2008-A.

"The rating actions reflect the transaction's collateral
performance to date, our views regarding future collateral
performance including tail-end risk, the transaction's structure,
and the credit enhancement available. In addition, our analysis
incorporated secondary credit factors such as credit stability,
payment priorities under certain scenarios, and sector- and
issuer-specific analysis," S&P said.

"The upgrades reflect our analysis of existing loss coverage
levels and account for other factors such as our current economic
forecast, our auto sector outlook, and issuer-specific issues.
Additional qualitative factors considered are tail-end/small pool-
factor risk and the potential for increased credit volatility,
which can arise late in a transaction's life. Examples of tail-end
risks include the potential for a pool's obligor base to become
less diversified and the possibility for increased concentration
of modified and/or extended loans that may lead to
disproportionately higher losses than expected. In our view, with
all these factors considered, the creditworthiness of the notes
remains consistent with the raised ratings," S&P said.

"The pool's performance has improved as observed by the shrinking
net loss-to-liquidation rates since our last full review on Sept.
16, 2010, when we lowered our rating on the class D notes to 'BB
(sf)' from 'BBB- (sf)' and removed it from CreditWatch negative,"
S&P said

"Since our last review, lifetime net loss-to-liquidation rates and
trailing 12 month net loss-to-liquidation rates have decelerated
more than we expected," S&P said.

"As a result, Standard & Poor's lowered its lifetime cumulative
net loss expectation for the series from its previous level.
However, the series has performed worse than our initial
expectations," S&P said.

Table 1
Net Loss-To-Liquidation Rate Comparison (%)
As of the distribution month
            September 2010        January 2012
         Lifetime   12-month   Lifetime   12-month
         loss-to-   loss-to-   loss-to-   loss-to-
Series  liq. rate  liq. rate  liq. rate  liq. rate
2008-A      11.64      11.18      10.35       5.39

Table 2
Collateral Performance (%)
As of the January 2012 distribution month
               Pool    60+ day   Current
Series  Mo.  factor     delinq.      CNL
2008-A   44   17.74       1.96      8.51
CNL--Cumulative net loss.

Table 3
CNL Expectations (%)
                      Initial      Former     Revised
              Pool   lifetime    lifetime    lifetime
Series  Mo. factor   CNL exp.  CNL exp.(i)   CNL exp.
2008-A   44  17.74  6.00-6.20  10.75-11.25  9.30-9.60
(i)CNLs were previously revised on Sept. 16, 2010. CNL--Cumulative
net loss.

"The issuer initially structured series 2008-A as a sequential
principal payment structure with credit enhancement consisting of
subordination for the higher-rated tranches, a letter of credit
(LOC) commitment, and a spread account. The transaction documents
state that the spread account can build by trapping monthly excess
spread, and, combined with the LOC commitment, reach a specified
combined credit enhancement target as shown in table 4. The spread
account is subject to a 0.50% floor, and the LOC is subject to a
1.00% floor, with a 1.50% combined floor of the initial collateral
balance," S&P said.

Table 4
Spread Account And LOC/Cash-Funded Levels
           Combined     Combined     Current LOC/
        enhancement  enhancement      cash funded
             target        floor          account
              (% of        (% of            (% of
Series     current)     initial)         current)
2008-A        10.25         1.50            10.25
LOC--Letter of credit.

"As of the January 2012 distribution month, the issuer had already
replaced the LOC with a cash-funded account by drawing on the LOC
amount available (as permitted by the transaction documents). The
issuer replaced the LOC after we lowered our short-term rating on
the LOC provider," S&P said.

"Series 2008-A's credit enhancement is currently at its target
amount of 10.25% as a percent of its current collateral balance
and will also be subject to its credit enhancement floor amount of
1.50% of the initial collateral balance according to its
transaction documents (see table 5 each class' hard credit
support)," S&P said.

Table 5
Hard Credit Support (%)
                                         Current
                   Total hard         total hard
               credit support  credit support(i)
Series  Class  at issuance(i)     (% of current)
2008-A  B               24.01             100.51
2008-A  C               16.26              56.84
2008-A  D                8.00              10.25

(i)Consists of a spread account and LOC/cash-funded account, as
well as subordination for the higher tranches, and excludes excess
spread that can also provide additional enhancement. LOC--Letter
of credit.

"We incorporated our cash flow analysis in our review of this
transaction, which included current and historical performance to
estimate future performance. Our various cash flow scenarios
included forward-looking assumptions on recoveries, timing of
losses, and voluntary absolute prepayment speeds that we believe
are appropriate given each transaction's current performance. The
results demonstrated, in our view, that all of the classes from
this transaction have adequate credit enhancement at their
respective raised rating levels," S&P said.

"We will continue to monitor the performance of all of the
outstanding transactions to ensure that the credit enhancement
remains sufficient, in our view, to cover our revised cumulative
net loss expectations under our stress scenarios for each of the
rated classes," S&P said.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

          http://standardandpoorsdisclosure-17g7.com

Ratings Raised

Franklin Auto Trust
                        Rating
Series   Class    To              From
2008-A   B        AAA (sf)        AA+ (sf)
2008-A   C        AA+ (sf)        A (sf)
2008-A   D        BB+ (sf)        BB (sf)


GCCFC 2006-GG7: Moody's Reviews Ba1 Rating for Possible Downgrade
-----------------------------------------------------------------
Moody's Investors Service (Moody's) placed nine classes of
Greenwich Capital Commercial Funding Corp. Commercial Mortgage
Trust, Series 2006-GG7 on review for possible downgrade:

Cl. A-M, Aa3 (sf) Placed Under Review for Possible Downgrade;
previously on April 15, 2010 Downgraded to Aa3 (sf)

Cl. A-J, Baa3 (sf) Placed Under Review for Possible Downgrade;
previously on April 15, 2010 Downgraded to Baa3 (sf)

Cl. B, Ba1 (sf) Placed Under Review for Possible Downgrade;
previously on April 15, 2010 Downgraded to Ba1 (sf)

Cl. C, Ba3 (sf) Placed Under Review for Possible Downgrade;
previously on April 15, 2010 Downgraded to Ba3 (sf)

Cl. D, B2 (sf) Placed Under Review for Possible Downgrade;
previously on April 15, 2010 Downgraded to B2 (sf)

Cl. E, B3 (sf) Placed Under Review for Possible Downgrade;
previously on April 15, 2010 Downgraded to B3 (sf)

Cl. F, Caa2 (sf) Placed Under Review for Possible Downgrade;
previously on March 2, 2011 Downgraded to Caa2 (sf)

Cl. G, Caa3 (sf) Placed Under Review for Possible Downgrade;
previously on March 2, 2011 Downgraded to Caa3 (sf)

Cl. H, Ca (sf) Placed Under Review for Possible Downgrade;
previously on April 15, 2010 Downgraded to Ca (sf)

RATINGS RATIONALE

The classes were placed on review due to higher expected losses
for the pool resulting from actual and anticipated losses from
specially serviced and troubled 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 March 2, 2011.

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

DEAL AND PERFORMANCE SUMMARY

As of the January 12, 2012 distribution date, the
transaction's aggregate certificate balance has decreased by 15%
to $3.09 billion from $3.61 billion at securitization. The
Certificates are collateralized by 119 mortgage loans ranging in
size from less than 1% to 8% of the pool, with the top ten loans
representing 49% of the pool.

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

Fourteen loans have been liquidated from the pool, resulting in an
aggregate realized loss of $131.7 million (42% loss severity).
Fifteen loans, representing 8% of the pool, are currently in
special servicing. The specially serviced loans are secured by a
mix of multifamily, retail, office, industrial, and hotel property
types.

Moody's review will focus on potential losses from specially
serviced and troubled loans and the performance of the overall
pool.


GE COMMERCIAL 2006-C1: S&P Lowers Rating on Class F Certs. to 'D'
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on five
classes of commercial mortgage pass-through certificates from
GE Commercial Mortgage Corp. Series 2006-C1 Trust, a U.S.
commercial mortgage-backed securities (CMBS) transaction.
"Concurrently, we raised our rating on class A-M and affirmed
our ratings on seven other classes from the same transaction,"
S&P said.

"Our rating actions follow our analysis of the credit
characteristics of the collateral remaining in the pool,
the deal structure, and the liquidity available to the
trust. The downgrades reflect credit support erosion that we
anticipate will occur upon the eventual resolution of the 10
assets ($209.6 million, 14.1%) that are currently with the special
servicer, as well as two loans that we determined to be credit-
impaired ($17.0 million, 1.1%). We also considered the monthly
interest shortfalls that are affecting the trust. We lowered our
rating on the class F certificate to 'D (sf)' because we believe
that the accumulated interest shortfalls will remain outstanding
for the foreseeable future," S&P said.

"The upgrade of class A-M reflects credit enhancement and
liquidity levels that provide adequate support through various
stress scenarios," S&P said.

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

"Using servicer-provided financial information, we calculated an
adjusted debt service coverage (DSC) of 1.81x and a loan-to-value
(LTV) ratio of 87.3%. We further stressed the loans' cash flows
under our 'AAA' scenario to yield a weighted average DSC of 1.13x
and an LTV ratio of 115.2%. The implied defaults and loss severity
under the 'AAA' scenario were 60.3% and 31.8%. The DSC and LTV
calculations exclude the 10 assets ($209.6 million, 14.1%) that
are with the special servicer, two loans that we determined to
be credit-impaired ($17.0 million, 1.1%), and one defeased loan
($1.6 million, 0.1%). We separately estimated losses for the
specially serviced and credit-impaired assets and included them in
our 'AAA' scenario implied default and loss severity figures," S&P
said.

"As of the Jan. 10, 2012 trustee remittance report, the trust
experienced monthly interest shortfalls totaling $325,569
primarily related to appraisal subordinate entitlement reduction
(ASER) amounts of $223,537, and special servicing and workout
fees of $77,112. The interest shortfalls affected all classes
subordinate to and including class F. Class F experienced
cumulative interest shortfalls of two months, and we expect
these interest shortfalls to continue for the foreseeable
future. Consequently, we downgraded class F to 'D (sf)'," S&P
said.

                     Credit Considerations

As of the Jan. 10, 2012 trustee remittance report, 10 assets
($209.6 million, 14.1%) in the pool were with the special
servicer, LNR Partners LLC (LNR).

The reported payment status of the specially serviced assets as of
the most recent trustee remittance report is as follows: four are
real estate owned (REO) ($124.0 million, 8.3%), one is in
foreclosure ($6.7 million, 0.5%), and five are 90-plus-days
delinquent ($78.9 million, 5.3%). Appraisal reduction amounts
(ARAs) totalling $56.6 million are in effect against seven of the
10 specially serviced assets. Details of the three largest
specially serviced assets, all of which are top 10 assets, are as
set forth.

The Beyman Multifamily Portfolio III asset ($82.1 million, 5.5%),
the third-largest asset in the pool, comprises three cross-
collateralized, cross-defaulted multifamily properties totaling
850 units in Charlotte, N.C., Memphis, Tenn., and Cordova, Tenn.
The total reported exposure was $91.6 million. The loan was
transferred to the special servicer on Jan. 7, 2010, due to
imminent default. Two of the properties became REO on May 11,
2011, and one became REO on July 1, 2011. LNR stated that it plans
to sell the properties through a March 2012 auction. The current
reported occupancy was 78.1% for the Memphis property, 89.5% for
the Cordova property, and 90.0% for the Charlotte property. An ARA
of $25.6 million is in effect against the asset. "We expect a
moderate loss upon the eventual resolution of this asset," S&P
said.

The 33 Washington loan ($54.2 million, 3.6%) is the fourth-largest
asset in the pool. The total reported exposure was $56.1 million.
The loan is secured by a 410,613-sq.-ft. office building in
Newark, N.J. The loan has a reported payment status of 90-plus-
days delinquent and was transferred to the special servicer on
Nov. 18, 2011, due to imminent default. LNR stated that it is
currently evaluating an updated appraisal and workout strategy on
the loan. The reported DSC and occupancy were 0.95x and 47.1% as
of June 30, 2011. An ARA of $13.6 million is in effect against the
loan. S&P expects a moderate loss upon the eventual resolution of
this loan.

The Atlanta Mall Area Portfolio asset ($28.2 million, 1.9%), the
eighth-largest asset in the pool, consists of two cross-
collateralized and cross-defaulted retail centers containing seven
buildings with a total of 158,297 sq. ft. Five buildings are in
Lithonia, Ga. and two are in Buford, Ga. The total reported
exposure was $28.6 million. The loan was transferred to the
special servicer on Jan. 20, 2010, due to imminent default, and
the properties became REO on Feb. 1, 2011. LNR stated that the two
buildings in Buford, Ga. were sold at an auction in September
2011, and LNR is marketing the remaining five properties for sale.
The most recent reported DSC was 0.41x as of Dec. 31, 2010. "We
expect a significant loss upon the eventual resolution of the
asset," S&P said.

"The seven remaining assets with the special servicer have
individual balances that represent less than 0.9% of the total
pooled trust balance. ARAs totalling $17.4 million are in effect
against five of these assets. We estimated losses for the seven
remaining assets, arriving at a weighted-average loss severity of
41.5%," S&P said.

"In addition to the specially serviced assets, we determined two
loans to be credit-impaired ($17.0 million, 1.1%) due to their
delinquent payment statuses. As a result, we view both loans to be
at an increased risk of default and loss. The larger of the two
loans, the Copans Commerce Depot loan ($13.7 million, 0.9%), has a
reported 30-days delinquent payment status. The loan is secured by
a 194,806-sq.-ft. office/warehouse property in Pompano Beach, Fla.
The loan is on the master servicer's watchlist due to a low
reported DSC, which was 0.47x for the nine months ended Sept. 30,
2011. The smaller of the two credit-impaired loans, the Yuciapa
Self Storage loan ($3.3 million, 0.2%), has a reported 90-plus
days payment status. The loan is secured by a 53,165-sq.-ft. self
storage facility in Yucaipa, Calif. The loan is on the master
servicer's watchlist due to low reported DSC, which was 0.85x
for the nine months ended Sept. 30, 2011," S&P said.

                         Transaction Summary

As of the Jan. 10, 2012 trustee remittance report, the collateral
pool had an aggregate trust balance of $1.48 billion, down from
$1.61 billion at issuance. The pool comprises 133 loans and four
REO assets, down from 145 loans at issuance. The master servicer,
Wells Fargo Bank N.A., provided financial information for 92.5% of
the loans in the pool (by balance), most of which reflected data
for full-year 2010 and the nine months ended Sept. 30, 2011.

"We calculated a weighted average DSC of 1.74x for the loans in
the pool based on the servicer-reported figures. Our adjusted DSC
and LTV were 1.81x and 87.3%. Our adjusted figures exclude the 10
assets ($209.6 million, 14.1%) with the special servicer, as
well as two loans that we determined to be credit-impaired
($17.0 million, 1.1%) and one ($1.6 million, 0.1%) defeased loan.
To date, the transaction has experienced $6.0 million in principal
losses from three assets. Eighteen loans ($138.1 million, 9.3%)
in the pool are on the master servicer's watchlist, including
one of the top 10 assets. Twenty-three loans ($167.1 million,
11.3%) have a reported DSC of less than 1.10x, 19 of which
($139.9 million, 9.4%) have a reported DSC of less than 1.00x,"
S&P said.

                         Summary of Top 10 Assets

"The top 10 assets have an aggregate outstanding pooled balance
of $679.7 million (45.8%). Using servicer-reported numbers, we
calculated a weighted average DSC of 2.31x for seven of the top 10
assets. The remaining three top 10 assets ($164.5 million, 11.0%)
are with the special servicer. Our adjusted DSC and LTV were 2.28x
and 74.5% for seven of the top 10 assets, excluding the three
specially serviced assets. One loan, the Level 3 Communications
loan, the seventh-largest asset in the pool, is on the master
servicer's watchlist due to its Oct. 1, 2010, anticipated
repayment date. The loan has an Oct. 1, 2015, final maturity date.
The loan has a trust balance of $41.4 million (2.8%) and a whole-
loan balance of $66.4 million. The loan is secured by a 776,058-
sq.-ft. suburban office building in Broomfield, Colo. According
to the Sept. 30, 2011 rent roll, a single tenant, Level 3
Communications Inc., occupies 100% of the office property. The
tenant's lease expiration is Sept. 30, 2020. The reported DSC
was 3.30x for the nine months ended Sept. 30, 2011," S&P said.

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

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

         http://standardandpoorsdisclosure-17g7.com

Ratings Lowered

GE Commercial Mortgage Corp. Series 2006-C1 Trust
Commercial mortgage pass-through certificates
             Rating
Class     To          From         Credit enhancement (%)
B         BB (sf)    BB+ (sf)                       8.94
C         B+ (sf)    BB (sf)                        8.00
D         CCC (sf)   BB- (sf)                       6.37
E         CCC- (sf)  CCC+ (sf)                      5.42
F         D (sf)     CCC- (sf)                      4.47

Rating Raised

GE Commercial Mortgage Corp. Series 2006-C1 Trust
Commercial mortgage pass-through certificates
             Rating
Class     To          From         Credit enhancement (%)
A-M       AA- (sf)    A (sf)                       21.27

Ratings Affirmed

GE Commercial Mortgage Corp. Series 2006-C1 Trust
Commercial mortgage pass-through certificates
Class     Rating    Credit enhancement (%)
A-2       AAA (sf)                   32.11
A-3       AAA (sf)                   32.11
A-AB      AAA (sf)                   32.11
A-4       AAA (sf)                   32.11
A-1A      AAA (sf)                   32.11
A-J       BBB- (sf)                  11.38
X-W       AAA (sf)                     N/A

N/A -- Not applicable.


GMAC COMMERCIAL: Fitch Affirms Junk Rating on 4 Security Classes
----------------------------------------------------------------
Fitch Ratings has affirmed seven classes of GMAC Commercial
Mortgage Securities, Inc.'s commercial mortgage pass-through
certificates, series 1998-C1 and downgraded one class.

The downgrade to the class H notes reflects an increase in Fitch
expected losses in light of updated values on specially serviced
assets.  Fitch modeled losses of 38.6% of the remaining
transaction.  There are currently two specially-serviced loans
(58.53%) in the pool.

As of the January 2012 distribution date, the pool's aggregate
principal balance has been paid down by 86.2% to $197.1 million
from $1.4 billion at issuance.  Three loans (7.5%) are defeased.
Currently, interest shortfalls are affecting classes G through N.

The largest contributor to loss (57% of pool balance) is the SLP
loan which is secured by 44 healthcare properties in Texas.  A
buyer was identified and engaged but a deal was never completed.
The maturity of the loan has been extended to Aug. 1, 2012. Fitch
expects losses upon liquidation of the loan.

The next largest contributor to losses (1.58%) is a 52,826 square
foot office property located in Rocky Mount, NC.  The special
servicer continues to pursue foreclosure of the property.  Fitch
expects losses upon liquidation of the loan.

Fitch downgrades this class and assigns the Recovery Estimate
(RE):

  -- $25.6 million class H to 'Csf; RE 85%' from 'Bsf'.

Fitch affirms these classes and revises the Outlooks and REs:

  -- $34.8 million class E at 'AAAsf'; Outlook Stable;
  -- $43.1 million class F at 'A-sf'; Outlook to Negative from
     Stable;
  -- $32.4 million class G at 'BBsf'; Outlook to Negative from
     Stable;
  -- $14.4 million class J at 'Csf'; RE to 0% from 90%;
  -- $25.2 million class K at 'Csf'; RE 0%;
  -- $14.4 million class L at 'Csf'; RE 0%;
  -- $10.8 million class M at 'Csf'; RE 0%.

Classes A-1, A-2, B, C and D have paid in full.
Fitch does not rate class N.

The ratings on the Class X notes were previously withdrawn.


GOLDEN KNIGHT: S&P Raises Rating on Class E Notes to 'B+'
---------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
D and E notes from Golden Knight II CLO Ltd., a collateralized
loan obligation (CLO) transaction managed by Lord Abbett & Co. "We
also affirmed our ratings on the class A, B, and C notes. At the
same time, we removed all the ratings from CreditWatch, where we
placed them with positive implications on Feb. 10, 2012," S&P
said.

"The upgrades reflect the improved performance we have observed in
the deal's underlying asset portfolio since our December 2009
rating actions. According to the Jan. 9, 2012 trustee report, the
transaction's asset portfolio did not hold any defaulted assets,
down from the $13.7 million noted in the October 2009 trustee
report. Additionally, the collateral pool consisted of
approximately $6.2 million in assets from obligors rated in the
'CCC' category in January 2012, down from $16.3 million in October
2009," S&P said.

"We affirmed our ratings on the class A, B, and C notes to reflect
the sufficient credit support available at the classes' current
rating levels," 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.

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

            http://standardandpoorsdisclosure-17g7.com

Rating And Creditwatch Actions

Golden Knight II CLO Ltd.
                         Rating
Class                To           From
A                    AA+ (sf)     AA+ (sf)/Watch Pos
B                    AA- (sf)     AA- (sf)/Watch Pos
C                    A- (sf)      A- (sf)/Watch Pos
D                    BBB (sf)     BB+ (sf)/Watch Pos
E                    B+ (sf)      CCC- (sf)/Watch Pos


GOLDENTREE IV: S&P Affirms Rating on Class D Notes at 'BB'
----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on two
classes of notes from Goldentree Loan Opportunities IV Ltd., a
collateralized loan obligation (CLO) transaction managed by
GoldenTree Asset Management L.P., and removed one of them from
CreditWatch positive. "At the same time, we affirmed our ratings
on six classes and removed three of them from CreditWatch
positive," S&P said.

"The upgrades reflect improvements in the overcollateralization
(O/C) available to support the rated notes and in the credit
quality of the transaction's underlying asset portfolio since
we lowered our ratings on the transaction in December 2009. As
of the December 2011 trustee report, the class A O/C ratio had
increased to 137.89% from 133.08% in September 2009, and the
balance of defaulted assets had declined to $7.86 million from
$16.62 million," S&P said.

"The rating affirmations on the notes reflect the availability of
sufficient credit support at the current rating levels. We will
continue to review our ratings on the notes and assess whether, in
our view, the ratings remain consistent with the credit
enhancement available," S&P said.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

              http://standardandpoorsdisclosure-17g7.com

Rating Actions

Goldentree Loan Opportunities IV Ltd.

                   Rating
Class        To               From
A-1cS        AAA (sf)         AA+ (sf)
C            BBB (sf)         BBB- (sf)/Watch Pos

Ratings Affirmed And Removed From Creditwatch

Goldentree Loan Opportunities IV Ltd.

                   Rating
Class        To               From
A-2          AA (sf)          AA (sf)/Watch Pos
B            A (sf)           A (sf)/Watch Pos
D            BB (sf)          BB (sf)/Watch Pos

Ratings Affirmed

Goldentree Loan Opportunities IV Ltd.

Class        Rating
A-1a         AA+ (sf)
A-1b         AA+ (sf)
A-1cJ        AA+ (sf)


GOLDMAN SACHS: Fitch Puts Rating on Two Note Classes at Low-B
-------------------------------------------------------------
Fitch Ratings has assigned these ratings and Outlooks to Goldman
Sachs Mortgage Company's GS Mortgage Securities Trust 2012-GC6:

  -- $65,525,000 class A-1 'AAAsf'; Outlook Stable;
  -- $82,190,000 class A-2 'AAAsf'; Outlook Stable;
  -- $570,467,000 class A-3 'AAAsf'; Outlook Stable;
  -- $89,850,000 class A-AB 'AAAsf'; Outlook Stable;
  -- $927,794,000*a class X-A 'AAAsf'; Outlook Stable;
  -- $119,762,000a class A-S 'AAAsf'; Outlook Stable;
  -- $63,489,000a class B 'AA-sf'; Outlook Stable;
  -- $44,730,000a class C 'A-sf'; Outlook Stable;
  -- $49 ,059,000a class D 'BBB-sf'; Outlook Stable;
  -- $21,644,000a class E 'BBsf'; Outlook Stable;
  -- $11,543,000a class F 'Bsf'; Outlook Stable.

*Notional amount and interest only.
Privately placed pursuant to Rule 144A.

Fitch does not rate the $226,538,646 interest-only class X-B or
the $36,073,646 class G.


GREYROCK CDO: S&P Raises Rating on Class B-2L Notes to 'BB+'
------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the seven
classes of notes from Greyrock CDO Ltd., a collateralized loan
obligation (CLO) transaction backed by U.S. corporate loans
managed by Aladdin Capital Management LLC.

"The upgrades reflect an increase in the overall credit support
available to the rated notes since we lowered our ratings on the
transaction in November 2009," S&P said.

"Since the October 2009 monthly report, which we used for our
November 2009 rating actions, the amount of defaulted assets
in the transaction's portfolio decreased from $25.4 million to
$6.85 million as of the January 2012 trustee report, which we used
in our current analysis. The January trustee report also noted
$23.67 million in assets from obligors rated 'CCC+' or below, down
from $40.54 million in October 2009," S&P said.

"Standard & Poor's will continue to review whether, in our view,
the ratings currently assigned to the notes remain consistent with
the credit enhancement available to support them and take rating
actions as we deem necessary," S&P said.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

              http://standardandpoorsdisclosure-17g7.com

Rating Actions

Greyrock CDO Ltd.
              Rating
Class     To           From
A-1L      AAA (sf)     AA+ (sf)
A-2L      AA+ (sf)     A+ (sf)
A-3L      A+ (sf)      BBB+ (sf)
B-1F      BBB+ (sf)    BB (sf)
B-1L      BBB+ (sf)    BB (sf)
B-2F      BB+ (sf)     CCC+ (sf)
B-2L      BB+ (sf)     CCC+ (sf)


GSMS 2006-GG8: Moody's Affirms Rating of Cl. A-J Notes at 'Ba1'
---------------------------------------------------------------
Moody's Investors Service (Moody's) affirmed the ratings of 23
classes of Goldman Sachs Mortgage Securities Corporation II,
Commercial Mortgage Pass-Through Certificates, Series 2006-GG8:

Cl. A-2, Affirmed at Aaa (sf); previously on Nov 8, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-3, Affirmed at Aaa (sf); previously on Nov 8, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-AB, Affirmed at Aaa (sf); previously on Nov 8, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on Nov 8, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-1A, Affirmed at Aaa (sf); previously on Nov 8, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-M, Affirmed at Aa3 (sf); previously on Mar 25, 2010
Downgraded to Aa3 (sf)

Cl. A-J, Affirmed at Ba1 (sf); previously on Mar 10, 2011
Downgraded to Ba1 (sf)

Cl. B, Affirmed at Ba2 (sf); previously on Mar 10, 2011 Downgraded
to Ba2 (sf)

Cl. C, Affirmed at B2 (sf); previously on Mar 10, 2011 Downgraded
to B2 (sf)

Cl. D, Affirmed at Caa1 (sf); previously on Mar 10, 2011
Downgraded to Caa1 (sf)

Cl. E, Affirmed at Caa2 (sf); previously on Mar 10, 2011
Downgraded to Caa2 (sf)

Cl. F, Affirmed at Caa3 (sf); previously on Mar 25, 2010
Downgraded to Caa3 (sf)

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

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

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

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

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

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

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

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

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

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

Cl. X, Affirmed at Aaa (sf); previously on Nov 8, 2006 Definitive
Rating Assigned Aaa (sf)

RATINGS RATIONALE

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

Moody's rating action reflects a cumulative base expected loss of
11.3% of the current balance. At last review, Moody's cumulative
base expected loss was 10.3%. 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 extent of the
slowdown in growth in the current macroeconomic environment and
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 in
recovery and improvements in the office sector continue, with
fundamentals in Gateway cities outperforming their suburban
counterparts. However, office demand is closely tied to
employment, where fundamentals remain weak, so significant
improvement may be delayed. Performance in the retail sector has
been mixed with on-going rent deflation and leasing challenges.
Across all property sectors, the availability of debt capital
continues to improve with monetary policy expected to remain
supportive and interest rate hikes postponed. Moody's central
global macroeconomic scenario reflects an overall downward
revision of forecasts since last quarter , amidst ongoing fiscal
consolidation efforts, household and banking sector deleveraging,
persistently high unemployment levels, and weak housing markets
that will continue to constrain growth.

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

Moody's noted that on November 22, 2011, it released a Request for
Comment, in which the rating agency has requested market feedback
on potential changes to its rating methodology for Interest-Only
Securities. If the revised methodology is implemented as proposed
the rating on J Goldman Sachs Mortgage Securities Corporation II,
Commercial Mortgage Pass-Through Certificates, Series 2006-GG8
Class X may be negatively affected. Please refer to Moody's
request for Comment, titled "Proposal Changing the Global Rating
Methodology for Structured Finance Interest-Only Securities," for
further details regarding the implications of the proposed
methodology change on Moody's rating.

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 45 compared to 41 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 March 10, 2011.

DEAL PERFORMANCE

As of the January 12, 2012 distribution date, the
transaction's aggregate certificate balance has decreased by 19%
to $3.43 billion from $4.24 billion at securitization. The
Certificates are collateralized by 142 mortgage loans ranging in
size from less than 1% to 6% of the pool, with the top ten loans
representing 39% of the pool.

Thirty-two loans, representing 31% 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 a
realized loss of $59.4 million (53% loss severity overall).
Currently twenty loans, representing 11% of the pool, are in
special servicing. The largest specially serviced loan is the
Ariel Preferred Retail Portfolio Loan ($89.9 million -- 2.6% of
the pool), which is secured by portfolio of six outlet centers
totaling 1.34 million square feet (SF) located in suburban markets
in California, Nevada, Minnesota, Missouri, Georgia and Michigan.
The loan was transferred to special servicing in June 2009 due to
imminent monetary default. The special servicer is currently in
the process of foreclosing on all of the assets in the portfolio.

The remaining 19 specially serviced properties are secured by a
mix of property types. Moody's estimates an aggregate $164.0
million loss for the specially serviced loans (43% expected loss
on average).

Moody's has assumed a high default probability for 14 poorly
performing loans representing 6% of the pool and has estimated an
aggregate $91.0 million loss (42% expected loss based on a 50%
probability default) from these troubled loans. A majority of this
loss is attributable to expected losses based on the modifications
of the Pointe South Mountain Resort Loan and Paradise Esplanade
Loan.

Moody's was provided with full year 2010 operating results for 88%
of the pool. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 120% compared to 119% at Moody's
prior review. Moody's net cash flow reflects a weighted average
haircut of 9% to the most recently available net operating income.
Moody's value reflects a weighted average capitalization rate of
9.7%.

Excluding special serviced and troubled loans, Moody's actual and
stressed DSCRs are 1.23X and 0.90X, respectively, compared to
1.30X and 0.93X 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 28% of the pool. The largest
conduit loan is the 222 South Riverside Plaza Loan ($200.8 million
-- 5.8% of the pool), which is secured by two Class A office
buildings with a combined total of 1.2 million SF located in
Chicago, Illinois. The largest tenants include Fifth Third Bank
(15% of the NRA; lease expiration August 2024) and Deutsche
Investment Management (10% of the NRA; lease expiration December
2016). The property was 84% leased as of December 2011 compared to
93% at the last full review. The U.S. Postal Service vacated at
lease maturity in 2011 causing a majority of the recent occupancy
loss at the property. Moody's LTV and stressed DSCR are 126% and
0.78X, respectively, compared to 90% and 1.08X at last full
review.

The second largest loan is the Arizona Grand Resort Loan, formerly
known as Pointe South Mountain Resort Loan ($190.0 million -- 5.5%
of the pool), which is secured by a 640-unit full-service hotel
located in Phoenix, Arizona. The loan had previously been in
special servicing but was modified and subsequently returned to
the master servicer. Under the loan modification agreement, the
original loan was split into an A Note ($100.0 million) and a B
Note ($90.0 million), both of which remain in the trust. The A
Note will remain interest only at 5.5% until March 2012 (at which
point it will amortize on a 360 month schedule at a 6.68% interest
rate through maturity), while the B Note will bear no interest and
is payable in full at maturity. Due to the decline in the hotel
market in Phoenix, Arizona, Moody's has assumed a high default
probability on this loan. Moody's LTV and stressed DSCR for the A
note are 156% and 0.78X, respectively, the same as at last review.

The third largest loan is the 1441 Broadway Loan ($183.0 million -
- 5.3% of the pool), which is secured by a 470,000 SF 33-story
multi-tenant office building located in the Garment District of
New York, NY. The largest tenants include Liz Claiborne (59% of
the NRA; lease expiration in December 2012) and Jones Denim
Management (14% of the NRA; lease expiration in May 2017). The
property was 99% leased as of September 2011 compared to 96% at
the prior review. The loan is currently on the master servicer's
watchlist due to Liz Claiborne's upcoming lease maturity. Per the
servicer, the borrower and Liz Claiborne are in negotiations
regarding a lease renewal. Moody's LTV and stressed DSCR are 137%
and 0.71X, respectively, compared to 122% and 0.79X at last full
review.


GSMS 2012-GC6: Moody's Assigns 'Ba2' Rating to Cl. E Notes
----------------------------------------------------------
Moody's Investors Service has assigned ratings to eleven classes
of CMBS securities, issued by GS Mortgage Securities Trust
Commercial Mortgage Pass-Through Certificates, Series 2012-GC6.

Cl. A-1, Definitive Rating Assigned Aaa (sf)

Cl. A-2, Definitive Rating Assigned Aaa (sf)

Cl. A-3, Definitive Rating Assigned Aaa (sf)

Cl. A-AB, Definitive Rating Assigned Aaa (sf)

Cl. X-A, Definitive Rating Assigned Aaa (sf)

Cl. A-S, Definitive Rating Assigned Aaa (sf)

Cl. B, Definitive Rating Assigned Aa3 (sf)

Cl. C, Definitive Rating Assigned A3 (sf)

Cl. D, Definitive Rating Assigned Baa3 (sf)

Cl. E, Definitive Rating Assigned Ba2 (sf)

Cl. F, Definitive Rating Assigned B2 (sf)

RATINGS RATIONALE

The Certificates are collateralized by 80 fixed rate loans secured
by 127 properties. The ratings are based on the collateral and the
structure of the transaction.

Moody's CMBS ratings methodology combines both commercial real
estate and structured finance analysis. Based on commercial real
estate analysis, Moody's determines the credit quality of each
mortgage loan and calculates an expected loss on a loan specific
basis. Under structured finance, the credit enhancement for each
certificate typically depends on the expected frequency, severity,
and timing of future losses. Moody's also considers a range of
qualitative issues as well as the transaction's structural and
legal aspects.

The credit risk of loans is determined primarily by two factors:
1) Moody's assessment of the probability of default, which is
largely driven by each loan's DSCR, and 2) Moody's assessment of
the severity of loss upon a default, which is largely driven by
each loan's LTV ratio.

The Moody's Actual DSCR of 1.51X is greater than the 2007
conduit/fusion transaction average of 1.31X. The Moody's Stressed
DSCR of 1.15X is greater than the 2007 conduit/fusion transaction
average of 0.92X.

Moody's Trust LTV ratio of 91.6% is lower than the 2007
conduit/fusion transaction average of 110.6%. Moody's Total LTV
ratio, (inclusive of subordinated debt) of 91.7% is also
considered when analyzing various stress scenarios for the rated
debt.

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
(includes cross collateralized and cross defaulted loans)
Herfindahl Index is 26.2. The transaction's loan level diversity
is at the higher end of the band of Herfindahl scores found in
most multi-borrower transactions issued since 2009. With respect
to property level diversity, the pool's property level Herfindahl
Index is 34.8. The transaction's property diversity profile is
higher than the indices calculated in most multi-borrower
transactions issued since 2009.

Moody's also grades properties on a scale of 1 to 5 (best to
worst) and considers those grades when assessing the likelihood of
debt payment. The factors considered include property age, quality
of construction, location, market, and tenancy. The pool's
weighted average property quality grade is 2.4, which is higher
than the indices calculated in most multi-borrower transactions
since 2009.

The transaction benefits from one loan, representing approximately
8.7% of the pool balance in aggregate, assigned an investment
grade credit estimate. Loans assigned investment grade credit
estimates are not expected to contribute any loss to a transaction
in low stress scenarios, but are expected to contribute minimal
amounts of loss in high stress scenarios.

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

On November 22, 2011, Moody's released a Request for Comment, in
which the rating agency has requested market feedback on potential
changes to its rating methodology for interest-only securities. If
the revised methodology is implemented as proposed, the rating on
GSMS 2012-GC6 Class X-A should not be affected. Please refer to
Moody's Request for Comment, titled "Proposal Changing the Global
Rating Methodology for Structured Finance Interest-Only
Securities," for further details regarding the implications of the
proposed methodology changes on Moody's ratings.

Moody's analysis employs the excel-based CMBS Conduit Model v2.60
which derives credit enhancement levels based on an aggregation of
adjusted loan level proceeds derived from Moody's loan level DSCR
and LTV ratios. Major adjustments to determining proceeds include
loan structure, property type, sponsorship and diversity.

The V Score for this transaction is assessed as Low/Medium, the
same as the V score assigned to the U.S. Conduit and CMBS sector.
This reflects typical volatility with respect to the critical
assumptions used in the rating process as well as an average
disclosure of securitization collateral and ongoing performance.

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

Moody's Parameter Sensitivities: If Moody's value of the
collateral used in determining the initial rating were decreased
by 5%, 14%, or 23%, the model-indicated rating for the currently
rated junior Aaa class would be Aa1, Aa2, A1, respectively.
Parameter Sensitivities are not intended to measure how the rating
of the security might migrate over time; rather they are designed
to provide a quantitative calculation of how the initial rating
might change if key input parameters used in the initial rating
process differed. The analysis assumes that the deal has not aged.
Parameter Sensitivities only reflect the ratings impact of each
scenario from a quantitative/model-indicated standpoint.
Qualitative factors are also taken into consideration in the
ratings process, so the actual ratings that would be assigned in
each case could vary from the information presented in the
Parameter Sensitivity analysis.


HALCYON 2005-2: Moody's Lowers Rating of Cl. A Notes to 'B3'
------------------------------------------------------------
Moody's has downgraded the ratings of two classes of Notes issued
by Halcyon 2005-2, Ltd., due to deterioration in the underlying
reference obligations as evidenced by the Moody's key credit
parameters. The affirmation is 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 Synthetic) transactions.

Moody's rating actions:

Cl. A, Downgraded to B3 (sf); previously on March 23, 2011
Downgraded to Ba3 (sf)

Cl. B, Downgraded to Caa2 (sf); previously on March 23, 2011
Downgraded to Caa1 (sf)

Cl. C, Affirmed at Caa3 (sf); previously on March 23, 2011
Downgraded to Caa3 (sf)

RATINGS RATIONALE

Halcyon 2005-2, Ltd., is a static synthetic CRE CDO transaction
backed by a reference portfolio of commercial mortgage backed
securities (CMBS) (100.0% of the pool). As of January 25,
2012, the aggregate rated Notes balance of the transaction
is EUR64.2 million and $15.8 million, the same as at issuance.

Moody's has identified these 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 reference obligations. The bottom-dollar WARF is a measure
of the default probability within a collateral pool. Moody's
modeled a bottom-dollar WARF of 260 compared to 238 at last
review. The distribution of current ratings and credit estimates
is as follows: Aaa-Aa3 (20.0% compared to 26.7% at last review),
A1-A3 (43.3% compared to 46.7% at last review), Baa1-Baa3 (33.3%
compared to 23.3% at last review), Ba1-Ba3 (0.0% compared to 0.0%
at last review), B1-B3 (3.3% compared to 3.3% at last review), and
Caa1-C (0.0% compared to 0.0% at last review).

WAL acts to adjust the probability of default of the reference
obligations in the pool for time. Moody's modeled to a WAL of 3.3
years compared to 4.0 at last review.

WARR is the par-weighted average of the mean recovery values for
the reference obligations in the pool. Moody's modeled a fixed
WARR of 44% compared to 46% at last review.

MAC is a single factor that describes the pair-wise asset
correlation to the default distribution among the instruments
within the reference obligations (i.e. the measure of diversity).
Moody's modeled a MAC of 41% compared to 48% 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.

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. In general, the rated Notes are particularly
sensitive to rating changes within the reference pool. Holding all
other key parameters static, changing the current ratings and
credit estimates of the reference obligations by one notch
downward or by one notch upward affects the model results by
approximately 0 to 2 notches downward and 1 to 2 notches upward,
respectively.

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

Primary sources of assumption uncertainty are the extent of the
slowdown in growth in the current macroeconomic environment and
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 in
recovery and improvements in the office sector continue, with
fundamentals in Gateway cities outperforming their suburban
counterparts. However, office demand is closely tied to
employment, where fundamentals remain weak, so significant
improvement may be delayed. Performance in the retail sector has
been mixed with on-going rent deflation and leasing challenges.
Across all property sectors, the availability of debt capital
continues to improve with monetary policy expected to remain
supportive and interest rate hikes postponed. Moody's central
global macroeconomic scenario reflects an overall downward
revision of forecasts since last quarter, amidst ongoing fiscal
consolidation efforts, household and banking sector deleveraging,
persistently high unemployment levels, and weak housing markets
that will continue to constrain growth.

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


INDEPENDENCE I: Fitch Lowers Rating on $50 Mil. Note to 'Dsf'
-------------------------------------------------------------
Fitch Ratings has upgraded one and downgraded one class of notes
issued by Independence I CDO, Ltd./Inc. (Independence I):

  -- $35,193,159 class A notes upgraded to 'BBBsf' from 'BBsf';
     Outlook revised to Stable from Negative;

  -- $50,000,000 class B notes downgraded to 'Dsf' from 'Csf'.

This review was conducted under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Structured Finance Portfolio Credit Model (SF PCM) for
projecting future default levels for the underlying portfolio.
These default levels were then compared to the breakeven levels
generated by Fitch's cash flow model of the CDO under various
default timing and interest rate stress scenarios, as described in
the report 'Global Criteria for Cash Flow Analysis in CDOs'.
Fitch also considered additional qualitative factors into its
analysis to conclude the rating affirmations for the rated notes.

Since the last rating action in March 2011, the credit quality of
the collateral has deteriorated with approximately 29.9% of the
portfolio downgraded a weighted average of 3.8 notches.
Approximately 77.2% of the portfolio has a Fitch derived rating
below investment grade and 53.8% is considered to be defaulted by
the trustee, compared to 59.7% and 41.9%, respectively, at last
review.

The required majority of the controlling class voted to
accelerate the maturity of the transaction in October 2011,
which subsequently diverts interest and principal collections
to redeem the class A notes following class A accrued interest
distributions.  The class A notes are upgraded due to continued
amortization offsetting the deterioration of the underlying
collateral.  Since the last review, the class A notes have
received approximately $24.1 million, or 40.6% of its previous
balance, in principal repayment.  Additionally, the class has
significantly less sensitivity to future interest rate changes,
as class B accrued interest is no longer senior to class A
redemption.

Fitch has revised the Outlook to Stable to reflect the cushion in
the cash flow modeling results to mitigate potential further
negative migration in the portfolio.

Due to the acceleration, the class B notes did not receive their
interest due starting on the Oct. 31, 2011 monthly distribution
date. The class B notes are non-deferrable and are downgraded to
'Dsf'.

Independence I is a cash flow structured finance collateralized
debt obligation (SF CDO) that closed on Dec. 18, 2000.  The
portfolio is monitored by Declaration Management & Research LLC
and is composed of commercial mortgage-backed securities (29%),
residential mortgage-backed securities (27.1%), commercial asset-
backed securities (23.6%), SF CDOs (13.1%) and corporate CDOs
(7.2%) from 1996 through 2003 vintage transactions.


INFINITI SPC: S&P Downgrades Rating on Class B Notes to 'D'
-----------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on the class
B notes from Infiniti SPC Ltd.'s Aladdin Synthetic CDO 2006-2 to
'D (sf)' from 'CCC- (sf)'.

"The downgrade follows a number of credit events within the
underlying pool of corporate reference entities. We received final
valuations on the credit events in the underlying portfolio, which
indicated that losses in the portfolio had caused the notes to
incur partial principal losses," S&P said.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

          http://standardandpoorsdisclosure-17g7.com

Rating Lowered

Infiniti SPC Ltd.
Aladdin Synthetic CDO 2006-2
               Rating
Class       To               From
B           D (sf)           CCC- (sf)


INFINITI SPC: S&P Lowers Rating on Notes to 'D'
-----------------------------------------------
Standard & Poor's Ratings Services lowered its rating on the notes
class from Infiniti SPC Ltd.'s Kenmore Street Synthetic CDO 2006-2
to 'D (sf)' from 'CCC- (sf)'.

"The downgrade follows a number of credit events within the
underlying pool of corporate reference entities. We received final
valuations on the credit events in the underlying portfolio, which
indicated that losses in the portfolio had caused the notes to
incur partial principal losses," S&P said.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

          http://standardandpoorsdisclosure-17g7.com

Rating Lowered

Infiniti SPC Ltd.
Kenmore Street Synthetic CDO 2006-2
               Rating
Class       To               From
Notes       D (sf)           CCC- (sf)


JP MORGAN: Fitch Puts 'B-sf' $164 Million Certs. on Watch Negative
------------------------------------------------------------------
Fitch Ratings has placed two classes of commercial mortgage pass-
through certificates from of JP Morgan Chase Commercial Mortgage
Securities Corp series 2006-CIBC15 on Rating Watch Negative.

Classes A-M and A-J have been placed on Rating Watch Negative
based on an increase in Fitch's preliminary estimate of expected
losses for the 20 specially serviced loans, four of which are
within the top 15 loans in the pool.

Fitch expects to resolve the Rating Watch status within the next
several months following a complete review of the transaction
including updated performance data for performing loans.  Fitch
expects classes A-M and A-J could be downgraded several categories
given limited subordination of the remaining classes to offset
losses.

Fitch has placed these classes on Rating Watch Negative:

  -- $211.8 million class A-M 'Asf';
  -- $164.2 million class A-J 'B-sf'.


JP MORGAN: Fitch Puts Three Note Class's Rating on Watch Negative
-----------------------------------------------------------------
Fitch Ratings has placed five classes of J.P. Morgan Chase
Commercial Mortgage Securities Corp., series 2006-CIBC17,
commercial mortgage pass-through certificates on Rating Watch
Negative.

Classes A-M through D have been placed on Rating Watch Negative
based on an increase in Fitch's preliminary estimate of expected
losses for the 20 specially serviced loans, three of which are
within the top 15 loans in the pool.  The largest contributor to
expected losses is the Bank of America Plaza loan.  The loan is
secured by a 1.25 million square foot (sf) office property located
in downtown Atlanta, GA.

Fitch expects to resolve the Rating Watch status within the next
several months following a complete review of the transaction
including updated performance data for performing loans.
Following its review, the classes placed on Rating Watch Negative
may be downgraded several categories.

Fitch has placed these classes on Rating Watch Negative:

  -- $253.7 million class A-M 'AAAsf';
  -- $202.9 million class A-J 'BBsf';
  -- $44.4 million class B 'Bsf';
  -- $19 million class C 'B-sf';
  -- $34.9 million class D 'B-sf'.


JPMORGAN 1997-C5: S&P Affirms 'CCC-' Rating on Class G Certificate
------------------------------------------------------------------
Standard & Poor's Ratings Services raised its rating to 'AAA (sf)'
from 'BBB- (sf)' on the class F commercial mortgage pass-through
certificate from JPMorgan Commercial Mortgage Finance Corp.'s
series 1997-C5, a U.S. commercial mortgage-backed securities
(CMBS) transaction. "In addition, we affirmed our 'CCC- (sf)'
rating on class G from the same transaction," S&P said.

"Our rating actions reflect our analysis of the transaction
including a review of the credit characteristics of the remaining
collateral, the transaction structure, and the liquidity available
to the trust," S&P said.

"The upgrade of class F reflects increased credit enhancement
levels, which was 63.8% according to the Jan. 17, 2012 trustee
remittance report, as well as overall strong credit metrics. We
calculated a weighted average debt service coverage (DSC) of 1.82x
for the remaining loans in the trust based on servicer-reported
figures. Our adjusted DSC and loan-to-value (LTV) ratio, based on
servicer-provided financial information, were 1.63x and 39.4%,
which exclude the three loans ($3.4 million, 6.0%) with the
special servicer. In addition, excluding the three loans with the
special servicer, nine of the remaining loans ($12.7 million,
22.1%) are fully amortizing loans that have maturities ranging
between 2017 and 2022," S&P said.

"The affirmed 'CCC- (sf)' rating on class G reflects subordination
(0.6%, according to the January 2012 trustee remittance report)
and liquidity support levels that are consistent with the current
rating," S&P said.

                         Transaction Summary

"As of the Jan. 17, 2012, trustee remittance report, the
collateral pool balance was $57.3 million, which is 5.6% of the
balance at issuance. The pool includes 18 loans, down from 269
loans at issuance. The master servicer, Midland Loan Services
(Midland), provided financial information for 98.2% of the loans
in the pool, 82.2% of which was full-year 2010 data and the
reminder was partial-year 2011 and 2010 data," S&P said.

The transaction has experienced $25.5 million in principal
losses from 19 assets to date. Five loans ($12.6 million, 21.9%)
in the trust are on the master servicer's watchlist. Three loans
($2.0 million, 3.5%) have a reported DSC of less than 1.00x.

                      Summary of Top 10 Loans

"The top 10 loans have an aggregate outstanding balance of
$51.0 million (89.0%). Using servicer-reported numbers, we
calculated a weighted average DSC of 1.91x for nine of the top 10
loans. The remaining loan ($1.4 million, 2.4%) is with the special
servicer. Our adjusted DSC and LTV ratio for nine of the top 10
loans, excluding the specially serviced loan are 1.68x and 38.7%.
Two of the top 10 loans ($10.6 million, 18.5%) are on the master
servicer's watchlist. Midland indicated that the third-largest
loan, the Crosstown Plaza Shopping Center loan ($9.2 million,
16.1%), which is on its watchlist due to Jan. 1, 2012 maturity,
was paid off in full after the January 2012 trustee remittance
report. The remaining loan, the Poore Brothers loan ($1.4 million,
2.4%), is secured by a 60,033-sq.-ft. industrial property in
Goodyear, Ariz. The loan is on Midland's watchlist because the
lease for the property's sole tenant expired June 30, 2010. The
master servicer indicated that the tenant is on a month-to-month
basis. The reported DSC was 2.29x for the nine months ended
Sept. 30, 2011," S&P said.

                       Credit Considerations

As of the Jan. 17, 2012 trustee remittance report, three loans
($3.4 million, 6.0%) in the pool were with the special servicer,
Berkadia Commercial Mortgage LLC (Berkadia). The three specially
serviced loans had a reported 90-plus-days delinquent payment
status as of the January 2012 trustee remittance report.
Details on the three specially serviced loans, one of which
is a top 10 loan, are as set forth.

The Whitney Estates loan ($1.4 million, 2.4%) is the largest
loan with the special servicer and the ninth-largest loan in
the pool. The loan, which has a total reported trust exposure of
$1.5 million, is secured by a 42-unit multifamily property in
Elmhurst, N.Y. The loan was transferred to the special servicer
on May 25, 2011, due to payment default. According to Berkadia,
there is also an unauthorized second mortgage for $900,000 on the
property from 2007 and several federal and state tax liens against
the loan sponsor. Berkadia indicated that it is currently working
to cure a document deficiency and will initiate foreclosure once
the deficiency is cured. The reported DSC for year-end 2010 was
2.12x and occupancy was 100% according to the borrower's June 2011
operating statement. "Based on a November 2011 appraisal value, we
expect a minimal loss, if any, upon the eventual resolution of
this loan," S&P said.

"The Ranch Auto Center loan ($1.0 million, 1.8%) has a total
reported trust exposure of $1.2 million and was transferred to the
special servicer on Aug. 9, 2011, for payment default. The loan is
secured by a 34,324-sq.-ft. automotive center in Scottsdale, Ariz.
The reported DSC for year-end 2010 was 1.28x and occupancy was
100% according to the borrower's June 2011 operating statement.
Berkadia stated that it is pursuing foreclosure. Based on a
September 2011 appraisal value, we expect a minimal loss, if any,
upon the eventual resolution of this loan," S&P said.

"The Days Inn - Orangeburg loan ($1.0 million, 1.8%) has a total
reported trust exposure of $1.4 million and was transferred to the
special servicer on July 1, 2009, for imminent payment default.
The loan is secured by a 75-unit lodging property in Orangeburg,
S.C. Berkadia indicated that although the borrower is seeking
financing to pay off the loan, it has initiated foreclosure
proceeding. No recent financial information was available for this
loan. Based on a June 2011 appraisal value, we expect a minimal
loss, if any, upon the eventual resolution of this loan," S&P
said.

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

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

             http://standardandpoorsdisclosure-17g7.com


KLEROS REAL: S&P Lowers Rating on Class A-1 Note From 'CC' to 'D'
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered Kleros Real Estate CDO
IV Ltd.'s class A-1 note rating from 'CC (sf)' to 'D (sf)' and
lowered its rating on Saturn Ventures 2005-1's class A-1 note to
'CCC- (sf)' from 'BB+ (sf)'.  Both transactions are collateralized
debt obligations (CDO) of mezzanine structured finance securities.

"These rating actions reflect our criteria for ratings on CDO
transactions that have triggered an EOD and is subject to
liquidation," S&P said.

"Kleros Real Estate CDO IV Ltd. has triggered an event of default
(EOD) and completed the liquidation of the portfolio collateral on
Feb. 9, 2012, after the majority of noteholders voted for
liquidation on Nov. 1, 2011. We have received notice from the
trustee stating that the liquidation of the portfolio assets is
complete and that the available proceeds were insufficient to pay
the noteholders in full. Therefore, we downgraded class A-1 notes
to 'D (sf)'," S&P said.

"Saturn Ventures 2005-1 Ltd. triggered an event of default (EOD)
on March 2, 2010, after which, the controlling noteholders
subsequently voted to liquidate the collateral. We lowered the
rating on the A-1 notes to 'CCC- (sf)' reflecting the uncertainty
as to whether the remaining collateral, including the recovery
value of defaulted securities, is sufficient to pay the
noteholders in full," S&P said.

             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 Represent ations,
warranties and enforcement mechanisms in issuances of similar
securities. The Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Reports
included in this credit rating report are available at:

            http://standardandpoorsdisclosure-17g7.com

Ratings Lowered

Kleros Real Estate CDO IV Ltd.
            Rating
Class     To       From
A-1      D(sf)    CC(sf)

Saturn Ventures 2005-1 Ltd.
            Rating
Class     To        From
A-1       CCC-(sf)  BB+(sf)

Other Ratings Outstanding

Kleros Real Estate CDO IV Ltd.
Class              Rating
A-2                D (sf)
A-3                D (sf)
A-4                D (sf)
B                  D (sf)
C                  D (sf)
D                  D (sf)
E                  D (sf)

Saturn Ventures 2005-1 Ltd.
Class              Rating
A-2                D (sf)
A-3                D (sf)
B                  D (sf)
C                  D (sf)


LAKESIDE CDO: Fitch Affirms Junk Rating on Four Note Classes
------------------------------------------------------------
Fitch Ratings has affirmed the ratings on four classes of notes
issued by Lakeside CDO II, Ltd./Inc. (Lakeside II):

  -- $435,050,425 class A-1 notes at 'CCCsf';
  -- $279,900,000 class A-2 notes at 'Csf';
  -- $15,373,080 class B notes at 'Csf';
  -- $15,069,341 class C notes at 'Csf'.

This review was conducted under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Structured Finance Portfolio Credit Model (SF PCM) for
projecting future default levels for the underlying portfolio.
This transaction has not been analyzed within a cash flow model
framework, as the impact of the structural features and principal
leakage to service the collateralized debt obligation (CDO)
liabilities was determined to be minimal in the context of the CDO
ratings.

Since the last rating action in February 2011, the credit quality
of the collateral has deteriorated, with 49.3% downgraded a
weighted average of 4.1 notches.  Approximately 68.9% of the
current portfolio has a Fitch derived rating below investment
grade and 43.1% has a rating of 'CCC' or lower, compared to 54.2%
and 33.7%, respectively, at last review.

The affirmation of the class A-1 notes is due to the deterioration
of the underlying collateral being offset by the amortization
of the notes.  The class A-1 notes have received approximately
$102.3 million, or 19% of its previous balance, in principal
redemptions since the last review.  The credit enhancement level
of the notes passes the 'CCC' PCM RLR with sufficient cushion to
withstand the expected amount of enhancement erosion from
principal collections continuously being used to cover a portion
of class A-2 accrued interest.

The class A-2, class B and class C notes are currently
undercollateralized, indicating that default continues to appear
inevitable at or prior to maturity for each of the classes.

Lakeside II is a cash flow structured finance collateralized debt
obligation (SF CDO) that closed on March 31, 2004.  The portfolio
is monitored by Vanderbilt Capital Advisors LLC and is composed of
61.7% residential mortgage-backed securities, 28.6% SF CDOs and
9.7% trust preferred CDOs, from 2001 through 2004 vintage
transactions.


LANDMARK IX: S&P Raises Rating on Class E Notes From 'B' to 'BB'
----------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class A-2, B, C, D, and E notes from Landmark IX CDO Ltd., a
U.S. collateralized loan obligation (CLO) transaction managed by
Aladdin Capital Management LLC. "At the same time, we affirmed our
rating on the class A-1 notes," S&P said.

"The upgrades reflect the improved performance we have observed
in the transaction's underlying asset portfolio since we last
downgraded the classes on Dec. 2, 2009. As of the Jan. 4,
2012 trustee report, the transaction's asset portfolio had
$1.23 million in defaulted obligations and approximately
$21.61 million in assets from obligors rated in the 'CCC' range.
This was down from $25.68 million in defaulted obligations and
approximately $60.23 million in assets from obligors rated in the
'CCC' range noted in the Oct. 2, 2009 trustee report, which we
used for our December 2009 rating actions," S&P said.

"We affirmed our rating on the class A-1 notes to reflect our
belief that the credit support available is commensurate with the
current rating," S&P said.

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.

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

           http://standardandpoorsdisclosure-17g7.com

Rating Actions

Landmark IX CDO Ltd.
                        Rating
Class              To           From
A-2                AA+ (sf)     AA (sf)
B                  AA (sf)      A+ (sf)
C                  A- (sf)       BBB (sf)
D                  BBB (sf)     BB+ (sf)
E                  BB (sf)      B (sf)

Rating Affirmed

Landmark IX CDO Ltd.
Class              Rating
A-1                AAA (sf)


LB-UBS 2006-C3: S&P Lowers Ratings on 2 Classes of Cert. to 'CCC-'
------------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on three
classes and lowered its ratings on four other classes of
commercial mortgage pass-through certificates from LB-UBS
Commercial Mortgage Trust 2006-C3, a U.S. commercial mortgage-
backed securities (CMBS) transaction. "In addition, we affirmed
our ratings on 10 other classes and four nonpooled 'NBT'-raked
classes from the same transaction," S&P said.

"Our rating actions follow our analysis of the credit
characteristics of the collateral remaining in the pool, the deal
structure, and the liquidity available to the trust. The upgrades
reflect credit enhancement and liquidity levels that provide
adequate support through various stress scenarios. Our analysis
included consideration of improved performance on several larger
loans in the pool, as well as resolutions that resulted in lower
losses than we had previously anticipated on other larger loans.
Specifically, the 200 South Wacker Drive loan ($95.5 million)
liquidated with a 1.0% realized loss to the trust, which was
significantly better than our expectations," S&P said.
"Additionally, we have estimated lower losses than we previously
anticipated for the 888 Seventh Avenue loan ($145.9 million,
10.0%), the largest loan in the pool, because the master servicer
has reported improved property performance since 2008, and for the
Time Hotel loan ($54.8 million, 3.8%), the sixth-largest loan in
the pool," S&P said.

"The downgrades reflect credit support erosion that we anticipate
will occur upon the eventual resolution of eight ($184.7 million,
12.7%) of the 10 ($246.0 million, 16.9%) assets that are currently
with the special servicer and four loans ($5.7 million, 0.4%) that
we determined to be credit-impaired," S&P said.

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

"The affirmed ratings on the class 'NBT'-raked certificates
reflect our analysis of the Northborough Tower loan. The
raked certificates derive 100% of their cash flows from the
subordinate portion of the loan. Our ratings analysis on the
raked certificates was consistent with our approach outlined
in the 'Approach' and 'Surveillance' sections of 'Presale: J.P.
Morgan Chase Commercial Mortgage Securities Trust 2011-FL1,'
published Nov. 8, 2011," S&P said.

"The Northborough Tower loan has a whole loan balance of
$19.9 million that consists of a senior pooled component of
$11.5 million (1.4%) and a subordinate nonpooled component
of $8.4 million. The loan is secured by a 207,908-sq.-ft. office
property in Houston. According to the Dec. 31, 2011, rent roll, a
single tenant (investment-grade rated by Standard & Poor's)
occupied 100% of the property. The master servicer reported a
DSC of 1.51x for the nine months ending Sept. 30, 2011. Using
the servicer-provided financial data for the nine months ended
Sept. 30, 2011, and the December 2011 rent roll, our adjusted
valuation, based on a capitalization rate of 9.25%, yielded a
stressed loan-to-value (LTV) ratio of 106.8% on the whole loan
balance. Consequently, we affirmed our ratings on the 'NBT'-raked
certificates," S&P said.

"Using servicer-provided financial information for the pool, we
calculated an adjusted debt service coverage (DSC) of 1.33x and a
LTV ratio of 103.7%. We further stressed the loans' cash flows
under our 'AAA' scenario to yield a weighted average DSC of 0.90x
and an LTV ratio of 139.3%. The implied defaults and loss severity
under the 'AAA' scenario were 65.7% and 43.3%. The DSC and LTV
calculations noted above exclude eight ($184.7 million, 12.7%)
of the 10 ($246.0 million, 16.9%) assets that are currently with
the special servicer and four loans ($5.7 million, 0.4%) that we
determined to be credit-impaired. We separately estimated losses
for the excluded specially serviced assets and credit-impaired
loans and included them in our 'AAA' scenario implied default and
loss severity figures," S&P said.

                     Transaction Summary

As of the Jan. 18, 2012 trustee remittance report, the transaction
had an aggregate trust balance of $1.46 billion (102 loans and one
real estate owned [REO] asset), compared with $1.74 billion (123
loans) at issuance. Wells Fargo Bank N.A. (Wells Fargo), the
master servicer, provided financial information for 92.6% of the
pool (by balance), which was primarily partial-year 2011 or full-
year 2010 data. "We calculated a weighted-average DSC of 1.38x
for the loans in the pool based on the reported figures. Our
adjusted DSC and LTV were 1.33x and 103.7%, which exclude eight
($184.7 million, 12.7%) of the 10 ($246.0 million, 16.9%) assets
that are currently with the special servicer and four loans
($5.7 million, 0.4%) that we determined to be credit-impaired.
To date, the trust has experienced principal losses totaling
$40.6 million on 13 assets. Thirty-four loans ($342.3 million,
23.5%) are on the master servicer's watchlist. Seven loans
($121.6 million, 8.4%) have reported DSC between 1.00x and 1.10x,
and 22 loans ($229.3 million, 15.8%) have reported DSC below
1.00x," S&P said.

                    Summary of Top 10 Loans

"The top 10 loans have an aggregate outstanding pooled trust
balance of $692.5 million (50.1%). Using servicer-reported
information, we calculated a weighted-average DSC of 1.53x for
seven of the top 10 loans. The remaining three top 10 loans
($206.2 million, 14.2%) are with the special servicer. Our
adjusted DSC and LTV figures for seven of the top 10 loans,
excluding the three specially serviced loans, were 1.32x and
107.6%. Details of the three largest non-specially serviced
top 10 loans, one of which is on the master servicer's watchlist,
are as set forth," S&P said.

The 888 Seventh Avenue loan, the largest loan in the pool, has a
trust balance of $145.9 million (10.0%) and a whole loan balance
of $318.5 million. The loan is secured by a 46-story office
building in New York City, comprising 908,299 sq. ft. of net
rentable area, which includes 69,633 sq. ft. of garage space
and 15,248 sq. ft. of retail space. Wells Fargo has reported an
improvement in property performance since 2008. The reported DSC
was 2.03x for the year ending Dec. 31, 2010, up from 1.42x as of
year-end 2008. Occupancy was 91.0% according to the Oct. 1, 2011,
rent roll.

The Station Place II loan ($99.0 million, 6.8%), the second-
largest loan in the pool, is secured by an 11-story, 362,069-sq.-
ft. class A office building in the Capitol Hill submarket of
Washington, D.C. According to the November 2011 rent roll, a
single tenant currently occupies 100% of the property. Wells
Fargo reported a DSC of 1.23x for the year ending Dec. 31, 2010.

The Marriott Hotel - Orlando Airport loan ($58.3 million, 4.0%)
is the fifth-largest loan in the pool and the largest loan on the
master servicer's watchlist. The loan is secured by a 486-room
full service lodging property, located approximately two miles
north of the Orlando International Airport. The loan appears on
Wells Fargo's watchlist due to a low reported DSC, which was 0.75x
for year-end 2010. The reported occupancy was 77.2%, as of
Sept. 30, 2011.

                        Credit Considerations

As of the Jan. 18, 2012 trustee remittance report, eight
assets ($180.6 million, 12.4%) in the pool were with the
special servicer, LNR Partners LLC (LNR). In addition, LNR
confirmed that two additional loans ($65.4 million, 4.5%) were
either transferred to the special servicer subsequent to the
January 2012 trustee remittance report or were erroneously not
reported as being specially serviced on the remittance report.
The reported payment status of the 10 specially serviced assets
is: one is REO ($13.6 million, 0.9%); three are 90-plus-days
delinquent ($18.9 million, 1.3%); one is 30 days delinquent
($54.8 million, 3.8%); one is late but less than 30 days
delinquent ($91.4 million, 6.3%); three are matured balloon
loans ($66.0 million, 4.5%); and one is current ($1.3 million,
0.1%). Four of the specially serviced assets have appraisal
reduction amounts (ARAs) in effect, totaling $10.0 million.
Details of the three largest specially serviced assets, all
of which are top 10 loans, are as set forth.

"The Eastpoint Mall loan ($91.4 million, 6.3%), is the largest
asset with the special servicer and the third-largest loan in the
pool. The total reported exposure on the loan is $92.0 million.
The loan, which has a reported late but less than 30 days
delinquent payment status, is secured by a retail mall comprising
844,175 sq. ft. in Baltimore. The loan was transferred to the
special servicer on June 25, 2010, due to imminent default. LNR
reported an 83.0% occupancy as of January 2012. Recent financial
performance data is not available for the property. LNR stated
that it is currently evaluating workout strategies for this loan.
We expect a significant loss upon the eventual resolution of the
loan," S&P said.

"The Spring Creek Apartments loan ($60.0 million, 4.1%) is the
fourth-largest loan in the pool. The loan, which matured on Jan.
11, 2011, is secured by 60 three-story multifamily apartment
buildings totaling 1,180 units in Atlanta. The loan was
transferred to the special servicer on June 25, 2010, due to
imminent default. LNR stated that it is currently working on a
forbearance agreement. The reported DSC was 1.03x for year-end
2010, and occupancy was 87.8% according to the February 2012 rent
roll," S&P said.

"The Time Hotel loan ($54.8 million, 3.8%), the sixth-largest loan
in the pool, is secured by a 193-room full-service lodging
property in New York City. The loan was transferred to the special
servicer on Jan. 30, 2012 (subsequent to the January 2012 trustee
remittance report) due to imminent default. The loan has a
reported 30 days delinquent payment status. LNR is currently
evaluating the transfer file. The loan was previously with the
special servicer and was transferred to the master servicer on
Jan. 21, 2011, performing under a forbearance agreement. The
master servicer placed this loan on its watchlist due to
delinquent debt service payment. The reported DSC and occupancy
were 0.82x and 87.7% for year-end 2010. Based on updated market
data, we expect a better than expected moderate loss upon the
eventual resolution of this loan," S&P said.

"The remaining seven specially serviced assets have balances that
individually represent less than 1.0% of the total pool balance.
ARAs totaling $10.0 million are in effect against four of these
assets. We estimated losses for six of these assets, arriving at a
weighted-average loss severity of 37.1%. LNR indicated that the
remaining loan has a reported current payment status," S&P said.

"In addition to the specially serviced assets, we determined four
loans ($5.7 million, 0.4%) to be credit-impaired due to low
reported DSCs. As a result, we viewed these loans to be at an
increased risk of default and loss. Three of the four loans are
secured by industrial properties with reported negative cash flow
or DSC close to 0.00x as of the nine months ended Sept. 30, 2011,
while the remaining loan, which is secured by a mobile home park,
has a reported DSC of 0.38x for the nine months ended Sept. 30,
2011," S&P said.

Standard & Poor's stressed the pool collateral according to our
criteria and the resultant credit enhancement levels are
consistent with its raised, lowered, and affirmed ratings.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Reports
included in this credit rating report are available at:

             http://standardandpoorsdisclosure-17g7.com

Ratings Raised

LB-UBS Commercial Mortgage Trust 2006-C3
Commercial mortgage pass-through certificates
              Rating
Class     To        From             Credit enhancement (%)
A-4       AAA (sf)  A (sf)                            33.21
A-1A      AAA (sf)  A (sf)                            33.21
A-M       A- (sf)   BBB- (sf)                         21.18

Ratings Lowered

LB-UBS Commercial Mortgage Trust 2006-C3
Commercial mortgage pass-through certificates
              Rating
Class     To        From             Credit enhancement (%)
E         B (sf)    B+ (sf)                            9.00
F         CCC+ (sf) B+ (sf)                            7.50
G         CCC- (sf) B (sf)                             5.84
H         CCC- (sf) CCC+ (sf)                          4.64

Ratings Affirmed

LB-UBS Commercial Mortgage Trust 2006-C3
Commercial mortgage pass-through certificates

Class     Rating                     Credit enhancement (%)
A-2       AAA (sf)                                    33.21
A-3       AAA (sf)                                    33.21
A-AB      AAA (sf)                                    33.21
A-J       BB (sf)                                     13.81
B         BB- (sf)                                    12.76
C         B+ (sf)                                     11.11
D         B+ (sf)                                      9.90
J         CCC- (sf)                                    3.14
X-CL      AAA (sf)                                      N/A
X-CP      AAA (sf)                                      N/A
NBT-1     BBB (sf)                                      N/A
NBT-2     BB (sf)                                       N/A
NBT-3     B (sf)                                        N/A
NBT-4     B- (sf)                                       N/A

N/A -- Not applicable


LEHMAN MANUFACTURED: Moody's Reviews Ratings for Downgrade
----------------------------------------------------------
Moody's Investors Service has placed ratings of 24 tranches on
downgrade review from 9 transactions, and 7 tranches on upgrade
review from 3 transactions. In addition, Moody's has downgraded
ratings of three tranches issued by Lehman Manufactured Housing
Asset-Backed Trust 1998-1.

RATINGS RATIONALE

The actions are primarily a result of the recent actions on the
underlying pre-2005 RMBS tranches.

The methodologies used in these ratings were "Moody's Approach to
Rating US Residential Mortgage-Backed Securities" published in
December 2008, "Moody's Approach to Rating US Resecuritized
Residential Mortgage-Backed Securities" published in February
2011, and "Pre-2005 US RMBS Surveillance Methodology" published in
January 2012.

To determine which tranches to place on review, Moody's compared
the model implied rating to the current rating. Tranches that
showed rating differences were placed on review. Once the actions
on the underlying bonds are completed additional transaction
specific analysis will be concluded.

The primary source of assumption uncertainty is the current
macroeconomic environment, in which unemployment levels remain
high, and weakness persists in the housing market. Moody's now
projects house price index to reach a bottom in early 2012, with a
3% remaining decline in 2012, and unemployment rate to start
declining, albeit slowly, as the year progresses.

Complete rating actions are:

Issuer: Citigroup Mortgage Loan Trust Inc. Re-REMIC Trust
Certificates, Series 2004-RR1

Cl. IIA-1, Aa2 (sf) Placed Under Review for Possible Downgrade;
previously on May 12, 2011 Downgraded to Aa2 (sf)

Cl. IIA-2, Aa2 (sf) Placed Under Review for Possible Downgrade;
previously on May 12, 2011 Downgraded to Aa2 (sf)

Cl. XS-2, Aa2 (sf) Placed Under Review for Possible Downgrade;
previously on May 12, 2011 Downgraded to Aa2 (sf)

Issuer: CSMC Series 2009-13R

Cl. 5-A-1, Baa3 (sf) Placed Under Review for Possible Upgrade;
previously on May 6, 2011 Downgraded to Baa3 (sf)

Issuer: CWHEQ Revolving Home Equity Loan Resecuritization Trust
2006-RES

Cl. 04P-1a, B3 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 2, 2009 Downgraded to B3 (sf)

Cl. 04P-1b, B3 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 2, 2009 Downgraded to B3 (sf)

Cl. 05A-1a, B3 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 2, 2009 Downgraded to B3 (sf)

Cl. 05A-1b, B3 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 2, 2009 Downgraded to B3 (sf)

Cl. 05E-1a, B3 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 2, 2009 Downgraded to B3 (sf)

Cl. 05E-1b, B3 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 2, 2009 Downgraded to B3 (sf)

Issuer: CWMBS, Inc. Resecuritization Mortgage Pass-Through
Certificates, Series 2005-8R

Cl. A-1, Baa3 (sf) Placed Under Review for Possible Upgrade;
previously on May 12, 2011 Downgraded to Baa3 (sf)

Cl. A-2, Baa3 (sf) Placed Under Review for Possible Upgrade;
previously on May 12, 2011 Downgraded to Baa3 (sf)

Cl. A-3, B1 (sf) Placed Under Review for Possible Upgrade;
previously on May 12, 2011 Downgraded to B1 (sf)

Cl. A-5, Ba3 (sf) Placed Under Review for Possible Upgrade;
previously on May 12, 2011 Downgraded to Ba3 (sf)

Cl. A-6, Ba3 (sf) Placed Under Review for Possible Upgrade;
previously on May 12, 2011 Downgraded to Ba3 (sf)

Issuer: Fannie Mae Grantor Trust 2004-T5

Cl. AB-1, Aa2 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 1, 2011 Downgraded to Aa2 (sf)

Cl. AB-9, Ba3 (sf) Placed Under Review for Possible Upgrade;
previously on Jun 1, 2011 Downgraded to Ba3 (sf)

Issuer: Financial Asset Securities Corp. AAA Trust 2003-1

Cl. A-5, Ba2 (sf) Placed Under Review for Possible Downgrade;
previously on May 12, 2011 Downgraded to Ba2 (sf)

Cl. A-6, Baa3 (sf) Placed Under Review for Possible Downgrade;
previously on May 12, 2011 Downgraded to Baa3 (sf)

Cl. X, Baa3 (sf) Placed Under Review for Possible Downgrade;
previously on May 12, 2011 Downgraded to Baa3 (sf)

Issuer: Financial Asset Securities Corp. AAA Trust 2005-1

Cl. I-A3A, A3 (sf) Placed Under Review for Possible Downgrade;
previously on May 12, 2011 Downgraded to A3 (sf)

Cl. I-A3B, A3 (sf) Placed Under Review for Possible Downgrade;
previously on May 12, 2011 Downgraded to A3 (sf)

Cl. I-X, A3 (sf) Placed Under Review for Possible Downgrade;
previously on May 12, 2011 Downgraded to A3 (sf)

Issuer: Lehman Manufactured Housing Asset-Backed Trust 1998-1

II-A1, Downgraded to Caa2 (sf); previously on Aug 10, 2009
Downgraded to Caa1 (sf)

II-A2, Downgraded to Caa3 (sf); previously on Aug 10, 2009
Downgraded to Caa2 (sf)

II-IO1, Downgraded to Caa2 (sf); previously on Aug 10, 2009
Downgraded to Caa1 (sf)

Issuer: MASTR Adjustable Rate Mortgages Trust 2005-4

Cl. A-1, Ba1 (sf) Placed Under Review for Possible Downgrade;
previously on May 24, 2011 Downgraded to Ba1 (sf)

Cl. A-2, Caa3 (sf) Placed Under Review for Possible Downgrade;
previously on May 24, 2011 Downgraded to Caa3 (sf)

Cl. A-X, Ba1 (sf) Placed Under Review for Possible Downgrade;
previously on May 24, 2011 Downgraded to Ba1 (sf)

Issuer: Mellon Re-Remic Pass-Through Trust 2004-TBC1

Cl. A, Aa1 (sf) Placed Under Review for Possible Downgrade;
previously on Jul 6, 2011 Downgraded to Aa1 (sf)

Cl. X, Aa1 (sf) Placed Under Review for Possible Downgrade;
previously on Jul 6, 2011 Downgraded to Aa1 (sf)

Issuer: RALI Series 2003-QR19 Trust

Cl. CB-3, Aa1 (sf) Placed Under Review for Possible Downgrade;
previously on May 12, 2011 Downgraded to Aa1 (sf)

Cl. CB-4, Baa1 (sf) Placed Under Review for Possible Downgrade;
previously on May 12, 2011 Downgraded to Baa1 (sf)

Issuer: RBSSP Resecuritization Trust 2009-8

Cl. 2-A1, Aa1 (sf) Placed Under Review for Possible Downgrade;
previously on May 6, 2011 Downgraded to Aa1 (sf)


LIGHTPOINT VII: S&P Raises Rating on Class D Notes to 'B+'
----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
B and D notes from LightPoint CLO VII Ltd., a collateralized loan
obligation (CLO) transaction managed by Neuberger Berman Inc., and
removed them from CreditWatch with positive implications. "At the
same time, we affirmed our ratings on the class A-1, A-2, and C
notes and removed two of them from CreditWatch positive," S&P
said.

"The upgrades reflect improved performance we have observed in
the deal's underlying asset portfolio since our December 2009
rating actions, when we lowered our ratings on all of the notes.
As of the Jan. 5, 2012 trustee report, the transaction held
$1.7 million in defaulted assets. This was down from the
$13.2 million in defaulted assets noted in the October 2009
trustee report, which we referenced for our December 2009
rating actions. Also, as of January 2011, the transaction held
$7.7 million in assets from underlying obligors with ratings in
the 'CCC' range, compared with $45.5 million in October 2009," S&P
said.

The improvement in asset credit quality has benefited the
transaction's overcollateralization (O/C) ratios, which all have
increased since October 2009:

   The class A O/C ratio is 120.4%, compared with 117.5%;

   The class B O/C ratio is 112.4%, compared with 109.6%;

   The class C O/C ratio is 107.2%, compared with 104.6%; and

   The class D O/C ratio is 102.8%, compared with 100.1%.

"Also, when we applied to the class D notes the largest obligor
test, one of the supplement tests, the transaction was able to
withstand the specified combination of underlying asset defaults
at the 'B (sf)' rating level. At the time of our last rating
action, the class D notes failed this test at the 'CCC (sf)'
rating level," S&P said.

"We affirmed our ratings on the class A-1, A-2, and C notes to
reflect the availability of credit support at the current rating
levels," S&P said.

"The transaction is still in its reinvestment period, and all of
the rated classes have their original principal balances
outstanding, with the exception of the A-1 class, which has paid
down to 97.7% of its original balance," S&P said.

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

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

             http://standardandpoorsdisclosure-17g7.com

Rating And Creditwatch Actions

LightPoint CLO VII Ltd.
                              Rating
Class                   To           From
A-2                     AA- (sf)     AA- (sf)/Watch Pos
B                       A- (sf)      BBB+ (sf)/Watch Pos
C                       BBB- (sf)    BBB- (sf)/Watch Pos
D                       B+ (sf)      CCC- (sf)/Watch Pos

Rating Affirmed

LightPoint CLO VII Ltd.
Class                   Rating
A-1                     AA+ (sf)


LNR CDO: Moody's Affirms Rating of Cl. A Notes at 'C'
-----------------------------------------------------
Moody's Investors Service has affirmed the ratings of all classes
of Notes issued by LNR CDO V Ltd. 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 and Re-Remic)
transactions.

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

Cl. B, Affirmed at C (sf); previously on Feb 19, 2010 Downgraded
to C (sf)

Cl. C-FL, Affirmed at C (sf); previously on Dec 4, 2009 Downgraded
to C (sf)

Cl. C-FX, Affirmed at C (sf); previously on Dec 4, 2009 Downgraded
to C (sf)

Cl. D, Affirmed at C (sf); previously on Dec 4, 2009 Downgraded to
C (sf)

Cl. E, Affirmed at C (sf); previously on Dec 4, 2009 Downgraded to
C (sf)

Cl. F, Affirmed at C (sf); previously on Dec 4, 2009 Downgraded to
C (sf)

Cl. G, Affirmed at C (sf); previously on Dec 4, 2009 Downgraded to
C (sf)

Cl. H, Affirmed at C (sf); previously on Dec 4, 2009 Downgraded to
C (sf)

Cl. J, Affirmed at C (sf); previously on Dec 4, 2009 Downgraded to
C (sf)

Cl. K, Affirmed at C (sf); previously on Dec 4, 2009 Downgraded to
C (sf)

Cl. L, Affirmed at C (sf); previously on Dec 4, 2009 Downgraded to
C (sf)

RATINGS RATIONALE

LNR CDO V Ltd. is a static CRE CDO transaction backed by a
portfolio commercial mortgage backed securities (CMBS). As of the
January 23, 2012 Trustee report, the collateral par amount is
$200.5 million, representing a $561.7 million decrease since
securitization primarily due to realized losses to the collateral
pool.

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 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 10,000, the same as last review. The distribution
of current ratings and credit estimates is as follows: Ca-C
(100.0%, the same as 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 7.3 years compared
to 9.0 at last review.

WARR is the par-weighted average of the mean recovery values for
the collateral assets in the pool. Due to the ratings of all of
the collateral currently within the Ca-C buckets, Moody's modeled
a fixed zero WARR, the same as 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 MAC was not applicable to this review as all of the
collateral has a bottom-dollar WARF of 10,000.

Moody's review incorporated CDOROM(R) v2.8, one of Moody's CDO
rating models, which was released on January 24, 2011.

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. In general, the rated notes are particularly
sensitive to changes in recovery rate assumptions. However, in
light of the performance indicators noted above, Moody's believes
that it is unlikely that the ratings are sensitive to further
change.

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 extent of the
slowdown in growth in the current macroeconomic environment and
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 in
recovery and improvements in the office sector continue, with
fundamentals in Gateway cities outperforming their suburban
counterparts. However, office demand is closely tied to
employment, where fundamentals remain weak, so significant
improvement may be delayed. Performance in the retail sector has
been mixed with on-going rent deflation and leasing challenges.
Across all property sectors, the availability of debt capital
continues to improve with monetary policy expected to remain
supportive and interest rate hikes postponed. Moody's central
global macroeconomic scenario reflects an overall downward
revision of forecasts since last quarter, amidst ongoing fiscal
consolidation efforts, household and banking sector deleveraging,
persistently high unemployment levels, and weak housing markets
that will continue to constrain growth.

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.


LNR CDO: Moody's Affirms Rating of Cl. B-FL Notes at 'C'
--------------------------------------------------------
Moody's Investors Service has affirmed the ratings of all classes
of Notes issued by LNR CDO IV Ltd. 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 and Re-Remic)
transactions.

Cl. A, Affirmed at C (sf); previously on Apr 6, 2011 Downgraded to
C (sf)

Cl. B-FL, Affirmed at C (sf); previously on Apr 6, 2010 Downgraded
to C (sf)

Cl. B-FX, Affirmed at C (sf); previously on Apr 6, 2010 Downgraded
to C (sf)

Cl. C-FL, Affirmed at C (sf); previously on Apr 6, 2010 Downgraded
to C (sf)

Cl. C-FX, Affirmed at C (sf); previously on Apr 6, 2010 Downgraded
to C (sf)

Cl. D-FL, Affirmed at C (sf); previously on Apr 6, 2010 Downgraded
to C (sf)

Cl. D-FX, Affirmed at C (sf); previously on Apr 6, 2010 Downgraded
to C (sf)

Cl. E, Affirmed at C (sf); previously on Apr 6, 2010 Downgraded to
C (sf)

Cl. F-FL, Affirmed at C (sf); previously on Apr 6, 2010 Downgraded
to C (sf)

Cl. F-FX, Affirmed at C (sf); previously on Apr 6, 2010 Downgraded
to C (sf)

Cl. G, Affirmed at C (sf); previously on Apr 6, 2010 Downgraded to
C (sf)

Cl. H, Affirmed at C (sf); previously on Apr 6, 2010 Downgraded to
C (sf)

Cl. J, Affirmed at C (sf); previously on Apr 6, 2010 Downgraded to
C (sf)

Cl. K, Affirmed at C (sf); previously on Apr 6, 2010 Downgraded to
C (sf)

RATINGS RATIONALE

LNR CDO IV Ltd. is a static CRE CDO transaction backed by a
portfolio commercial mortgage backed securities (CMBS). As of the
January 25, 2012 Trustee report, the collateral par amount is
$798.9 million, representing a $802.5 million decrease since
securitization primarily due to realized losses to the collateral
pool.

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 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 8,745 compared to 9,074 at last review. The
distribution of current ratings and credit estimates is as
follows: Aaa-Aa3 (1.5% compared to 0.0% at last review), Baa1-Baa3
(5.1% compared to 3.7% at last review), Ba1-Ba3 (4.1% compared to
1.6% at last review), B1-B3 (1.2% compared to 3.9% at last
review), and Caa1-C (88.1% compared to 90.8% 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 5.2 years compared
to 6.6 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
3.1% compared to 3.2% at last review.

MAC is a single factor that describes the pair-wise asset
correlation to the default distribution among the instruments
within the collateral pool (i.e. the measure of diversity).
Moody's modeled a MAC of 100.0% compared to 99.9% 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. In general, the rated notes are particularly
sensitive to changes in recovery rate assumptions. However, in
light of the performance indicators noted above, Moody's believes
that it is unlikely that the ratings are sensitive to further
change.

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 extent of the
slowdown in growth in the current macroeconomic environment and
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 in
recovery and improvements in the office sector continue, with
fundamentals in Gateway cities outperforming their suburban
counterparts. However, office demand is closely tied to
employment, where fundamentals remain weak, so significant
improvement may be delayed. Performance in the retail sector has
been mixed with on-going rent deflation and leasing challenges.
Across all property sectors, the availability of debt capital
continues to improve with monetary policy expected to remain
supportive and interest rate hikes postponed. Moody's central
global macroeconomic scenario reflects an overall downward
revision of forecasts since last quarter, amidst ongoing fiscal
consolidation efforts, household and banking sector deleveraging,
persistently high unemployment levels, and weak housing markets
that will continue to constrain growth.

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.


MACLAURIN SPC: Moody's Lowers Rating of Cl. A1 Notes to 'C'
-----------------------------------------------------------
Moody's has downgraded one class and affirmed one class of Notes
issued by Maclaurin SPC 2007-2 Segregated Portfolio.

Cl. A1, Downgraded to C (sf); previously on Mar 2, 2011 Downgraded
to Caa3 (sf)

Cl. A2, Affirmed at C (sf); previously on Mar 2, 2011 Downgraded
to C (sf)

RATINGS RATIONALE

The classes affected by the action is a result of a termination of
the transaction subject to a Termination Agreement and the
subsequent direction of the Trustee to liquidate the reference
obligation and cash term collateral. Moody's has been notified by
the Trustee that a final distribution of liquidation proceeds has
taken place; with the exception of retention of a small amount of
reserve funds. The ratings on the outstanding funded notes in the
transaction will be subsequently withdrawn due to the Agreement
between transaction parties which reduced the funded notes
notional balances to $0.

The rating action taken reflects the severity of loss associated
with certain tranches and reflects the final liquidation
distribution.

Maclaurin SPC 2007-2 Segregated Portfolio is a synthetic CRE CDO
transaction backed by a portfolio of commercial mortgage backed
securities (CMBS) reference obligations (100.0% of the pool
balance). All of the CMBS referenced obligations were securitized
between 2005 and 2007 and originally rated or credit estimated
A2 or A3. The aggregate Note balance of the transaction is
$1.0 billion, the same as at securitization.

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


MADISON PARK V: S&P Raises Rating on Class D Notes to 'BB+'
-----------------------------------------------------------
Standard & Poor's Ratings Services  raised its ratings on the
class A-1a, A-1b, A-2, B, C, and D notes from Madison Park Funding
V Ltd., a U.S. collateralized loan obligation (CLO) transaction
managed by CSFB Alternative Capital Inc. "At the same time, we
removed them from CreditWatch, where we had placed them with
positive implications on Nov. 14, 2011," S&P said.

"The upgrades mainly reflect the improved credit performance of
the transaction's underlying asset portfolio since we lowered our
ratings on all of the notes in December 2009, following the
application of our September 2009 collateralized debt obligation
(CDO) criteria. As of the January 2012 trustee report, the
transaction had $2.21 million of defaulted assets. This was down
from the $19.25 million of defaulted assets noted in the October
2009 trustee report, which we referenced for our December 2009
rating actions. Additionally, the trustee reported $47.39 million
in assets from obligors rated in the 'CCC' category in January
2012, compared with $80.62 million in October 2009," S&P said.

"The upgrades also reflect an improvement in the
overcollateralization (O/C) available to support the notes since
our December 2009 rating actions," S&P said. The trustee reported
the O/C ratios in the January 2012 monthly report:

   The class A O/C ratio was 128.31%, compared with a reported
   ratio of 121.79% in October 2009;

   The class B O/C ratio was 118.59%, compared with a
   reported ratio of 112.57% in October 2009;

   The class C O/C ratio was 114.17%, compared with a reported
   ratio of 108.37% in October 2009; and

   The class D O/C ratio was 109.80%, compared with a reported
   ratio of 104.22% in October 2009.

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.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

          http://standardandpoorsdisclosure-17g7.com

Ratings Raised

Madison Park Funding V Ltd.
                   Rating
Class         To           From
A-1a          AAA (sf)     AA+ (sf)/Watch Pos
A-1b          AA+ (sf)     AA- (sf)/Watch Pos
A-2           AA (sf)      A+ (sf)/Watch Pos
B             A (sf)       BBB- (sf)/Watch Pos
C             BBB (sf)     BB+ (sf)/Watch Pos
D             BB+ (sf)     B+ (sf)/Watch Pos

Transaction Information
Issuer:             Madison Park Funding V Ltd.
Co-issuer:          Madison Park Funding V (Delaware) Corp.
Underwriter:        Citigroup Global Markets Inc.
Collateral manager: CSFB Alternative Capital Inc.
Trustee:            Bank of America N.A.
Transaction type:   Cash flow CDO


MAPS CLO: S&P Raises Rating on Class D Notes to 'BB'; Off Watch
---------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on all rated
notes from MAPS CLO Fund II Ltd., a U.S. collateralized loan
obligation (CLO) transaction managed by GSO/Blackstone Debt Funds.
"At the same time, we removed our ratings on these classes from
CreditWatch, where we placed them with positive implications on
Feb. 10, 2012," S&P said.

"The upgrades reflect improved performance we have observed in the
deal's underlying asset portfolio since we downgraded the notes on
Nov. 25, 2009. As of the Jan. 10, 2012 trustee report, the
transaction's asset portfolio had $2.68 million in defaulted
obligations and $43.32 million in 'CCC' rated obligations. This
was a decrease from $16.15 million in defaulted obligations and
$67.16 million in 'CCC' rated obligations noted in the Oct. 10,
2009 trustee report, which we used for our November 2009 rating
actions," S&P said.

"We also observed an increase in the overcollateralization (O/C)
available to support the rated notes," S&P said. The trustee
reported the O/C ratios in the Jan. 10, 2012 monthly report:

    The class A O/C ratio was 129.41%, compared with a reported
    ratio of 125.72% in October 2009;

    The class B O/C ratio was 119.03%, compared with a reported
    ratio of 115.63% in October 2009;

    The class C O/C ratio was 111.46%, compared with a reported
    ratio of 108.28% in October 2009; and

    The class D O/C ratio was 106.53%, compared with a reported
    ratio of 103.49% in October 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.

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

           http://standardandpoorsdisclosure-17g7.com

Rating Actions

MAPS CLO Fund II Ltd.
                       Rating
Class              To          From
A-1R               AAA (sf)    AA+ (sf)/Watch Pos
A-1S               AAA (sf)    AA+ (sf)/Watch Pos
A-1                AA+ (sf)    A+ (sf)/Watch Pos
A-1J               AA+ (sf)    A+ (sf)/Watch Pos
A-2                AA (sf)     A+ (sf)/Watch Pos
B                  A (sf)      BBB (sf)/Watch Pos
C                  BBB (sf)    BB (sf)/Watch Pos
D                  BB (sf)    CCC+ (sf)/Watch Pos


MASTR ASSET: S&P Lowers Rating on Class 8-B-3 From 'BBB' to 'CCC'
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on six
classes from MASTR Asset Securitization Trust Series 2004-9, a
U.S. residential mortgage-backed securities (RMBS) transaction
backed by prime jumbo mortgage loan collateral. "Additionally, we
affirmed our ratings on 26 classes from the same transaction and
one other transaction, American Housing Trust Series 1, a U.S.
RMBS transaction backed by prime conforming mortgage loan
collateral issued in 1988," S&P said.

"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 previous rating stresses,"
S&P said.

"The affirmations reflect our belief that the amount of projected
credit enhancement available for these classes is sufficient to
cover projected losses associated with these rating levels," S&P
said.

"In order to maintain a 'B' rating on a class from a prime
conforming or prime jumbo transaction, we assessed whether, in our
view, a class could absorb the remaining base-case loss
assumptions we used in our analysis. In order to maintain a rating
higher than 'B', we assessed whether the class could withstand
losses exceeding our remaining base-case loss assumptions at a
percentage specific to each rating category, up to 235% for a
'AAA' rating. For example, in general, we would assess whether one
class could withstand approximately 127% of our remaining base-
case loss assumptions to maintain a 'BB' rating, while we would
assess whether a different class could withstand approximately
154% 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 235% of our remaining base-case loss
assumptions under our analysis," S&P said.

For additional structure-level information regarding delinquencies
and cumulative losses for these transactions through the January
2012 remittance period please see:

Losses and Delinquencies*

American Housing Trust
         Original    Pool    Cum.          Total         Severe
         balance   factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
1             309    1.57     N/A          15.73          11.93

MASTR Asset Securitization Trust
          Original    Pool    Cum.          Total         Severe
          balance  factor  losses   delinquencies  delinquencies
Series    (mil. $)     (%)     (%)            (%)            (%)
2004-9         90    19.14   0.00            2.41           2.41
2004-9        193    15.50   0.00            1.84           1.84
2004-9        328    22.12   0.33            8.60           5.82

*Cumulative losses represent the percentage of the original pool
balance, and total and severe delinquencies represent the
percentage of the current pool balance.

Subordination provides credit support for the affected
transactions.

             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 Represent ations,
warranties and enforcement mechanisms in issuances of similar
securities. The Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Reports
included in this credit rating report are available at:

           http://standardandpoorsdisclosure-17g7.com

Rating Actions

MASTR Asset Securitization Trust
Series 2004-9
                      Rating
Class  CUSIP        To        From
8-B-1  57643MGH1    A (sf)    AA (sf)
8-B-2  57643MGJ7    BB (sf)   A (sf)
8-B-3  57643MGK4    CCC (sf)  BBB (sf)
8-B-4  57643MGL2    CC (sf)   B (sf)
15-B-2  57643MGA6   BBB (sf)  A (sf)
15-B-3  57643MGB4   B (sf)    BBB (sf)

Ratings Affirmed

American Housing Trust
Series 1
Class  CUSIP      Rating
2    026709AE5    AAA (sf)
3    026709AG0    AAA (sf)
4    026709AF2    AAA (sf)
5    026709AH8    AAA (sf)
7    026709AB1    AAA (sf)

MASTR Asset Securitization Trust
Series 2004-9
Class  CUSIP        Rating
1-A-1  57643MFC3    AAA (sf)
2-A-2  57643MFE9    AAA (sf)
2-A-3  57643MFF6    AAA (sf)
2-A-4  57643MFG4    AAA (sf)
3-A-4  57643MFL3    AAA (sf)
3-A-5  57643MFM1    AAA (sf)
3-A-6  57643MFN9    AAA (sf)
3-A-7  57643MFP4    AAA (sf)
4-A-1  57643MFQ2    AAA (sf)
5-A-1  57643MFR0    AAA (sf)
6-A-1  57643MFS8    AAA (sf)
7-A-1  57643MFT6    AAA (sf)
8-A-2  57643MGG3    AAA (sf)
8-B-5  57643MGM0    CC (sf)
15-A-X 57643MFV1    AAA (sf)
15-B-1 57643MFZ2    AA (sf)
15-B-4 57643MGP3    CCC (sf)
15-B-5 57643MGQ1    CC (sf)
30-A-X 57643MFW9    AAA (sf)
30-B-3 57643MGE8    CC (sf)
PO     57643MFU3    AAA (sf)


MCG 2006-1: S&P Raises Rating on Class D Notes to 'BB+'
-------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1, A-2, A-3, B, C, and D notes from MCG Commercial Loan Trust
2006-1 and removed the ratings on the class A-1, A-2, and A-3
notes from CreditWatch with positive implications. MCG Commercial
Loan Trust 2006-1 is a collateralized loan obligation (CLO)
transaction managed by MCG Capital Corp.

"The upgrades reflect the improved performance we have observed in
the deal since our rating actions in February 2011. According to
the Jan. 5, 2012 trustee report, the transaction held no defaulted
assets and $128.0 million in assets rated 'CCC', down from
$22.7 million in defaulted assets and $146.1 million in assets
rated 'CCC' as of the Dec. 25, 2010 trustee report, which we used
in our February 2011 analysis," S&P said.

"Since the transaction's reinvestment period ended in July 2011,
the class A-1 notes have paid down $52.8 million, the class A-2
notes have paid down $2.5 million, and the class A-3 notes have
paid down $42.7 million," S&P said.

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

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

             http://standardandpoorsdisclosure-17g7.com

Rating Actions

MCG Commercial Loan Trust 2006-1
                       Rating
Class               To           From
A-1                 AAA (sf)     AA- (sf)/Watch Pos
A-2                 AAA (sf)     AA- (sf)/Watch Pos
A-3                 AAA (sf)     AA- (sf)/Watch Pos
B                   AA (sf)      A+ (sf)
C                   A (sf)       BBB+ (sf)
D                   BB+ (sf)     BB (sf)


MERRILL LYNCH: DBRS Confirms Class F Rating at 'BB'
---------------------------------------------------
DBRS has confirmed the ratings of all 15 classes of Merrill Lynch
Financial Assets Inc., Series 2006-Canada 19:

  -- Class A-2 at AAA (sf)
  -- Class A-3 at AAA (sf)
  -- Class B at AA (sf)
  -- Class C at A (sf)
  -- Class D at BBB (sf)
  -- Class E at BBB (low) (sf)
  -- Class F at BB (high) (sf)
  -- Class G at BB (sf)
  -- Class H at BB (low) (sf)
  -- Class J at B (high) (sf)
  -- Class K at B (sf)
  -- Class L at B (low) (sf)
  -- Class XP-1 at AAA (sf)
  -- Class XP-2 at AAA (sf)
  -- Class XC at AAA (sf)

Trends for Class J, K and L changed to Stable from Negative.  All
other classes were confirmed with a Stable trend.

These rating actions reflect the continued stable performance of
the pool overall.  At the time of the February 2011 DBRS review of
this transaction, there were two loans in special servicing and
two large loans on the servicer's watchlist.  Given the
uncertainty surrounding these four loans, DBRS placed classes J, K
and L on trend Negative at that time.  Shortly after the review,
one of the loans in special servicing, Prospectus ID #23 (Summit
Properties), was resolved with no loss to the trust and the two
large loans on the watchlist, Prospectus ID #3 (Castle Royale) and
Prospectus ID #10 (8100 Granville), have been removed as the
performance has improved significantly for each property.
Reflecting these developments, DBRS has changed the trends for
classes J, K and L to Stable.

As of the February 2012 remittance report, there were 58 of the
original 75 loans in the pool remaining, with a collateral
reduction of approximately 24.2% since issuance.  With 96.6% of
loans reporting updated financial information, the pool has a
weighted-average DSCR of 1.5x, as compared to 1.4x at issuance.
In addition, the current weighted-average debt yield is 12.1% and
the weighted-average LTV is 64.5%, as compared to 10.3% and 70.6%,
respectively, at issuance.  There is one loan in special
servicing, Prospectus ID #4 (Marriott Pooled Senior Loan), which
comprises 5.6% of the outstanding pool balance.  There are 11
loans on the servicer's watchlist; those loans combine for 10.9%
of the outstanding pool balance.

For a complete discussion of the DBRS viewpoint, including
detailed information on the largest loans in the pool, the loans
in special servicing and the loans on the servicer's watchlist,
see the February 2012 Monthly Surveillance Report for this pool,
which will publish shortly.


MERRILL LYNCH: DBRS Confirms Class G Rating at 'BB'
---------------------------------------------------
DBRS has confirmed the ratings of all 15 classes of Merrill Lynch
Financial Assets Inc., Series 2006-Canada 20:

  -- Class A-2 at AAA (sf)
  -- Class A-3 at AAA (sf)
  -- Class B at AA (sf)
  -- Class C at A (sf)
  -- Class D at BBB (sf)
  -- Class E at BBB (low) (sf)
  -- Class F at BB (high) (sf)
  -- Class G at BB (sf)
  -- Class H at BB (low) (sf)
  -- Class J at B (high) (sf)
  -- Class K at B (sf)
  -- Class L at B (low) (sf)
  -- Class XP-1 at AAA (sf)
  -- Class XP-2 at AAA (sf)
  -- Class XC at AAA (sf)

All classes were confirmed with a Stable trend.

These rating actions reflect the continued stable performance of
the pool overall.  As of the February 2012 remittance report,
there were 49 of the original 66 loans in the pool remaining, with
a collateral reduction of approximately 26.9% since issuance.
With 77.8% of loans reporting updated financial information, the
pool has a weighted-average DSCR of 1.7x, as compared to 1.4x at
issuance.  In addition, the current weighted-average debt yield is
13.2% and the weighted-average LTV is 63.5%, as compared to 10.4%
and 69.5%, respectively, at issuance.  The actual percentage of
the pool reporting updated financial information is significantly
higher than 77.8%, but because of reporting issues, DBRS was
unable to include the complete list in these calculations.  DBRS
is working with the servicer to resolve the issues for future
reports.  There is one loan in special servicing, Prospectus ID #8
(Marriott Pooled Senior Loan), which comprises 5.7% of the
outstanding pool balance. There are four loans on the servicer's
watchlist; those loans combine for 6.0% of the outstanding pool
balance.

For a complete discussion of the DBRS viewpoint, including
detailed information on the largest loans in the pool, the loans
in special servicing and the loans on the servicer's watchlist,
see the February 2012 Monthly Surveillance Report for this pool,
which will publish shortly.




MERRILL LYNCH: DBRS Downgrades Class F Rating to 'C'
----------------------------------------------------
DBRS has downgraded Class F of Merrill Lynch Mortgage Trust 2005-
CIP1 (the Trust) to C (sf) from CCC (sf).  DBRS has also confirmed
these classes of Merrill Lynch Mortgage Trust 2005-CIP1:

  -- Classes A-2, A-3A, A-3B, A-4, A-SB, XC and XP at AAA (sf)
  -- Class A-M at AA (sf)
  -- Class A-J at BBB (sf)
  -- Class B at BB (high) (sf)
  -- Class C at BB (low) (sf)
  -- Class D at B (low) (sf)
  -- Class E at CCC (sf)
  -- Classes G, H, J, K and L at C (sf)

Three pivotal loans that had been in special servicing at the
time of the last full surveillance review have been modified.
The borrower for the 2801 Network Boulevard loan (Prospectus
ID#20, 1.3% of the current pool balance) was issued a two-year
forbearance, and the loan has been transferred back to the
master servicer.  Highwoods Portfolio57 (Prospectus ID#2, 10.0%
of the current pool balance) and University Village (Prospectus
ID#12, 1.9% of the current pool balance) were each restructured
with a subordinate B-note.  DBRS's assumption is that the balance
of the B-notes will ultimately be lost to the Trust.  The losses
associated with these two B-notes in addition to the losses
expected from the liquidation of loans in special servicing totals
approximately $70 million, which would impact Class F.  Highwoods
Portfolio57 (Prospectus ID#2) and University Village (Prospectus
ID#12) remain in special servicing.

Two loans in the original top ten are on the servicer's watchlist
because of a low debt service coverage ratio (DSCR), but are not
deemed by DBRS to pose an immediate threat to the pool's overall
stability.  Residence Inn Hotel Portfolio (Prospectus ID#6, 3.0%
of the current pool balance) is secured by four extended-stay
Residence Inn hotels located in Texas, New York and Florida.  The
YE2010 DSCR was reported to be 1.11x, a figure likely driven by a
relatively low occupancy rate of 56% for the same time frame.
According to Q3 2011 financials, performance has improved
slightly.  As of September 2011, the DSCR and occupancy rate
were reported to be 1.27x and 73%, respectively, for the trailing
twelve months.

The second top-ten loan currently on the servicer's watchlist
is Equity Lifestyle Portfolio (Prospectus ID#8, 2.4% of the
current pool balance).  This loan is secured by three RV resort
communities located in New York and New Hampshire.  Performance at
the properties was originally projected to fluctuate, due to the
seasonality of this particular property type.  There were over
$10.0 million in total reserves for the loan as of January 2012.
This loan has been on the watchlist since May 2006 and has never
been delinquent.

The cumulative losses for this transaction, to date, have resulted
in the full principal losses to Classes Q, P and N and have
reduced the balance of Class M to $1.9 million.  DBRS currently
projects that potential losses to loans in special servicing will
be contained to Class F.  DBRS continues to monitor this
transaction on a monthly basis, with increased focus on these
pivotal loans.


MERRILL LYNCH: S&P Affirms 'BB+' Rating on Class A-3 Certificates
-----------------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on three
classes of commercial mortgage pass-through certificates from
Merrill Lynch Floating Trust's series 2008-LAQ, a U.S. commercial
mortgage-backed securities (CMBS) transaction.

"The affirmations follow our analysis of the transaction, which
included our revaluation of the 355 limited-service hotels
securing the sole floating-rate interest-only mortgage loan that
serves as collateral for the trust. Our adjusted valuation on the
hotel portfolio, using a 12.01% capitalization rate, yielded an
in-trust stressed loan-to-value ratio of 71.5%. We also considered
the potential modification of the defaulted one month LIBOR
indexed mortgage loan," S&P said.

"The mortgage loan was transferred to the special servicer, Bank
of America N.A. (BofA), on Sept. 9, 2011, due to imminent default
following the borrower's request for a loan modification and
extension. The mortgage loan is scheduled to mature on July 6,
2012. BofA recently informed us that it is currently working with
the borrower on a loan extension and modification agreement that
is projected to close at the earliest, the end of this month.
Based on our conversation, BofA expects that the borrower will pay
the special servicing fees and associated expenses as part of the
loan modification and extension request. We may reevaluate the
effect on the certificate classes and adjust our ratings
accordingly if the loan modification/extension does not occur,"
S&P said.

"Our ratings analysis on the certificate classes was consistent
with our approach outlined in the 'Approach' and 'Surveillance'
sections of 'Presale: J.P. Morgan Chase Commercial Mortgage
Securities Trust 2011-FL1,' published Nov. 8, 2011. We based our
analysis, in part, on a review of the borrower's consolidated
operating statements for the trailing-12-months (TTM) ended
Nov. 30, 2011, the year-ended Dec. 31, 2010, the borrower's
consolidated 2012 budget, and available Smith Travel Research
(STR) reports. The reported TTM ended Nov. 30, 2011, combined
occupancy and average daily rate for the lodging portfolio were
60.2% and $64.86 yielding a revenue per available room of $39.02.
This was up 5.6% from year-end 2010 and 5.9% from year-end 2009.
The master servicer, also BofA, reported a combined in-trust
DSC of 10.21x for the TTM ended Sept. 30, 2011. The one-month
LIBOR rate was 0.295% (according to the Feb. 9, 2012 trustee
remittance report)," S&P said.

"As of the Feb. 9, 2012 trustee remittance report, the mortgage
loan has a whole-loan balance of $2.35 billion that consists of
28 in-trust senior notes totaling $1.438 billion and two nontrust
junior notes totaling $911.5 million. In addition, the equity
interests in the borrower secure mezzanine debt totaling
$559.9 million," S&P said.

"The mortgage loan is secured by 355 limited-service hotel
properties totaling 44,110 rooms in 35 states in the U.S. The
collateral properties operated under one of three flags: La Quinta
Inn, La Quinta Inn & Suites, and Baymont Inn and Suites. The loan
has property release provisions, provided certain conditions are
met, which include a payment of a release price that is 100%-120%
of the applicable released amount for the mortgaged property.
According to BofA, with the exception of a pad site release, no
hotel properties have been released to date," S&P said.

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

            http://standardandpoorsdisclosure-17g7.com

Ratings Affirmed

Merrill Lynch Floating Trust
Commercial mortgage pass-through certificates series 2008-LAQ

Class     Rating
A-1       AA+ (sf)
A-2       BBB- (sf)
A-3       BB+ (sf)


MERRILL LYNCH: S&P Withdraws 'B-' Rating on Class J Certs.
----------------------------------------------------------
Standard & Poor's Ratings Services withdrew its ratings on 61
certificates from 33 commercial mortgage-backed securities (CMBS)
and three commercial real estate-collateralized debt obligations
(CRE CDO) transactions.

"We withdrew our ratings on 49 principal and interest paying
classes from 30 CMBS and three CRE CDO transactions following the
repayment in full of each class' principal balance, as noted in
each transaction's respective January 2012 trustee remittance
report. We withdrew our ratings on four interest-only (IO) classes
from four CMBS transactions following the reduction of the
classes' notional balances as noted in each transaction's
respective January 2012 trustee remittance report," S&P said.

"In addition, we withdrew our ratings on eight IO classes from six
CMBS transactions following the repayment of all principal and
interest paying classes rated 'AA- (sf)' or higher, according to
our criteria for rating IO securities," S&P said.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

          http://standardandpoorsdisclosure-17g7.com

Ratings Withdrawn Following Repayment Of Principal Balance Or
Reduction Of Notional Balance

Asset Securitization Corp.
Commercial mortgage pass-through certificates series 1997-D4
                                 Rating
Class                    To                  From
A-8                      NR                  AAA (sf)


Banc of America Commercial Mortgage Inc.
Commercial mortgage pass-through certificates series 2003-1

                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

Bear Stearns Commercial Mortgage Securities Trust 2007-TOP28
Commercial mortgage pass-through certificates
                               Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

Brascan Real Estate CDO 2004-1 Ltd.
Commercial real estate-collateralized debt obligations
                                 Rating
Class                    To                  From
B                        NR                  AA (sf)
C                        NR                  A- (sf)

Citigroup Commercial Mortgage Trust 2007-FL3
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

Credit Suisse Commercial Mortgage Trust Series 2006-C2
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From

A-1                      NR                  AAA (sf)

Credit Suisse Commercial Mortgage Trust Series 2006-C5
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

Credit Suisse First Boston Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2001-CK6
                                 Rating
Class                    To                  From
D                        NR                  AAA (sf)

Credit Suisse First Boston Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2002-CKP1
                                 Rating
Class                    To                  From
B                        NR                  AAA (sf)

Credit Suisse First Boston Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2003-C3
                                 Rating
Class                    To                  From
A-4                      NR                  AAA (sf)

Credit Suisse First Boston Mortgage Securities Corp.
Commercial mortgage pass-through certificated series 2003-CPN1
                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

CVS Lease Pass-Through Trust 2001
Commercial mortgage pass-through certificates
                                 Rating
Cusip                    To                  From
126650AF7                NR                  BBB+ (sf)

First Union National Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2000-C1
                                 Rating
Class                    To                  From
D                        NR                  AAA (sf)

First Union National Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2000-C2
                                 Rating
Class                    To                  From
F                        NR                  A- (sf)

First Union National Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2002-C1
                                 Rating
Class                    To                  From
B                        NR                  AAA (sf)
C                        NR                  AAA (sf)
D                        NR                  AAA (sf)
E                        NR                  AA+ (sf)

FMC Real Estate CDO 2005-1 Ltd.
Commercial real estate-collateralized debt obligations
                                 Rating
Class                    To                  From
A-2                      NR                  A- (sf)

GE Capital Commercial Mortgage Corp.
Commercial mortgage pass-through certificates series 2001-3
                                 Rating
Class                    To                  From
D                        NR                  AAA (sf)

GE Commercial Mortgage Corporation
Commercial mortgage pass-through certificates series 2005-C1
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

Greenwich Capital Commercial Funding Corp.
Commercial mortgage pass-through certificates series 2006-GG7
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

HVB Mortgage Capital Corp.
Commercial mortgage pass-through certificates series 2003-FL1
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

JPMorgan Chase Commercial Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2001-CIBC3
                                 Rating
Class                    To                  From
C                        NR                  AA+ (sf)
D                        NR                  AA (sf)

LB-UBS Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2000-C4
                                 Rating
Class                    To                  From
D                        NR                  AAA (sf)

LB-UBS Commercial Mortgage Trust 2001-C3
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
B                        NR                  AAA (sf)

LB-UBS Commercial Mortgage Trust 2001-C7
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
H                        NR                  A- (sf)

LB-UBS Commercial Mortgage Trust 2002-C4
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
A-3                      NR                  AAA (sf)
A-4                      NR                  AAA (sf)
X-VF                     NR                  AAA (sf)

LB-UBS Commercial Mortgage Trust 2005-C1
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
X-CP                     NR                  AAA (sf)

Merrill Lynch Financial Assets Inc.
Commercial mortgage pass-through certificates series 2000-CANADA4
                                 Rating
Class                    To                  From
J                        NR                  B- (sf)

Merrill Lynch Floating Trust
Commercial mortgage pass-through certificates series 2006-1
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)
B                        NR                  AAA (sf)
C                        NR                  AAA (sf)
D                        NR                  AAA (sf)
E                        NR                  AA+ (sf)
F                        NR                  AA- (sf)
G                        NR                  A+ (sf)
H                        NR                  A (sf)
J                        NR                  A- (sf)
X-3A                     NR                  AAA (sf)

Morgan Stanley Capital I Trust 2003-TOP11
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
A3                       NR                  AAA (sf)

Morgan Stanley Dean Witter Capital 1 Trust 2000-LIFE1
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
F                        NR                  BB (sf)
G                        NR                  B+ (sf)

PNC Mortgage Acceptance Corp.
Commercial mortgage pass-through certificates series 2001-C1
                                 Rating
Class                    To                  From
B                        NR                  AAA (sf)

Prima Capital CDO 2005-1 Ltd.
Commercial real estate-collateralized debt obligations
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

Salomon Brothers Commercial Mortgage Trust 2001-C2
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
E                        NR                  AA (sf)
F                        NR                  A+ (sf)

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2004-C11
                                 Rating
Class                    To                  From
A-3                      NR                  AAA (sf)

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2005-C16
                                 Rating
Class                    To                  From
X-P                      NR                  AAA (sf)

Ratings Withdrawn Due To Repayment Of All Principal And Interest
Paying Classes Rated 'Aa- (Sf)' Or Higher

Banc of America Commercial Mortgage Inc.
Commercial mortgage pass-through certificates series 2000-1
                                 Rating
Class                    To                  From
X                        NR                  AAA (sf)

Citigroup Commercial Mortgage Trust 2007-FL3
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
X-2                      NR                  AAA (sf)

JPMorgan Chase Commercial Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2001-CIBC3
                                 Rating
Class                    To                  From
X-1                      NR                  AAA (sf)

LB-UBS Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2000-C4
                                 Rating
Class                    To                  From
X                        NR                  AAA (sf)

Merrill Lynch Floating Trust
Commercial mortgage pass-through certificates series 2006-1
                                 Rating
Class                    To                  From
X-1B                     NR                  AAA (sf)
X-3B                     NR                  AAA (sf)
X-3C                     NR                  AAA (sf)

Salomon Brothers Commercial Mortgage Trust 2001-C2
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
X1                       NR                  AAA (sf)

NR -- Not rated.


MID-ATLANTIC FREDERAL: Fitch Assigns Viability Rating at 'B'
------------------------------------------------------------
Fitch Ratings has affirmed the 'A+' long-term Issuer Default
Rating (IDR) and 'F1+' short-term IDR of Mid-Atlantic Corporate
Federal Credit Union (Mid-Atlantic) following the close of the
company's merger with VACORP Federal Credit Union (VACORP).  The
Rating Outlook is Stable.

Fitch's affirmation of the ratings reflects that Mid-Atlantic's
IDR is currently at its Support Rating floor. The 'b' Viability
rating denotes weak future prospects.  Material failure risk is
present, but a limited margin of safety remains.  The company's
capacity for continued unsupported operation is vulnerable to
deterioration in the business and economic environment.  In
Fitch's view the company continues to benefit from the government
support provided to the industry.  The ratings also reflect Mid-
Atlantic's stronger capital relative to other corporate credit
unions (CCUs).

Mid-Atlantic has met all the new regulatory capital requirements
due to its successful capital raising initiatives. Total capital
for the merged entity is about $176 million which includes
$16 million in retained earnings.  As of year-end 2011, Mid-
Atlantic's reported Tier 1 risk-weighted capital ratio of 19.18%
and Total risk-weighted capital ratio of 22.24% far exceeds the
new regulatory requirement of 4.00% and 8.00%, respectively.  The
leverage ratio of 5.38% also exceeded the required minimum of
4.00%.  At year end 2011, Mid-Atlantic's retained earnings ratio
of 0.47% slightly exceeds the 0.45% required minimum that CCUs
must meet by 2013.

Mid-Atlantic is ranked the 4th largest company in the CCU network
with total assets of approximately $4 billion and serves more than
850 members.  Headquartered in Middletown, PA, Mid-Atlantic
provides investment, lending and payment services including ACH,
share draft and electronic processing in 44 states.

Fitch affirms these ratings with a Stable Rating Outlook:

Mid-Atlantic Corporate Federal Credit Union

  -- Long-term IDR at 'A+';
  -- Short-term IDR at 'F1+';
  -- Viability at 'b';
  -- Support '1';
  -- Support Floor 'A+'.


MONTANA RE: S&P Raises Series 2010-1 Class C Note Rating to 'B'
---------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on Montana
Re Ltd.'s Series 2010-1 Class C notes to 'B(sf)' from 'CCC+(sf)',
and on the Class E notes to 'B-(sf)' from 'CCC(sf)'.

The upgrade puts the ratings back to where they were when the
transaction closed in December 2010.

"The Class E notes were downgraded to 'CCC(sf)' on June 14, 2011,
as a result of the Tohoku earthquake. Under the terms of the
transaction, the earthquake was determined to be a covered event
that put the Class E notes, which had been second-event notes (it
would take at least two covered events to result in a loss of
principal to note holders) on risk for a principal reduction upon
the occurrence of any future covered event. Because the initial
annual risk period expired without any subsequent covered events,
the Class E notes have returned to being second-event notes," S&P
said.

"The Class C notes were lowered to 'CCC+(sf)' on July 11, 2011.
This was the result of the update to the Risk Management Solutions
Inc. (RMS) RiskLink v11.0 U.S. hurricane model. RiskLink v11.0
indicated that the initial probability of attachment was greater
than indicated from RiskLink v10.0, which had been used to model
the transaction," S&P said.

"Pursuant to the terms of the issuance, if an updated model is
available for commercial use, it would replace the initial model.
As a result, RiskLink v11.0 was used for the initial reset. The
updated probability of attachment for the Class C notes is 5.27%,
and 6.02% for the Class E notes," S&P said.

"We base our ratings on the notes on the probability of attachment
in each year. Because we expect the actual results to differ from
the modeled results, we adjust the probability of attachment for
each class of notes in line with strengths and weaknesses
identified and then derive adjusted probabilities of attachment
for each class of notes," S&P said.

Ratings List
Ratings Raised               To              From
Montana Re Ltd.
Series 2010-1 Class C      B(sf)           CCC+(sf)
Series 2010-1 Class E      B-(sf)          CCC(sf)


MORGAN STANLEY: Fitch Affirms Junk Ratings on Four Note Classes
---------------------------------------------------------------
Fitch Ratings has upgraded three and affirmed four classes of
Morgan Stanley 2007-XLC1, Ltd./Morgan Stanley 2007XLC1, LLC
(Morgan Stanley 2007-XLC1) reflecting Fitch's base case loss
scenario loss expectation of 36.4%.  Fitch's performance
expectation incorporates prospective views regarding commercial
real estate market value and cash flow declines.

The upgrades to class A-2 thru C reflect improved credit
enhancement as a result of significant paydown to the
transaction's senior liabilities, including the full payment of
class A-1.  Since the last rating action, scheduled amortization,
property releases, partial paydowns related to loan modifications,
and the full payoff of three loans have resulted in total paydown
of over $195 million (17% of the original deal balance), as of the
January 2012 trustee report.  Further the CDO is failing its F/G/H
overcollateralization test resulting in the diversion of interest
payments for classes J and below toward principal of the senior
classes.

The portfolio is very concentrated with only 10 loans remaining.
Current collateralized debt obligation consists of mezzanine debt
(60.4%), A-notes (15.5%), and B-notes (12.9%).  After the most
recent trustee report was issued, an additional mezzanine loan
(6.6%) was wiped out by the severely distressed sale of the mall
property backing the loan.  The current percentage of defaulted
assets and Loans of Concern is 4.8% and 67.9%, respectively.

Under Fitch's methodology, approximately 88.8% of the portfolio is
modeled to default in the base case stress scenario, defined as
the 'B' stress.  In this scenario, the modeled average cash flow
decline is 6.7% from, generally, trailing 12-month second or third
quarter 2011.

The largest component of Fitch's base case loss expectation is a
mezzanine loan (24.3%) secured by interests in a portfolio of five
full-service hotels (1,910 keys) located in Stamford, CT; Sonoma,
CA; Norfolk, VA; Atlanta, GA; and Southfield, MI.  The hotels are
under the Marriott, Hilton, Sheraton, and Westin flags.  Due to
economic conditions, the portfolio has not performed up to
expectations.  Current cash flow does not support a stressed debt
service.  Fitch modeled a term default and substantial loss on
this position in its base case scenario.

The next largest component of Fitch's base case loss expectation
is an A-note secured by approximately 60 acres of land located in
Las Vegas, NV.  The property, which is in the process of being
master planned and rezoned for development, is currently comprised
of improved land with 457 apartments and 425,000 square feet of
office/industrial space, with 20 acres of vacant land.  Fitch
modeled a term default and significant loss on this position 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 tests to project future default levels
for the underlying portfolio.  Recoveries are based on stressed
cash flows and Fitch's long-term capitalization rtes.  The default
levels were then compared to the breakeven levels generated by
Fitch's cash flow model of the CDO under the various defaults
timing and interest rate stress scenarios as described in the
report 'Global Criteria for Cash Flow Analysis in CDOs'.  The
breakeven rates for classes A-2 thru C pass the cash flow model at
the ratings listed below.  Further, due to the concentrated nature
of the pool and significant percentage of defaulted assets and
Fitch Loans of Concern, Fitch performed additional sensitivity
analysis, which assumed all loans had a term default, as well as
applied additional cash flow stresses.  In this scenario, the
credit enhancement for classes A-2 thru C is consistent with the
ratings.

The Positive and Stable Outlooks on classes A-2 thru C reflect the
classes' senior position in the capital structure and the
substantial credit enhancement to the classes.

The 'CCC' ratings for classes D thru G are based on a
deterministic analysis that considers Fitch's base case loss
expectation for the pool and the current percentage of defaulted
assets and Fitch Loans of Concern, factoring in anticipated
recoveries relative to each classes' credit enhancement.

Fitch upgrades these classes and assign or revises Outlooks:

-- $89,922,416 class A-2 to 'BBBsf' from 'BBsf'; Outlook to
    Positive from Negative;
-- $58,613,508 class B to 'BBsf' from 'Bsf; Outlook to Stable
    from Negative;
-- $25,549,254 class C to 'Bsf' from 'CCCsf'; Outlook Stable.

In addition, Fitch affirms these classes:

-- $12,022,835 class D at 'CCCsf'; RE 100%;
-- $9,768,918 class E at 'CCCsf'; RE 100%;
-- $20,288,900 class F at 'CCCsf'; RE 0%;
-- $14,277,482 class G at ' CCCsf'; RE 0%

Class A-1 has paid in full.


MORGAN STANLEY: Fitch Places Rating on 8 Cert. Class at Low-B
-------------------------------------------------------------
Fitch Ratings has placed 10 classes of Morgan Stanley Capital
Trust I, series 2007-HQ12, commercial mortgage pass-through
certificates on Rating Watch Negative:

  -- $170.9 million class A-M 'BBB-sf';
  -- $25 million class A-MFL 'BBB-sf';
  -- $53 million class A-J 'B-sf';
  -- $91.4 million class A-JFL 'B-sf';
  -- $41.6 million class B 'B-sf';
  -- $22 million class C 'B-sf';
  -- $24.5 million class D 'B-sf';
  -- $14.7 million class E 'B-sf';
  -- $24.5 million class F 'B-sf';
  -- $22 million class G 'B-sf'.

The classes have been placed on Rating Watch Negative due to an
expectation for increased losses following updated valuations on
several specially serviced loans.

The largest specially serviced loan is the Beacon Seattle and DC
Portfolio (7% of the pool).  The pari passu loan transferred to
special servicing in April 2010 for imminent default; however, the
loan is currently performing under a modification agreement which
included a maturity extension to 2017 and incentives for the
borrower to sell the underlying properties to pay down the debt.
The loan has paid down 30% from the sale of six of the original 20
properties.

Fitch expects to resolve the Rating Watch status within the next
several months following a complete review of the transaction
including updated performance data for performing loans.
Following its review, the classes placed on Rating Watch Negative
may be downgraded several categories.


MORGAN STANLEY: S&P Cuts Rating on Class G Cert. to 'D'
-------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on six
classes of U.S. commercial mortgage-backed securities (CMBS) from
Morgan Stanley Capital I Trust 2006-IQ11. "In addition, we
affirmed our ratings on seven other classes from the same
transaction," S&P said.

"Our rating actions follow our analysis of the credit
characteristics of the collateral remaining in the pool, the
transaction structure, and the liquidity available to the trust.
The downgrades reflect credit support erosion that we anticipate
will occur upon the eventual resolution of 11 ($73.7 million,
5.7%) of the 13 ($139.3 million, 10.8%) assets that are with the
special servicers. We also considered monthly interest shortfalls
affecting the trust. We lowered our rating on the class G
certificate to 'D (sf)' because we believe the resulting
accumulated interest shortfalls will remain outstanding for the
foreseeable future," S&P said.

"The affirmed ratings on the principal and interest certificates
reflect subordination levels and liquidity that is consistent with
the outstanding ratings. We affirmed our 'AAA (sf)' rating on the
class X and X-Y interest-only (IO) certificate based on our
current criteria," S&P said.

"Using servicer-provided financial information, we calculated an
adjusted debt service coverage (DSC) of 1.40x and a loan-to-value
(LTV) ratio of 101.4% for the loans in the pool. We further
stressed the loans' cash flows under our 'AAA' scenario to yield a
weighted average DSC of 1.02x and an LTV ratio of 130.6%. The
implied defaults and loss severity under the 'AAA' scenario were
63.5% and 38.4%. All of the DSC and LTV calculations we exclude 11
($73.7 million, 5.7%) of the transaction's 13 ($139.3 million,
10.8%) specially serviced assets, as well as one defeased loan
($7.9 million, 0.6%). We separately estimated losses for the
specially serviced assets and included them in the 'AAA' scenario
implied default and loss severity figures," S&P said.

"As of the Jan. 17, 2012 trustee remittance report, the trust had
experienced net monthly interest shortfalls totaling $230,617.
The net interest shortfall amount primarily reflects appraisal
subordinate entitlement reduction (ASER) amounts totaling $96,748,
special servicing and workout fees of $64,943, and interest not
advanced in the amount of $75,593. The interest shortfalls
affected classes G through M. Class G experienced cumulative
interest shortfalls for two months, and we expect these interest
shortfalls to continue for the foreseeable future. Consequently,
we lowered our rating on the class G certificates to 'D (sf)'. We
previously lowered our ratings on classes H through O to 'D
(sf)'," S&P said.

                    Credit Considerations

"As of the Jan. 17, 2012 trustee remittance report, 13 assets
($139.3 million; 10.8%) in the pool were with the special
servicers, LNR Partners LLC (LNR) and National Consumer
Cooperative Bank, including one of the top 10 loans. None of the
66 cooperative apartment loans are with the special servicers.
The reported payment status of the specially serviced assets is:
three are real estate owned (REO; $25.5 million; 1.9%), seven
are 90-plus-days delinquent ($42.9 million; 3.3%), one is 30-
days delinquent ($5.3 million, 0.4%), and two are current
($65.6 million; 5.1%). Eight assets ($52.9 million, 4.1%)
have appraisal reduction amounts (ARAs) in effect totaling
$35.8 million," S&P said.

"The LeNature's Headquarters loan is the fourth-largest loan in
the pool ($54.4 million, 4.2%) and the largest loan with the
special servicers. The loan is secured by a 500,000-sq.-ft.
warehouse distribution facility in Phoenix, Ariz. The loan was
transferred to the special servicer on Nov. 9, 2006, because
LeNature, the sole tenant, filed for bankruptcy and subsequently
vacated the space. Subsequent to the bankruptcy filing of
LeNature, a data center operator signed a 20-year master lease for
100% of the space, which extends past the Jan. 5, 2016 maturity
date of the loan. The payment status of the loan is current and
the loan continues to perform in accordance with the executed
workout agreements. No recent financial information was available.
We expect a modest loss upon the resolution of this loan," S&P
said.

"The remaining 12 assets with the special servicers
($84.9 million; 6.6%) individually represent less than 1.1% of the
total pool balance. ARAs totaling $35.8 million are in effect for
eight of these assets. We estimated losses for 11 of the 12
assets, arriving at a weighted average loss severity of 53.4%,"
S&P said.

                      Transaction Summary

"As of the Jan. 17, 2012 trustee remittance report, the
transaction had an aggregate trust balance of $1.3 billion
and comprised 215 loans and three REO assets, compared with
$1.7 billion (232 loans) at issuance. The master servicers
for the transaction, Wells Fargo Bank N.A. (Wells Fargo) and
NCB, FSB (NCB), provided financial information for 89.0% of the
pool (by balance), which was primarily full-year 2010 or partial-
year 2011 data. We calculated a weighted-average DSC of 1.33x for
the assets in the pool based on the reported figures. Our adjusted
DSC and LTV figures were 1.40x and 101.4%, which excluded 11
($73.7 million, 5.7%) assets that are currently with the special
servicers and one ($7.9 million, 0.6%) defeased loan. The trust
has experienced principal losses to date totaling $27.4 million
on nine assets. Seventy-one loans ($413.9 million, 31.9%) are on
the master servicers' watchlist, including three of the top 10
loans ($133.5 million, 10.3%). Sixteen loans ($153.1 million,
11.8%) have reported DSCs between 1.00x and 1.10x, and 43 loans
($138.8 million, 10.7%) have reported DSCs of less than 1.00x,"
S&P said.

            Summary of Top 10 Assets Secured By Real Estate

"The top 10 assets secured by real estate have an aggregate
outstanding trust balance of $412.0 million (31.8%). Using
servicer-reported information, we calculated a weighted-average
DSC of 1.26x for nine of the top 10 assets. The remaining top 10
asset ($54.4 million, 4.2%) is in special servicing. Our adjusted
DSC and LTV figures for nine of the top 10 assets, excluding the
specially serviced loan, were 1.44x and 116.2%,. Three of the top
10 assets ($133.5 million, 10.3%) are on the master servicers'
watchlist," S&P said.

"The Crossroads Tower Office Building loan ($57.4 million, 4.4%)
is the second-largest asset secured by real estate in the pool.
The loan is secured by a 485,544-sq.-ft. office building in Kew
Gardens, N.Y., which was built in 1989. The loan is on Well's
Fargo's watchlist due to deferred maintenance. According to
Wells Fargo, the exterior of the building is currently being
waterproofed. As of the nine months ended Sept. 30, 2011, the
reported DSC was 1.12x; occupancy as of Nov. 21, 2011, was 99.0%,"
S&P said.

"The Merritt Square Mall loan ($55.9 million, 4.3%), the third-
largest asset in the pool, is secured by 478,040 sq. ft. of an
807,787-sq.-ft. regional mall in Merritt Island, Fla., which was
built in 1970 and renovated in 2004. The loan is on Wells Fargo's
watchlist due to low DSC. As of the year-ended Dec. 31, 2010, the
reported DSC was 1.05x; occupancy as of June 30, 2011, was 87.0%,"
S&P said.

"The Waianae Mall ($20.1 million, 1.6%), the ninth-largest loan in
the pool, is secured by a 168,263-sq.-ft. retail center in
Waianae, Hawaii. The loan is on Wells Fargo's watchlist due to
major deferred maintenance at the property. The reported DSC was
1.65x as of year-end Dec. 31, 2010, and the occupancy was as
81.0% of June 30, 2011," S&P said.

"Standard & Poor's stressed the assets in the pool according to
our criteria and the resultant credit enhancement levels are
consistent with our lowered and affirmed ratings," S&P said.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

              http://standardandpoorsdisclosure-17g7.com

Ratings Lowered

Morgan Stanley Capital I Trust 2006-IQ11
Commercial mortgage pass-through certificates
          Rating
Class   To         From           Credit enhancement (%)
B       BB+ (sf)   BBB (sf)                         9.11
C       BB  (sf)   BBB-(sf)                         8.17
D       B  (sf)    BB+(sf)                          6.46
E       B- (sf)    BB (sf)                          5.21
F       CCC- (sf)  B-(sf)                           4.12
G       D  (sf)    CCC-(sf)                         2.72

Ratings Affirmed

Morgan Stanley Capital I Trust 2006-IQ11
Commercial mortgage pass-through certificates

Class     Rating   Credit enhancement (%)
A-1A      AAA (sf)                  35.29
A-3       AAA (sf)                  35.29
A-4       AAA (sf)                  35.29
A-M       AA- (sf)                  22.82
A-J       BBB+(sf)                  11.45
X         AAA (sf)                    N/A
X-Y       AAA (sf)                    N/A

N/A -- Not applicable.


MORGAN STANLEY: S&P Lowers Class F Cert. Rating to 'D'
------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on five
classes of commercial mortgage pass-through certificates from
Morgan Stanley Capital I Trust 2007-IQ13, a U.S. commercial
mortgage-backed securities (CMBS) transaction. "Concurrently,
we affirmed our ratings on nine other classes from the same
transaction," S&P said.

"The downgrades primarily reflect credit support erosion that we
anticipate will occur upon the eventual resolution of the
transaction's 14 ($215.9 million, 15.5%) assets with the special
servicer, and a reduction in liquidity support available to the
subject classes due to interest shortfalls. As of the revised
Jan. 19, 2012 trustee remittance report, the trust experienced a
monthly interest shortfall of $272,084, primarily due to appraisal
subordinate entitlement reduction (ASER) amounts ($162,831) and
special servicing fees ($82,577). The net interest shortfalls
affected all classes subordinate to and including class F. Our
analysis indicated that the total anticipated recurring monthly
interest shortfalls will cause continued interest shortfalls for
class F and the classes subordinate to it for the foreseeable
future, and lead to a reduction in the liquidity support available
to the classes senior to it. As a result of our analysis, we
lowered our rating on class F to 'D (sf)'. We previously lowered
our ratings on classes G through L, N, and O to 'D (sf)'," S&P
said.

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

"Our analysis of the transaction included a review of the credit
characteristics of all of the remaining assets in the pool and
the transaction structure. Using servicer-provided financial
information, we calculated an adjusted debt service coverage (DSC)
of 1.20x and a loan-to-value (LTV) ratio of 133.9%. We further
stressed the loans' cash flows under our 'AAA' scenario to yield a
weighted average DSC of 0.75x and an LTV ratio of 183.3%. The
implied defaults and loss severity under the 'AAA' scenario were
82.3% and 43.9%. The DSC and LTV calculations noted above exclude
the transaction's 14 ($215.9 million, 15.5%) specially serviced
assets, 38 ($124.2 million, 8.9%) loans secured by cooperative
housing (COOP) properties, and one ($43.0 million, 3.1%) defeased
loan. We separately estimated losses for the specially serviced
assets and included them in our 'AAA' scenario implied default and
loss severity figures. The COOP loans did not default under our
'AAA' scenario due to extremely low leverage," S&P said.

                    Credit Considerations

"As of the revised Jan. 19, 2012 trustee remittance report,
13 ($213.0 million, 15.3%) assets in the pool were with the
special servicer, LNR Partners LLC (LNR). Additionally, the
610 E. Stoughton Student Housing loan ($2.9 million, 0.2%)
was transferred to the special servicer after the January
reporting date due to payment default. The reported payment
status of the specially serviced assets is as follows: five
are real estate-owned (REO) ($66.0 million, 4.7%), one is
in foreclosure ($8.6 million, 0.6%), three are 90-plus-days
delinquent ($20.6 million, 1.5%), one is 60 days delinquent
($2.9 million, 0.2%), two are 30 days delinquent ($25.5 million,
1.8%), and two are matured balloon loans ($92.3 million, 6.6%).
Appraisal reduction amounts (ARAs) totaling $31.0 million are in
effect for seven of the specially serviced assets," S&P said.

"The St. Louis Mills loan ($90.0 million, 6.5%) is the third-
largest loan in the pool and the largest specially serviced asset.
The loan is secured by the fee interest in a shopping mall
totaling 1.2 million sq. ft. in Hazelwood, Mo. The loan, which was
reported as a matured balloon loan, was transferred to the special
servicer on Oct. 24, 2011, due to imminent maturity default," S&P
said.

"According to the special servicer, a loan modification is under
consideration, the terms of which were not disclosed. As of year-
end 2010, the reported DSC was 1.24x. As of March 2011, reported
occupancy was 78.0%. We expect a moderate loss upon the eventual
resolution of this asset," S&P said.

"The Northridge I REO asset ($27.4 million, 2.0%) is the sixth-
largest asset in the pool and the second-largest specially
serviced asset and is collateralized by an office building
totaling 123,208 sq. ft. in Herndon, Va. The loan was transferred
to the special servicer on Feb. 17, 2010, due to imminent default
and subsequently became REO. According to the special servicer, a
potential new lease is currently being negotiated. As of year-end
2010, the reported DSC and occupancy were 1.12 and 80%. An ARA of
$9.9 million is in effect against this asset. We expect a
significant loss upon the eventual resolution of this asset," S&P
said.

"The Plaza Continental loan ($21.0 million, 1.5%) is the 10th-
largest loan in the pool and the third-largest specially serviced
asset. The loan is collateralized by a retail shopping center
totaling 119,898 sq. ft. in Ontario, Calif. The loan was
transferred to the special servicer on July 27, 2010, due to a
change in the property management company and a transfer of
ownership without lender consent. According to the special
servicer, a receiver was put in place on Nov. 19, 2011. As of
October 2011, the reported DSC was 0.13x. We expect a moderate
loss upon the eventual resolution of this asset," S&P said.

"The remaining 11 specially serviced assets have balances that
individually represent less than 1.1% of the total pool balance.
ARAs totaling $21.1 million are in effect against six of these
assets. We estimated losses for all of these assets, arriving at a
weighted average loss severity of 32.4%," S&P said.

                      Transaction Summary

As of the revised Jan. 19, 2012 trustee remittance report, the
total pool balance was $1.39 billion, which is 84.9% of the pool
balance at issuance.

The pool includes 158 loans and five REO assets, down from 174
loans at issuance. The master servicers, Wells Fargo Bank N.A. and
NCB, FSB, provided financial information for 86.0% of the assets
in the pool, the majority of which was full-year 2010 data (53.1%)
or September 2011 data (28.4%).

"We calculated a weighted average DSC of 1.20x for the assets in
the pool based on the servicer-reported figures. Our adjusted DSC
and LTV ratio were 1.20x and 133.9%. Our adjusted DSC and LTV
figures exclude the transaction's 14 ($215.9 million, 15.5%)
specially serviced assets, 38 ($124.2 million, 8.9%) loans secured
by COOP properties, and one ($43.0 million, 3.1%) defeased loan.
Recent financial reporting information was available for nine
of the excluded specially serviced assets, which exhibited a
reported weighted average DSC of 1.07x. To date, the transaction
has experienced $43.2 million in principal losses in connection
with 10 assets. Thirty-seven loans ($209.2 million, 15.0%) in the
pool are on the master servicers' combined watchlist. Forty-four
assets ($432.9 million, 31.1%) have a reported DSC of less than
1.10x, 35 of which ($381.3 million, 27.4%) have a reported DSC of
less than 1.00x," S&P said.

           Summary of Top 10 Assets Secured By Real Estate

"The top 10 assets secured by real estate have an aggregate
outstanding balance of $605.8 million (43.5%). Using servicer-
reported numbers, we calculated a weighted average DSC of 1.07x
for the top 10 assets. Our adjusted DSC and LTV ratio for the top
10 assets were 0.93x and 166.7%. Three of the top 10 assets
($138.4 million, 9.9%) are with the special servicer, and are
discussed above. In addition, the United Investors Portfolio Roll-
Up loan ($21.5 million, 1.5%, ninth-largest loan in the pool)
appears on the master servicer's watchlist. The loan is secured by
a seven-property portfolio containing both multifamily and retail
properties in Illinois. The loan appears on the master servicer's
watchlist for low DSC. As of September 2011, reported consolidated
DSC was 0.94x, while the most recent reported consolidated
occupancy was 76.8%," S&P said.

"Standard & Poor's stressed the assets in the pool according to
its current criteria. The resultant credit enhancement levels are
consistent with our rating actions," S&P said.

             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 Represent ations,
warranties and enforcement mechanisms in issuances of similar
securities. The Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Reports
included in this credit rating report are available at:

             http://standardandpoorsdisclosure-17g7.com

Ratings Lowered

Morgan Stanley Capital I Trust 2007-IQ13
Commercial mortgage pass-through certificates

                Rating
Class      To           From        Credit enhancement (%)
B          B (sf)       B+ (sf)                        7.35
C          B- (sf)      B (sf)                         6.17
D          CCC+ (sf)    B (sf)                         4.99
E          CCC- (sf)    B (sf)                         3.96
F          D (sf)       CCC- (sf)                      2.64

Ratings Affirmed

Morgan Stanley Capital I Trust 2007-IQ13
Commercial mortgage pass-through certificates

Class    Rating                      Credit enhancement (%)
A-1      AAA (sf)                                     32.22
A-2      AAA (sf)                                     32.22
A-3      AAA (sf)                                     32.22
A-4      A-(sf)                                       32.22
A-1A     A- (sf)                                      32.22
A-M      BB+ (sf)                                     20.45
A-J      B+ (sf)                                       9.70
X        AAA (sf)                                       N/A
X-Y      AAA (sf)                                       N/A

N/A -- Not applicable.


MORGAN STANLEY: S&P Withdraws 'CCC-' Class I Note Rating
--------------------------------------------------------
Standard & Poor's Ratings Services withdrew its rating on the
class I notes issued by Morgan Stanley ACES SPC's series 2006-31,
a synthetic corporate investment-grade collateralized debt
obligation (CDO) transaction  The rating withdrawal follows
the cancellation of the notes.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

             http://standardandpoorsdisclosure-17g7.com

Rating Withdrawn

Morgan Stanley ACES SPC
Series 2006-31

             Rating
Class      To      From
I          NR      CCC-(sf)

NR -- Not rated.


MOUNTAIN VIEW: S&P Raises Class E Rating From 'CCC+' to 'B+'
------------------------------------------------------------
"We raised our ratings on Mountain View CLO III Ltd. on Feb. 9,
2012, and we raised our ratings on Stone Tower CLO III Ltd. on
Feb. 10, 2012. Due to an error, the ratings on both transactions
were inadvertently lowered and placed on CreditWatch positive on
Feb. 10, 2012," S&P said.

             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 Represent actions,
warranties and enforcement mechanisms in issuances of similar
securities. The Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Reports
included in this credit rating report are available at:

            http://standardandpoorsdisclosure-17g7.com

Ratings Corrected

Mountain View CLO III Ltd.
                            Rating
Class               To                    From
A-2                 AA+ (sf)              AA (sf)/Watch Pos
B                   AA (sf)               A+ (sf)/Watch Pos
C                   A (sf)                BBB+ (sf)/Watch Pos
D                   BBB (sf)              BB+ (sf)/Watch Pos
E                   B+ (sf)               CCC+ (sf)/Watch Pos

Stone Tower CLO III Ltd.
                            Rating
Class               To                    From
A-1                 AAA (sf)              AA+ (sf)/Watch Pos
A-2                 AAA (sf)              AA+ (sf)/Watch Pos
A-3                 AA+ (sf)              AA- (sf)/Watch Pos
B                   A+ (sf)               A- (sf)/Watch Pos
C-1                 BBB- (sf)             BB+ (sf)/Watch Pos
C-2                 BBB- (sf)             BB+ (sf)/Watch Pos
D-1                 B+ (sf)               CCC+ (sf)/Watch Pos
D-2                 B+ (sf)               CCC+ (sf)/Watch Pos


MOUNTAIN VIEW: S&P Raises Rating on Class E Notes to 'B+'
---------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-2, B, C, D, and E notes from Mountain View CLO III Ltd., a U.S.
collateralized loan obligation (CLO) transaction managed by Seix
Advisors. "At the same time, we affirmed our rating on the class
A-1 notes," S&P said.

"The transaction, which is still in its reinvestment period
(ending April 2014), has fewer defaulted assets in its collateral
pool and stronger credit quality than when we lowered our ratings
on the notes in December 2009 following the application of our
September 2009 corporate collateralized debt obligation (CDO)
criteria," S&P said.

"Based on the January 2012 monthly trustee report, the
transaction's asset portfolio had $4.2 million of defaulted
assets, down from $23.1 million in the October 2009 monthly
report, which we used for our December 2009 rating actions. Since
that time, the transaction has sold many of the defaulted assets
at prices that were higher than the assumed recover rates, which
contributed to an improvement in the transaction's par value
(overcollateralization) tests," S&P said.

The trustee reported the par value ratios in the January 2012
monthly report:

    The class A/B par value ratio was 124.01%, compared with a
    reported ratio of 121.90% in October 2009;

    The class C par value ratio was 115.03%, compared with a
    reported ratio of 113.08% in October 2009;

    The class D par value ratio test was 108.92%, compared with a
    reported ratio of 107.07% in October 2009; and

    The class E par value ratio test was 105.65%, compared with a
    reported ratio of 103.86% in October 2009.

"In addition, the credit quality of the collateral also improved
during this period. The January 2012 trustee report indicates that
the transaction had $12.23 million of assets rated in the 'CCC'
category, down from $36.67 million in October 2009," S&P said.

"We raised our ratings on the class A-2, B, C, D, and E due to an
increase in the credit support available to them. The affirmed
rating on the class A-1 notes reflects our opinion that the credit
support available at the current rating level is sufficient," S&P
said.

"The obligor concentration supplemental test (which is part of our
criteria for rating corporate CDO transactions) affected our
rating on the class E notes," 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.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

             http://standardandpoorsdisclosure-17g7.com

Rating And Creditwatch Actions

Mountain View CLO III Ltd.
                        Rating
Class              To           From
A-2                AA+ (sf)     AA (sf)
B                  AA (sf)      A+ (sf)
C                  A (sf)       BBB+ (sf)
D                  BBB (sf)     BB+ (sf)
E                  B+ (sf)      CCC+ (sf)

Rating Affirmed

Mountain View CLO III Ltd.
Class              Rating
A-1                AAA (sf)


MOUNTAIN VIEW: S&P Upgrades Rating on Class E Notes to 'B+'
-----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1, A-2, A-3, B, C, D, and E notes from Mountain View CLO II
Ltd., a U.S. collateralized loan obligation (CLO) transaction
managed by Seix Advisors. "At the same time, we removed our
ratings on these classes from CreditWatch, where we placed them
with positive implications on Dec. 20, 2011," S&P said.

"The upgrades reflect improved credit performance we have
observed in the transaction's underlying asset portfolio since we
last downgraded the classes on Dec. 11, 2009. As of the Jan. 5,
2012, trustee report, the transaction's asset portfolio had
$4.95 million in defaulted obligations and approximately
$20.01 million in assets from obligors rated in the 'CCC' range.
This was down from $18.66 million in defaulted obligations and
approximately $53.46 million in assets from obligors rated in the
'CCC' range noted in the Oct. 30, 2009 trustee report, which we
used for our December 2009 rating actions," S&P said.

"We also observed an increase in the overcollateralization (O/C)
available to support the rated notes," S&P said. The trustee
reported the O/C ratios in the Jan. 5, 2012, monthly report:

    The A/B O/C ratio was 121.32%, compared with a reported ratio
    of 119.27% in October 2009;

    The C O/C ratio was 113.87%, compared with a reported ratio of
    111.93% in October 2009;

    The D O/C ratio was 108.42%, compared with a reported ratio of
    106.58% in October 2009; and

    The E O/C ratio was 104.68%, compared with a reported ratio of
   102.91% in October 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.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

           http://standardandpoorsdisclosure-17g7.com


Rating And Creditwatch Actions

Mountain View CLO II Ltd.
                        Rating
Class              To           From
A-1                AA+ (sf)     AA (sf)/Watch Pos
A-2                AA+ (sf)     AA (sf)/Watch Pos
A-3                AA+ (sf)     AA (sf)/Watch Pos
B                  AA- (sf)     A+ (sf)/Watch Pos
C                  A (sf)       BBB+ (sf)/Watch Pos
D                  BBB- (sf)    BB+ (sf)/Watch Pos
E                  B+ (sf)      CCC- (sf)/Watch Pos


MYSTIC RE: S&P Gives 'BB' Rating on Class A Notes
-------------------------------------------------
Standard & Poor's Ratings Services assigned preliminary ratings of
'BB(sf)' and 'B(sf)' to the Series 2012-1 Class A and Class B
notes, , to be issued by Mystic Re III Ltd. The notes cover losses
from hurricanes and earthquakes on a per-occurrence basis in the
covered area.

"Our view of the transaction's credit risk reflects the
counterparty credit ratings on all of the parties involved that
can affect the timely payment of interest and the ultimate payment
of principal on the notes. Our preliminary ratings on the notes
take into account the rating on Liberty Mutual Insurance Co.,
which will make quarterly premium payments to Mystic Re III; the
implied rating on the catastrophe risk ('BB' for the Class A notes
and 'B' for the Class B notes); and the rating on the assets in
the collateral account ('AAAm'). The preliminary ratings reflect
the lower of these three ratings, which for each class of notes is
the implied rating on the catastrophe risk," S&P said.

Mystic Re III, a Cayman Islands exempted company licensed as a
Class B Insurer, is seeking to raise money to collateralize two
reinsurance agreements with Liberty Mutual Insurance Co.

Ratings List
Preliminary Ratings Assigned
Mystic Re III Ltd.
  Series 2012-1 Class A Notes               BB(sf)
  Series 2012-1 Class B Notes               B(sf)


N-45 2003-1: Moody's Raises Rating of Cl. F Notes to 'B1'
---------------------------------------------------------
Moody's upgraded the ratings of three classes and affirmed four
classes of N-45 First CMBS Issuer Corporation, Commercial Mortgage
Bonds, Series 2003-1:

Cl. A-2, Affirmed at Aaa (sf); previously on Jun 18, 2003
Definitive Rating Assigned Aaa (sf)

Cl. B, Affirmed at Aaa (sf); previously on Dec 21, 2006 Upgraded
to Aaa (sf)

Cl. C, Affirmed at Aaa (sf); previously on Mar 4, 2010 Upgraded to
Aaa (sf)

Cl. D, Upgraded to Aa2 (sf); previously on Mar 4, 2010 Upgraded to
A1 (sf)

Cl. E, Upgraded to Baa2 (sf); previously on Apr 11, 2008 Upgraded
to Ba1 (sf)

Cl. F, Upgraded to B1 (sf); previously on Jun 18, 2003 Definitive
Rating Assigned B2 (sf)

Cl. IO, Affirmed at Aaa (sf); previously on Jun 18, 2003
Definitive Rating Assigned Aaa (sf)

RATINGS RATIONALE

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

Moody's rating action reflects a cumulative base expected loss of
1.7% of the current balance compared to 2.2% at last review.
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 extent of the
slowdown in growth in the current macroeconomic environment and
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 in
recovery and improvements in the office sector continue, with
fundamentals in Gateway cities outperforming their suburban
counterparts. However, office demand is closely tied to
employment, where fundamentals remain weak, so significant
improvement may be delayed. Performance in the retail sector has
been mixed with on-going rent deflation and leasing challenges.
Across all property sectors, the availability of debt capital
continues to improve with monetary policy expected to remain
supportive and interest rate hikes postponed. Moody's central
global macroeconomic scenario reflects an overall downward
revision of forecasts since last quarter, amidst ongoing fiscal
consolidation efforts, household and banking sector deleveraging,
persistently high unemployment levels, and weak housing markets
that will continue to constrain growth.

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

Moody's noted that on November 22, 2011, it released a Request for
Comment, in which the rating agency has requested market feedback
on potential changes to its rating methodology for Interest-Only
Securities. If the revised methodology is implemented as proposed
the rating on N-45, First CMBS Issuer Corporation, Commercial
Mortgage Bonds, Series 2003-1, Class IO may be negatively
affected. Please refer to Moody's request for Comment, titled
"Proposal Changing the Global Rating Methodology for Structured
Finance Interest-Only Securities," for further details regarding
the implications of the proposed methodology change on Moody's
rating.

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 pay down analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Moody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade credit estimates is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
underlying rating of the loan which corresponds to a range of
credit enhancement levels. Actual fusion credit enhancement levels
are selected based on loan level diversity, pool leverage and
other concentrations and correlations within the pool. Negative
pooling, or adding credit enhancement at the underlying rating
level, is incorporated for loans with similar credit estimates in
the same transaction.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 4, down from 6 at last 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 8.2 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 February 16, 2011.

DEAL PERFORMANCE

As of the January 16, 2012 distribution date, the
transaction's aggregate certificate balance has decreased by 77%
to $129.7 million from $559.7 million at securitization. The most
recent remittance statement does not reflect an additional $1.4
million payoff of a mortgage loan that occured subsequent to the
cut-off date for that report. The Certificates are collateralized
by 12 mortgage loans which range in size from less than 1% to 42%
of the pool, with the top ten loans representing 93% of the pool
(excluding defeasance). No loans have credit estimates. One loan,
representing 7% of the pool, has defeased and is collateralized by
Canadian Government securities.

One loan, representing 0.3% of the pool, is on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, Moody's reviews the
watchlist to assess which loans have material issues that could
impact performance. Moody's has assumed a high default probability
for the watchlisted loan and has estimated a $170,000 loss (37.5%
expected loss based on a 75% probability default) from this
troubled loan.

No loans have been liquidated from the pool since securitization.
There are currently no loans in special servicing.

Moody's was provided with full year 2010 operating results for
100% of the pool.

Moody's weighted average LTV is 57% compared to 59% at Moody's
prior review. Moody's net cash flow reflects a weighted average
haircut of 24.3% to the most recently available net operating
income. Moody's value reflects a weighted average capitalization
rate of 9.6%.

Moody's actual and stressed DSCRs are 1.47X and 1.95X,
respectively, compared to 1.38X and 1.78X at last review. Moody's
actual DSCR is based on Moody's net cash flow (NCF) and the loan's
actual debt service. Moody's stressed DSCR is based on Moody's NCF
and a 9.25% stressed rate applied to the loan balance.

The top three conduit loans represent 64% of the pool balance.
The largest loan is the State Street Financial Centre Loan
($54.4 million -- 42%), which is secured by a 413,937 square foot
Class A office building located in Toronto, Ontario. The property
was 94% leased as of March 2011 compared to 100% at last review.
Year-end 2010 financial statements reflected stronger financial
performance than in 2009. Moody's anticipates that 2011 year-end
financials will reflect the decline in occupancy which has been
partly offset by 3% amortization since last review. Moody's LTV
and stressed DSCR are 61% and 1.63X, respectively, compared to 61%
and 1.48X at last review.

The second largest loan is the 180 Duncan Mill Road Loan
($14.5 million -- 11.3%), which is secured by a 146,300 square
foot office building located in Toronto, Ontario. The property was
100% leased as of May 2011 compared to 85% leased as of February
2011. Despite higher reported occupancy, property performance has
been stable since last review due to lower current market rents.
Moody's LTV and stressed DSCR are 67% and 1.54X, respectively,
compared to 72% and 1.28X at last review.

The third largest loan is the Zellers Centre Loan ($13.7 million -
- 10.7%), which is secured by a 1,092,673 square foot industrial
complex located in Brampton, Ontario. The property is 100% leased
to the Hudson's Bay Company through February 2013. Moody's
stressed the cash flow due to concerns about single tenant
occupancy and the near-term lease expiration. Moody's LTV and
stressed DSCR are 63% and 1.72X, respectively, compared to 54% and
1.02X at last review.


N-STAR CDO: S&P Lowers Rating on Class C-2 Notes to 'CCC'
---------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on nine
classes of notes from N-Star Real Estate CDO I Ltd., a U.S.
collateralized debt obligation transaction backed primarily by
commercial mortgage-backed securities (CMBS) and real estate
investment trust (REIT) debt, and removed them from CreditWatch
with negative implications. "We also affirmed our rating on the
class A-1 notes from the same transaction," S&P said.

"The downgrades primarily reflect deterioration in the credit
profile of the assets available to support the notes since our
June 2011 rating actions, when we lowered our ratings on the C-2,
D-1A, and D-1B notes. As of the Dec. 30, 2011 trustee report, the
transaction held $27.8 million in defaulted assets. This was up
from the $19.0 million in defaulted assets noted in the March 2011
trustee report, which we referenced for our June 2011 rating
actions. Also, the transaction held $16.6 million in assets from
underlying obligors with ratings in the 'CCC' range, compared with
the $10.7 million held in March 2011," S&P said.

The deterioration in asset credit quality has been detrimental
to the transaction's overcollateralization (O/C) and interest
coverage (I/C) ratios. As of Dec. 30, 2011, the transaction's O/C
and I/C ratios have decreased since March 2011:

    The class A O/C ratio is 146.1%, compared with 148.4%;
    The class B O/C ratio is 121.8%, compared with 126.6%;
    The class C O/C ratio is 98.4%, compared with 105.0%;
    The class D O/C ratio is 91.1%, compared with 98.1%;
    The class A I/C ratio is 143.8%, compared with 256.0%;
    The class B I/C ratio is 113.1%, compared with 149.5%;
    The class C I/C ratio is 61.0%, compared with 79.7%; and
    The class D I/C ratio is 54.5%, compared with 71.6%.

The class C and D notes are failing O/C and I/C tests and the
class C-1, C-2, and D-1 notes have capitalized deferred interest
as of December 2011.

On the Nov. 15, 2011 payment date, the transaction paid interest
due on the B-1 and B-2 notes with principal proceeds. Using
principal proceeds increases the risk of an interest shortfall
because the notes are relying on the availability of unscheduled
principal proceeds for their interest payments.

"We downgraded the class D-1A and D-1B notes to 'CC (sf)' to
reflect our opinion that the transaction has insufficient
collateral to repay the full principal amount currently due," S&P
said.

"Finally, we affirmed our rating on the class A-1 notes to reflect
the availability of credit support at the current rating level,"
S&P said.

"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 said.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

            http://standardandpoorsdisclosure-17g7.com

Rating And Creditwatch Actions

N-Star Real Estate CDO I Ltd.
                              Rating
Class                   To           From
A-2A                    AA (sf)      AAA (sf)/Watch Neg
A-2B                    AA (sf)      AAA (sf)/Watch Neg
B-1                     BB+ (sf)     A (sf)/Watch Neg
B-2                     BB (sf)      A- (sf)/Watch Neg
C-1A                    BB- (sf)     BBB+ (sf)/Watch Neg
C-1B                    BB- (sf)     BBB+ (sf)/Watch Neg
C-2                     CCC (sf)     BB+ (sf)/Watch Neg
D-1A                    CC (sf)      CCC- (sf)/Watch Neg
D-1B                    CC (sf)      CCC- (sf)/Watch Neg

Rating Affirmed
N-Star Real Estate CDO I Ltd.

Class                   Rating
A-1                     AAA (sf)


N-STAR REAL: Fitch Lowers Rating on Four Note Classes
-----------------------------------------------------
Fitch Ratings has downgraded four and affirmed six classes
issued by N-Star Real Estate CDO I, Ltd. (N-Star CDO I).  The
affirmations to the senior notes are a result of delevering of the
capital structure.  Alternatively, the downgrades are a result of
negative credit migration.

Since Fitch's last rating action in March 2011, approximately
22.3% of the collateral has been downgraded and 11.6% has been
upgraded.  Currently, 45.5% of the portfolio has a Fitch derived
rating below investment grade, and 13.7% has a rating in the 'CCC'
category and below, compared to 31% and 12.7%, respectively, at
the last rating action.  Over this period, the percentage of
collateral experiencing interest shortfalls has increased to
22.3% from 12.7%.  Additionally, the class A-1 notes have received
$19.8 million in paydowns since the last rating action for a total
of $189 million in principal repayment since issuance.

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.  The breakeven rates in Fitch's cash flow model for
the class A though C-2 notes are generally consistent with the
ratings assigned below.

For the class D 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 D
notes have been affirmed at 'Csf', indicating that default is
inevitable.  The class C and D notes are currently receiving
interest paid in kind (PIK) whereby the principal amount of the
notes is written up by the amount of interest due.

The Stable Outlook on the class A-1 notes is primarily driven by
Fitch's view that the notes will continue to delever.  The
Negative Outlook on the class A-2 through C-1 notes reflects the
minimal cushion in the modeling results. Fitch does not assign
Outlooks to classes rated 'CCC' and below.

N-Star CDO I is a cash flow collateralized debt obligation (CDO),
which closed Aug. 21, 2003.  The collateral is composed of 66.3%
CMBS, 22.7% real estate investment trusts (REIT), 9.1% of SF CDOs,
and the remaining 1.9% of commercial real estate loans (CREL).
The transaction is collateralized by 43 assets from 41 obligors.
Fitch notes that the class B-1 notes are non-deferrable, while
junior in priority to the class A OC test in the waterfall.

Fitch has taken these actions:

  -- $61,013,011 class A-1 notes affirmed at 'AAAsf'; Outlook
     Stable;
  -- $45,000,000 class A-2A notes affirmed at 'AAsf'; Outlook
     Negative;
  -- $15,000,000 class A-2B notes affirmed at 'AAsf'; Outlook
     Negative;
  -- $15,000,000 class B-1 notes affirmed at 'Asf'; Outlook
     Negative;
  -- $10,000,000 class B-2 notes downgraded to 'BBBsf' from 'Asf';
     Outlook Negative;
  -- $5,041,948 class C-1A notes downgraded to 'BBsf' from
     'BBBsf'; Outlook Negative;
  -- $5,096,200 class C-1B notes downgraded to 'BBsf' from
     'BBBsf'; Outlook Negative;
  -- $24,420,540 class C-2 notes downgraded to 'CCCsf' from 'Bsf';
  -- $10,198,058 Class D-1A notes affirmed at 'Csf';
  -- $4,123,976 Class D-1B notes affirmed at 'Csf'.


NANTUCKET CLO: S&P Raises Rating on Class E Notes to 'B+'
---------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
C, D, and E notes from Nantucket CLO I Ltd., a collateralized loan
obligation (CLO) transaction managed by Fortis Investment
Management USA Inc. "We also affirmed our ratings on the class A
and B notes. At the same time, we removed our ratings on the class
B, C, D, and E notes from CreditWatch, where we placed them with
positive implications on Dec. 20, 2011," S&P said.

"The upgrades reflect the improved performance we have observed in
the deal's underlying asset portfolio since our December 2009
rating actions. According to the Dec. 30, 2011 trustee report, the
transaction's asset portfolio did not hold any defaulted assets,
down from the $5.8 million noted in the October 2009 trustee
report. Additionally, about 1.4% of the collateral pool consisted
of assets from obligors rated in the 'CCC' category in December
2011, down from about 7.7% million in October 2009," S&P said.

"We affirmed our ratings on the class A and B notes to reflect the
sufficient credit support available at the classes' current rating
levels," 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.

             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 Represent actions,
warranties and enforcement mechanisms in issuances of similar
securities. The Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Reports
included in this credit rating report are available at:

             http://standardandpoorsdisclosure-17g7.com

Rating And Creditwatch Actions

Nantucket CLO I Ltd.
                         Rating
Class                To           From
B                    AA (sf)      AA (sf)/Watch Pos
C                    A (sf)       A- (sf)/Watch Pos
D                    BBB- (sf)    BB+ (sf)/Watch Pos
E                    B+ (sf)      CCC- (sf)/Watch Pos

Rating Affirmed

Nantucket CLO I Ltd.
Class                Rating
A                    AA+ (sf)


NAUTIQUE FUNDING: S&P Raises Rating on Class D Notes to 'BB-'
-------------------------------------------------------------
Standard and Poor's Ratings Services raised its ratings on eight
classes of notes from Nautique Funding Ltd., a collateralized loan
obligation (CLO) managed by INVESCO Senior Secured Management
Inc., and removed two of the ratings from CreditWatch positive.
"We also affirmed our rating on the class A-2A notes," S&P said.

"The upgrades reflect improvements in the overcollateralization
(O/C) available to support the rated notes and in the credit
quality of the transaction's underlying asset portfolio since
we last initiated rating actions on this transaction in January
2010. As of the January 2012 trustee report, the class A O/C
ratio had increased to 124.35% from 118.66% in December 2009 and
the balance of defaulted assets had declined to $3.21 million from
$29.79 million," S&P said.

"The rating affirmation on class A-2A reflects the availability of
sufficient credit support at the current rating level. We will
continue to review our ratings on the notes and assess whether, in
our view, the ratings remain consistent with the credit
enhancement available," S&p said.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

            http://standardandpoorsdisclosure-17g7.com

Rating Actions

Nautique Funding Ltd.
                   Rating
             To               From
A-1A         AA+ (sf)         AA (sf)
A-1B         AA+ (sf)         AA (sf)
A-2B         AA+ (sf)         AA (sf)
A-3          AA (sf)          A+ (sf)
B-1          A (sf)           BBB+ (sf)
B-2          A (sf)           BBB+ (sf)
C            BB+ (sf)         B+ (sf)/Watch Pos
D            BB- (sf)         CCC+ (sf)/Watch Pos

Rating Affirmed

Nautique Funding Ltd.
             Rating
A-2A         AA+ (sf)


NYLIM FLATIRON: S&P Affirms 'B+' Rating on Class D Notes
--------------------------------------------------------
Standard & Poor's Ratings Services raised its rating on the class
C notes from NYLIM Flatiron 2004-1 Ltd., a collateralized loan
obligation (CLO) transaction managed by New York Life Investment
Management LLC and removed it from CreditWatch with positive
implications. "At the same time, we affirmed our ratings on the
class A, B, and D notes, and removed the rating on the class D
notes from CreditWatch with positive implications," S&P said.

"The upgrades reflect an improvement in the overcollateralization
(O/C) available to support the notes since our February 2011
rating actions, when we raised our ratings on all of the notes.
There have been $88.9 million in paydowns to the class A notes
since the January 2011 trustee report, which we referenced for our
February 2011 rating actions," S&P said. As of the Jan. 12, 2012,
trustee report, each of the transaction's O/C ratios had improved
since January 2011:

    The class A/B O/C ratio is 167.5%, compared with 130.8%;
    The class C O/C ratio is 133.3%, compared with 117.6%; and
    The class D O/C ratio is 107.6%, compared with 105.3%.

"Also, when we applied the largest obligor test, one of the
supplement tests, to the class D notes, the transaction was able
to withstand the specified combination of underlying asset
defaults at the 'B (sf)' rating level," S&P said.

"We affirmed our ratings on the class A, B, and D notes to reflect
the availability of credit support at the current rating levels,"
S&P said.

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

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

             http://standardandpoorsdisclosure-17g7.com

Rating And Creditwatch Actions

NYLIM Flatiron 2004-1 Ltd.
                            Rating
Class                   To           From
C                       AA+ (sf)     A+ (sf)/Watch Pos
D                       B+ (sf)      B+ (sf)/Watch Pos

Ratings Affirmed

NYLIM Flatiron 2004-1 Ltd.
Class                   Rating
A                       AAA (sf)
B                       AAA (sf)


OCTAGON INVESTMENT: S&P Raises Rating on Class D Notes to 'BB'
--------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1A, A-1B, A-2, B, C, and D notes from Octagon Investment
Partners XI Ltd., a collateralized loan obligation (CLO)
transaction managed by Octagon Credit Investors LLC. "At the same
time, we removed them from CreditWatch, where we placed them with
positive implications on Nov. 17, 2011," S&P said.

"The upgrades reflect the improved performance we have observed in
the deal's underlying asset portfolio since our November 2009
rating actions. According to the Jan. 18, 2012 trustee report, the
transaction's asset portfolio did not hold any defaulted assets,
down from the $15 million noted in the September 2009 trustee
report. Additionally, the collateral pool consisted of
approximately $5 million in assets from obligors rated in the
'CCC' category in January 2012, down from $20 million in September
2009," 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.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

          http://standardandpoorsdisclosure-17g7.com

Rating And Creditwatch Actions

Octagon Investment Partners XI Ltd.
                         Rating
Class                To           From
A-1A                 AA+ (sf)     AA (sf)/Watch Pos
A-1B                 AA+ (sf)     AA (sf)/Watch Pos
A-2                  AA (sf)      A+ (sf)/Watch Pos
B                    A (sf)       BBB+ (sf)/Watch Pos
C                    BBB (sf)     BB+ (sf)/Watch Pos
D                    BB (sf)      B+ (sf)/Watch Pos


OCTAGON INVESTMENT: S&P Says $2.05MM From 'CCC'-Rated Obligors
--------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class A-2 and C notes from Octagon Investment Partners IX Ltd., a
U.S. collateralized loan obligation (CLO) transaction managed by
Octagon Credit Investors LLC. "At the same time, we affirmed our
ratings on the class A-1 and B notes. Concurrently, we removed the
ratings on the class A-2, B, and C notes from CreditWatch, where
we placed them with positive implications on Feb. 10, 2012," S&P
said.

"The upgrades mainly reflect the improved credit performance of
the transaction's underlying asset portfolio since we lowered our
ratings on the class A-1, A-2, and C notes in November 2009
following the application of our September 2009 collateralized
debt obligation (CDO) criteria. As of the January 2012 trustee
report, the transaction's collateral pool had no defaulted assets.
This was down from the $14.16 million of defaulted assets noted in
the October 2009 trustee report, which we referenced for our
November 2009 rating actions. Additionally, the trustee reported
$2.05 million in assets from obligors rated in the 'CCC' category
in January 2012, compared with $21.64 million in October 2009,"
S&P said.

The upgrades also reflect a slight improvement in the
overcollateralization (O/C) available to support the notes since
S&P's November 2009 rating actions. The trustee reported the O/C
ratios in the January 2012 monthly report:

    The class A O/C ratio was 121.91%, compared with a reported
    ratio of 118.90% in October 2009;

    The class B O/C ratio was 114.61%, compared with a reported
    ratio of 111.78% in October 2009; and

    The class C O/C ratio was 107.77%, compared with a reported
    ratio of 105.11% in October 2009.

"We affirmed our ratings on the class A-1 and B notes to reflect
the availability of credit support at the current rating levels,"
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.

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

            http://standardandpoorsdisclosure-17g7.com

Rating And Credit Watch Actions

Octagon Investment Partners IX Ltd.
                   Rating
Class         To           From
A-2           AA (sf)      AA- (sf)/Watch Pos
B             A (sf)       A (sf)/Watch Pos
C             BBB (sf)     BBB- (sf)/Watch Pos

Rating Affirmed

Octagon Investment Partners IX Ltd.
Class             Rating
A-1               AA+ (sf)

Transaction Information
Issuer:             Octagon Investment Partners IX Ltd.
Coissuer:           Octagon Investment Partners IX LLC
Underwriter:        JPMorgan
Collateral manager: Octagon Credit Investors LLC
Trustee:            U.S. Bank N.A.
Transaction type:   Cash flow CDO


PARKRIDGE LANE: S&P Withdraws 'CCC-' Ratings on 3 Classes of Notes
------------------------------------------------------------------
Standard & Poor's Ratings Services withdrew its ratings on 20
classes of notes from 14 collateralized debt obligation (CDO)
transactions.

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

ACAS Business Loan Trust 2005-1 is a cash flow collateralized loan
obligation (CLO). The transaction paid the class A-1 and A-2B note
down in full on the Jan. 25, 2012 payment date, from outstanding
balances of $21.72 million and $9.99 million.

C-Bass CBO V Ltd. is a cash flow CDO backed by mezzanine
structured finance assets. The transaction paid the class B
notes down in full on the Dec. 22, 2011 payment date, from an
outstanding balance of $0.14 million.

Field Point III Ltd. is a cash flow CLO. The transaction paid the
class A-2 notes down in full on the Feb. 1, 2012 payment date,
from an outstanding balance of $19.19 million.

Field Point IV Ltd. is a cash flow CLO. The transaction paid the
class B-1 notes down in full on the Feb. 1, 2012 payment date,
from an outstanding balance of $109.74 million.

Flint European Debt Investments Trust is a cash flow
collateralized bond obligation (CBO). The transaction paid the
class B notes down in full on the Nov. 21, 2011 payment date, from
an outstanding balance of $29.18 million.

Forest Creek CLO Ltd. is a cash flow CLO. The transaction paid the
class A-1LA notes down in full on the Jan. 10, 2012 payment date,
from an outstanding balance of $1.82 million.

Freeport Loan Trust 2006-1 is a cash flow CLO. The transaction
paid the class B and C notes down in full on the Jul. 20, 2011 and
Jan. 20, 2012 payment dates.

Parkridge Lane Structured Finance Special Opportunities CDO I Ltd.
is a cash flow CDO backed by mezzanine structured finance assets.
The transaction paid the class B, C, D, and E notes down in full
on the Jan. 12, 2012 payment date, from outstanding balances of
$3.87 million, $3.53 million, $2.21 million, and $2.20 million.

Rosemont CLO Ltd. is a cash flow CLO. The transaction paid
the class B-1 and B-2 notes down in full on the Jan. 17, 2012
payment date, from outstanding balances of $3.81 million and
$1.48 million.

Securitized Product of Restructured Collateral Limited SPC for the
account of the Series 2005-1 Segregated Portfolio (SPRC 2005-1) is
a cash flow CDO re-tranche of a separate mezzanine structured
finance backed transaction. The re-tranche paid the class A1 notes
down in full on the Nov. 1, 2011 payment date, from an outstanding
balance of $0.53 million.

Sequils-Centurion V Ltd. is a cash flow CLO. The transaction paid
the class A note down in full on the Dec. 28, 2011 payment date,
from an outstanding balance of $4.24 million.

Solar Investment Grade CBO II Ltd. is a cash flow CBO. The
transaction paid the class I note down in full on the Jan. 24,
2012 payment date, from an outstanding balance of $37.08 million.

Stedman Loan Fund II Ltd. is a cash flow CLO. The transaction paid
the class A-1 note down in full on the Jan. 17, 2012 payment date,
from an outstanding balance of $6.01 million.

Vista Leveraged Income Fund is a cash flow CLO. The transaction
paid the senior notes down in full on the Jan. 26, 2012 payment
date, from an outstanding balance of $153.60 million.

             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 Represent ations,
warranties and enforcement mechanisms in issuances of similar
securities. The Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Reports
included in this credit rating report are available at:

           http://standardandpoorsdisclosure-17g7.com

Ratings Withdrawn

ACAS Business Loan Trust 2005-1
                           Rating
Class               To                From
A-1                 NR                AAA (sf)
A-2B                NR                AAA (sf)

C-Bass CBO V Ltd.
                            Rating
Class               To                  From
B                   NR                  AA (sf)

Field Point III Ltd.
                            Rating
Class               To                  From
A-2                 NR                  AA (sf)

Field Point IV Ltd.
                            Rating
Class               To                  From
B-1                 NR                  AA- (sf)

Flint European Debt Investments Trust
                            Rating
Class               To                  From
B                   NR                  A- (sf)

Forest Creek CLO Ltd.
                            Rating
Class               To                  From
A-1LA               NR                  AAA (sf)

Freeport Loan Trust 2006-1
                            Rating
Class               To                  From
B                   NR                  AAA (sf)
C                   NR                  AA (sf)/ Watch Pos

Parkridge Lane Structured Finance Special Opportunities CDO I Ltd.
                            Rating
Class               To                  From
B                   NR                  CCC+ (sf)
C                   NR                  CCC- (sf)
D                   NR                  CCC- (sf)
E                   NR                  CCC- (sf)

Rosemont CLO Ltd.
                            Rating
Class                 To                From
B-1                   NR                AAA (sf)
B-2                   NR                AAA (sf)

Securitized Product of Restructured Collateral Limited SPC for the
account of
the Series 2005-1 Segregated Portfolio
                            Rating
Class                To                From
A1                   NR                BBB (sf)

Sequils-Centurion V Ltd.
                            Rating
Class               To                From
A                   NR                AAA (sf)

Solar Investment Grade CBO II Ltd.
                            Rating
Class               To                  From
I                   NR                  AA+ (sf)

Stedman Loan Fund II Ltd.
                            Rating
Class               To                  From
A-1                 NR                  AAA (sf)

Vista Leveraged Income Fund
                            Rating
Class               To                  From
Senior              NR                  BB+ (sf)/Watch Neg

NR -- Not rated.


PINETREE CDO: S&P Lowers Rating on Class A-1S Notes to 'CC'
-----------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on the
class A-1S notes from Pinetree CDO Ltd. Pinetree CDO Ltd. is
a collateralized debt obligation (CDO) transaction backed by
residential mortgage-backed securities (RMBS) and other asset-
backed securities.

The downgrade reflects deterioration in credit quality available
to support the notes, particularly an increase in defaulted
assets. According to the Dec. 29, 2011 trustee report, the
transaction held $81.1 million in defaulted assets, which now
represents more than 66% of the underlying asset balance. Also,
the transaction is failing its class A-2, A-3, and B
overcollateralization ratio tests.

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

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

             http://standardandpoorsdisclosure-17g7.com

Rating Action

Pinetree CDO Ltd.
                         Rating
Class               To            From
A-1S                CC (sf)       CCC- (sf)

Other Outstanding Ratings

Pinetree CDO Ltd.
Class                                 Rating
A-1J                                  D (sf)
A-2                                   D (sf)
A-3                                   D (sf)
B                                     D (sf)


PNCMA 2000-C2: Moody's Lowers Rating of Cl. J Notes to 'B2'
-----------------------------------------------------------
Moody's Investors Service (Moody's) upgraded the ratings of two
classes, downgraded three classes and affirmed four classes of PNC
Mortgage Acceptance Corp., Commercial Mortgage Pass-Through
Certificates, Series 2000-C2:

Cl. F, Upgraded to Aaa (sf); previously on Sep 25, 2008 Upgraded
to Aa1 (sf)

Cl. G, Upgraded to Aa2 (sf); previously on Sep 25, 2008 Upgraded
to Aa3 (sf)

Cl. H, Downgraded to Baa2 (sf); previously on Oct 3, 2007 Upgraded
to Baa1 (sf)

Cl. J, Downgraded to B2 (sf); previously on Sep 9, 2010 Downgraded
to B1 (sf)

Cl. K, Downgraded to Caa1 (sf); previously on Sep 9, 2010
Downgraded to B3 (sf)

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

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

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

Cl. X, Affirmed at Aaa (sf); previously on Oct 23, 2000 Definitive
Rating Assigned Aaa (sf)

RATINGS RATIONALE

The upgrades are due to an increase in subordination from payoffs
and amortization. The downgrades are due to higher than expected
realized and anticipated losses from specially serviced and
troubled loans and interest shortfalls. The affirmations are due
to key parameters, including Moody's loan to value (LTV) ratio,
Moody's stressed debt service coverage ratio (DSCR) and the
Herfindahl Index (Herf), remaining within acceptable ranges. Based
on Moody's current base expected loss, the credit enhancement
levels for the affirmed classes are sufficient to maintain the
existing ratings.

Moody's rating action reflects a cumulative base expected loss of
21.2% of the current balance compared to 13.6% at last review..
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 U.S. CMBS Conduit Transactions" published in September 2000
and "Moody's Approach to Rating CMBS Large Loan/Single Borrower
Transactions" published in July 2000.

Moody's noted that on November 22, 2011, it released a Request for
Comment, in which the rating agency has requested market feedback
on potential changes to its rating methodology for Interest-Only
Securities. If the revised methodology is implemented as proposed
the rating on PNC Mortgage Acceptance Corp., Commercial Mortgage
Series 2000-C2 Class X may be negatively affected. Please refer to
Moody's request for Comment, titled "Proposal Changing the Global
Rating Methodology for Structured Finance Interest-Only
Securities," for further details regarding the implications of the
proposed methodology change on Moody's rating.

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 10 compared to 12 at last 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 8.2 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.

DEAL PERFORMANCE

As of the January 12, 2012 distribution date, the
transaction's aggregate certificate balance has decreased by 90%
to $110.9 million from $1.1 billion at securitization. The
Certificates are collateralized by 21 mortgage loans ranging in
size from less than 1% to 20% of the pool, with the top ten loans
representing 88% of the pool. The pool does not contain any
defeased loans or loans with investment grade credit estimates.

Four 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.

Fifteen loans have been liquidated from the pool, resulting in a
realized loss of $14 million (17% loss severity overall).
Currently seven loans, representing 37% of the pool, are in
special servicing. The largest specially serviced loan is the
Northside Marketplace Loan ($13.5 million -- 12.2% of the pool),
which is secured by a 189,299 square foot (SF) retail property
located in Nashville, Tennessee. The loan transferred into special
servicing in January 2010 due to imminent payment default. The
loan passed its anticipated repayment date (ARD) of September 1,
2010 and the borrower submitted a modification proposal which was
subsequently rejected. The loan is currently tracking foreclosure.
The master servicer recognized a $6 million appraisal reduction
for this loan in December 2011.

The remaining six specially serviced loans are secured by a
mix of asset types. The servicer has recognized an aggregate
$15.5 million appraisal reduction for four of the specially
serviced loans. Moody's has estimated a $21.1 million loss (51%
loss severity on average) for the specially serviced loans.

Moody's has assumed a high default probability two six poorly
performing loans representing 8% of the pool and has estimated an
aggregate $1.8 million loss (20% expected loss based on a 40%
probability default) from these troubled loans.

Based on the most recent remittance statement, Classes J
through O have experienced cumulative interest shortfalls totaling
$4.5 million compared to $2.7 million at last review. Moody's
anticipates that the pool will continue to experience interest
shortfalls because of the exposure to specially serviced loans.
Interest shortfalls are caused by special servicing fees,
including workout and liquidation fees, appraisal entitlement
reductions (ASERs), advanced interest claw backs on loans
determined to be non-recoverable and extraordinary trust expenses

Moody's was provided with full-year 2010 and partial year 2011
operating results for 82% and 67% of the pool, respectively.
Excluding specially serviced and troubled loans, Moody's weighted
average LTV is 71% compared to 84% at last review. Moody's net
cash flow reflects a weighted average haircut of 14% to the most
recently available net operating income (NOI). Moody's value
reflects a weighted average capitalization rate of 10.1%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.25X and 1.97X, respectively, compared to
1.16X 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.

The top three performing conduit loans represent 35.2% of the pool
balance. The largest loan is the Sweetheart Cup Distribution
Center Loan ($22.3 million -- 20.1% of the pool), which is secured
by a 1.03 million SF industrial building located in Hampstead,
Maryland. The property is fully occupied by a single tenant, Solo
Cup Company, through July 2020. The loan had an ARD of October 1,
2010 but is current. Although property performance has been stable
since securitization, Moody's analysis reflects a stressed cash
flow due to a challenged refinance environment and Moody's
concerns about single tenant exposure. Moody's LTV and stressed
DSCR are 79% and 1.48X, respectively, compared to 86% and 1.40X at
last review.

The second largest loan is The Waterford at Portage Loan
($8.9 million -- 8.1% of the pool), which is secured by two
multifamily properties located in Akron, Ohio. This loan has been
on the master servicer's watchlist since 2010 due to a low DSCR.
Property performance has declined since securitization primarily
due to increased operating expenses. Combined occupancy was 88% as
of September 2011 compared to 93% at last review. Moody's
considers this loan as having a high risk of default. Moody's LTV
and stressed DSCR are 147% and 0.72X, respectively, compared to
136% and 0.76X at last review.

The third largest loan is The Waterford at Spencer Oaks Loan
($7.8 million -- 7.0% of the pool), which is secured by a 208-unit
multifamily complex located in Denton, Texas. This loan has been
on the master servicer's watchlist due to a low DSCR. At last
review property performance had declined due to increased
operating expenses. However, performance has improved and
occupancy was 92% as of November 2011 compared to 89% at last
review. Moody's LTV and stressed DSCR are 81% and 1.28X,
respectively, compared to 94% and 1.10X at last review.


PUTNAM CDO: Moody's Affirms Class A-1MT -a Notes Rating at 'Ba1'
----------------------------------------------------------------
Moody's Investors Service has affirmed the ratings of eleven
classes and upgraded the ratings of one Class of Notes issued by
Putnam CDO 2002-1, Ltd. The affirmations are due to key
transaction parameters performing within levels commensurate with
the existing ratings levels. The upgrade is due to revised
repayment expectations of the Class B Rated Principal Balance. The
rating action is the result of Moody's on-going surveillance of
commercial real estate collateralized debt obligation (CRE CDO and
ReRemic) transactions.

US$176,000,000 Class A-1MT -a Medium Term Floating Rate Notes Du
2038, Affirmed at Ba1 (sf); previously on Mar 4, 2010 Downgraded
to Ba1 (sf)

US$176,000,000 Class A-1MT -b Medium Term Floating Rate Notes Due
2038, Affirmed at Ba1 (sf); previously on Mar 4, 2010 Downgraded
to Ba1 (sf)

US$176,000,000 Class A-1MT -c Medium Term Floating Rate Notes Due
2038, Affirmed at Ba1 (sf); previously on Mar 4, 2010 Downgraded
to Ba1 (sf)

US$176,000,000 Class A-1MM -d Floating Rate Notes Due 2038,
Affirmed at Ba1 (sf); previously on Mar 4, 2010 Downgraded to Ba1
(sf)

US$176,000,000 Class A-1MM -e Floating Rate Notes Due 2038,
Affirmed at Ba1 (sf); previously on Mar 4, 2010 Downgraded to Ba1
(sf)

US$176,000,000 Class A-1MM -f Floating Rate Notes Due 2038,
Affirmed at Ba1 (sf); previously on Mar 4, 2010 Downgraded to Ba1
(sf)

US$176,000,000 Class A-1MM -g Floating Rate Notes Due 2038,
Affirmed at Ba1 (sf); previously on Mar 4, 2010 Downgraded to Ba1
(sf)

US$176,000,000 Class A-1MM -h Floating Rate Notes Due 2038,
Affirmed at Ba1 (sf); previously on Mar 4, 2010 Downgraded to Ba1
(sf)

US$176,000,000 Class A-1MM -i Floating Rate Notes Due 2038,
Affirmed at Ba1 (sf); previously on Mar 4, 2010 Downgraded to Ba1
(sf)

US$176,000,000 Class A-1MM -j Floating Rate Notes Due 2038,
Affirmed at Ba1 (sf); previously on Mar 4, 2010 Downgraded to Ba1
(sf)

US$150,000,000 Class B Participating Notes Due 2038, Upgraded to
B3 (sf); previously on Mar 4, 2010 Downgraded to Ca (sf)

US$80,000,000 Class A-2 Floating Rate Notes Due 2038, Affirmed at
Caa3 (sf); previously on Mar 4, 2010 Downgraded to Caa3 (sf)

RATINGS RATIONALE

Putnam CDO 2002-1 Ltd. is a static cash CRE CDO transaction backed
by a portfolio of commercial mortgage backed securities (CMBS)
(62.9% of the pool balance), asset backed securities (ABS) (28.7%
-- of which 42% of which are government-sponsored enterprise
guaranteed mortgage bonds, the remainder primarily in the form of
subprime and prime residential mortgage backed securities (RMBS)),
and CDOs (8.4%) . As of the January 10, 2012 Trustee report, the
aggregate Note balance of the transaction, including the
outstanding balance of Class B and Class C Notes, is $1.49 billion
from $2.0 billion at issuance. The paydown has been directed to
the Class A Notes, which amortize pro-rata as long as certain
conditions are met, as a result of amortization of the underlying
collateral. The Rated Principal Amount of Class B and Class C has
also been reduced in accordance with a turbo feature as outlined
in the transaction governing documents.

There are nine assets with a par balance of $30 million (2.0% of
the current pool balance) that are considered Defaulted Securities
as of the January 10, 2012 Trustee report. Eight of these assets
(66.0% of the defaulted balance) are ABS and one asset is a CDO
(34%).

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 1,313 compared to 1,095 at last review. The
distribution of current ratings and credit estimates is as
follows: Aaa-Aa3 (63.2% compared to 69.1% at last review), A1-A3
(4.3% compared to 4.5% at last review), Baa1-Baa3 (7.0% compared
to 5.7% at last review), Ba1-Ba3 (7.7% compared to 6.2% at last
review), B1-B3 (4.1% compared to 4.0% at last review), and Caa1-C
(13.7% compared to 10.6% at last review).

WAL acts to adjust the probability of default of the collateral in
the pool for time. Moody's modeled to a WAL of 3.7 years compared
to 4.2 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
53.8% compared to 57.6% at last review.

MAC is a single factor that describes the pair-wise asset
correlation to the default distribution among the instruments
within the collateral pool (i.e. the measure of diversity).
Moody's modeled a MAC of 1.2% compared to 1.9% 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
54% to 44% or up to 64% would result in average rating movement on
the rated tranches of 0 to 1 notches downward and 0 to 4 notches
upward, respectively.

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

Primary sources of assumption uncertainty are the extent of the
slowdown in growth in the current macroeconomic environment and
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 in
recovery and improvements in the office sector continue, with
fundamentals in Gateway cities outperforming their suburban
counterparts. However, office demand is closely tied to
employment, where fundamentals remain weak, so significant
improvement may be delayed. Performance in the retail sector has
been mixed with on-going rent deflation and leasing challenges.
Across all property sectors, the availability of debt capital
continues to improve with monetary policy expected to remain
supportive and interest rate hikes postponed. Moody's central
global macroeconomic scenario reflects an overall downward
revision of forecasts since last quarter, amidst ongoing fiscal
consolidation efforts, household and banking sector deleveraging,
persistently high unemployment levels, and weak housing markets
that will continue to constrain growth.

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.


RAMP SERIES 2006-RZ1: S&P Raises Rating on Class A-2 From 'CC'
--------------------------------------------------------------
Standard & Poor's Ratings Services corrected its rating on class
A-2 from RAMP Series 2006-RZ1 Trust by raising it to 'AAA (sf)'
from 'CC (sf)'. RAMP 2006-RZ1 is a residential mortgage-backed
securities (RMBS) first-lien, high-LTV (loan-to-value)
transaction.

"On Jan. 19, 2012, we inadvertently lowered our rating on class A-
2. The correction of the rating reflects our view that the amount
of projected credit enhancement available for this class is
expected to cover projected losses based on the stress scenario
associated with the corrected rating level," S&P said.

Subordination, overcollateralization (prior to depletion), and
excess spread provide credit support for this transaction.

Rating Corrected

RAMP Series 2006-RZ1 Trust
Series 2006-RZ1
                                Rating
Class   CUSIP       Current     1/19/12      Pre-1/19/12
A-2     76112BY87   AAA (sf)    CC (sf)      AAA (sf)
Primary Credit Analyst: James Taylor, New York (1) 212-438-6067;


RESTRUCTURED ASSET: Moody's Raises Class A-3 Notes Rating to 'B2'
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of one class of
certificates issued by Restructured Asset Backed Securities Series
2003-3. The rating action is:

$23,326,186 Class A-3 Certificates due January 2022 (current
outstanding balance of $4,281,816), Upgraded to B2 (sf);
previously on May 10, 2010 Downgraded to Caa2 (sf).

RATINGS RATIONALE

Restructured Asset Backed Securities Series 2003-3, issued on
August 19, 2003, is a repackaging of the Class A Notes issued by
Sunrise CDO I, Limited, a collateralized debt obligation issuance
that is backed by a portfolio of corporate bonds and ABS
securities, including exposure to Residential Mortgage-Backed
Securities. The Moody's rating assigned to the Class A Notes
issued by Sunrise CDO I, Limited is currently B2. Moody's
explained that its rating of the Certificates is directly linked
to, and will change as a result of, Moody's rating assigned to the
Class A Notes issued by Sunrise CDO I, Limited.

The methodologies used in this rating were "Moody's Refines Its
Approach to Rating Structured Notes" published in July 1997,
"Rating CDO Repacks: An Application Of The Structured Note
Methodology" published in February 2004, and "Using the Structured
Note Methodology to Rate CDO Combo-Notes" published in February
2004.


RFC CDO: Fitch Lowers Rating on $7.2 Million Notes to 'Csf'
-----------------------------------------------------------
Fitch Ratings has downgraded one and affirmed four classes of
notes issued by RFC CDO I, Ltd. (RFC CDO I):

  -- $19,552,492 class A notes affirmed at 'BBBsf'; Outlook
     revised to Stable from Negative;
  -- $22,500,000 class B1 notes affirmed at 'Bsf'; Outlook
     Negative;
  -- $2,000,000 class B2 notes affirmed at 'Bsf'; Outlook
     Negative;
  -- $16,200,000 class C notes affirmed at 'CCsf';
  -- $7,288,634 class D notes downgraded to 'Csf' from 'CCsf'.

This review was conducted under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Structured Finance Portfolio Credit Model (SF PCM) for
projecting future default levels for the underlying portfolio.
These default levels were then compared to the breakeven levels
generated by Fitch's cash flow model of the CDO under various
default timing and interest rate stress scenarios, as described in
the report 'Global Criteria for Cash Flow Analysis in CDOs'.
Fitch also considered additional qualitative factors into its
analysis to conclude the rating actions for the notes.

Since the last rating action in February 2011, the credit quality
of the collateral has further deteriorated with approximately
51.5% of the portfolio downgraded a weighted average of 4.0
notches.  Approximately 82.7% of the portfolio has a Fitch derived
rating below investment grade and 57.9% has a rating in the 'CCC'
rating category or lower, compared to 67.8% and 49.6%,
respectively, at last review.

Despite the continued deterioration in the portfolio, the
class A notes are affirmed at 'BBBsf' and its Outlook is revised
to Stable due to sufficient increase in the credit enhancement
(CE) available to these notes, resulting from the continued
deleveraging of the capital structure. Since the last review, the
class A notes have received approximately $14.5 million, or 42.6%
of its previous balance, in principal redemptions.  In addition to
normal principal amortization, the notes have also been benefiting
from excess spread redirected to cure the failure of the class C
overcollateralization (OC) test.  Approximately $1 million of such
interest proceeds were used to amortize these notes over the last
four payment dates.  The current outstanding balance represents
8.6% of the original issued amount.  Based on the maturity profile
of the underlying pool, Fitch expects the remaining balance to be
paid down within the next two to three years.

The amortization of the capital structure has also increased the
class B-1 and B-2 (together, class B) notes' CE levels.  This
increase was sufficiently high to offset the deterioration in the
underlying assets, resulting in an affirmation of the notes'
rating.  However, Fitch maintains a Negative Outlook on this class
due to the limited cushion available to protect them against
additional deterioration in the underlying portfolio over the next
one to two years.

The class C notes continue to receive current interest
distributions, since they precede the failing class C OC test in
the distribution waterfall.  However, the breakeven for this class
is below SF PCM's 'CCC' default level; therefore, Fitch compared
the class' CE level to the expected losses from distressed and
defaulted assets in the portfolio (rated 'CCsf' or lower).  At
present, the CE level of the class C notes is only slightly below
the portfolio's expected loss, thus the notes are affirmed at
'CCsf', indicating that default is probable but not yet
inevitable.

The class D notes are no longer receiving any distributions and
are not expected to in the future.  The CE available to this class
of notes is now greatly exceeded by the portfolio's expected loss,
indicating that default appears inevitable at or prior to
maturity. Therefore, the class D notes are downgraded to 'Csf'.

RFC CDO I is a structured finance collateralized debt obligation
(SF CDO) that closed on June 30, 2004.  The portfolio of
collateral was originally selected by Residential Funding
Corporation and is now monitored by Castle Peak Capital Advisors.
The portfolio is composed of primarily residential mortgage-backed
securities (97.1%) from the 2004 and prior vintages.


RMBS: DBRS Confirms Series 2006-CB4, CLASS AV2 at 'C'
-----------------------------------------------------
DBRS has removed from Under Review with Developing Implications
and confirmed ratings on 371 tranches from 71 RMBS and Re-REMIC
transactions.  DBRS has also discontinued ratings on the 371
tranches from 71 RMBS and Re-REMIC transactions as the noteholders
of the respective classes of securities have been fully repaid.

C-BASS 2006-CB4 TRUST C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2006-CB4, Class AV2 Confirmed C (sf) --
Feb 7, 2012


SB 2002-KEY: Moody's Affirms Cl. L Notes Rating at 'Ba1'
--------------------------------------------------------
Moody's Investors Service upgraded the ratings of four classes and
affirmed 13 classes and downgraded seven classes of Salomon
Brothers Mortgage Securities VII, Inc., Commercial Mortgage Pass-
Through Certificates, Series 2002-KEY2:

Cl. A-2, Affirmed at Aaa (sf); previously on Mar 9, 2011 Confirmed
at Aaa (sf)

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

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

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

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

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

Cl. F, Upgraded to Aaa (sf); previously on Apr 30, 2009 Upgraded
to Aa2 (sf)

Cl. H, Upgraded to Aa2 (sf); previously on Apr 30, 2009 Upgraded
to A1 (sf)

Cl. J, Upgraded to A1 (sf); previously on Apr 30, 2009 Upgraded to
A3 (sf)

Cl. K, Upgraded to Baa1 (sf); previously on Apr 30, 2009 Upgraded
to Baa2 (sf)

Cl. L, Affirmed at Ba1 (sf); previously on Sep 26, 2002 Definitive
Rating Assigned Ba1 (sf)

Cl. M, Affirmed at Ba2 (sf); previously on Sep 26, 2002 Assigned
Ba2 (sf)

Cl. N, Affirmed at Ba3 (sf); previously on Sep 26, 2002 Downgraded
to Ba3 (sf)

Cl. P, Affirmed at B1 (sf); previously on Sep 26, 2002 Downgraded
to B1 (sf)

Cl. Q, Affirmed at Caa1 (sf); previously on Feb 16, 2011
Downgraded to Caa1 (sf)

Cl. S, Affirmed at Caa3 (sf); previously on Feb 16, 2011
Downgraded to Caa3 (sf)

Cl. X-1, Affirmed at Aaa (sf); previously on Mar 9, 2011 Confirmed
at Aaa (sf)

RATINGS RATIONALE

The upgrades are due to increased credit support as a result of
amortization and scheduled loan payoffs and overall stable pool
performance. The affirmations are due to key parameters, including
Moody's loan to value (LTV) ratio, Moody's stressed debt service
coverage ratio (DSCR) and the Herfindahl Index (Herf), remaining
within acceptable ranges. Based on Moody's current base expected
loss, the credit enhancement levels for the affirmed classes are
sufficient to maintain their current ratings.

Moody's rating action reflects a cumulative base expected loss of
3.2% of the current balance, compared to 3.1% at last review.
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 extent of the
slowdown in growth in the current macroeconomic environment and
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 in
recovery and improvements in the office sector continue, with
fundamentals in Gateway cities outperforming their suburban
counterparts. However, office demand is closely tied to
employment, where fundamentals remain weak, so significant
improvement may be delayed. Performance in the retail sector has
been mixed with on-going rent deflation and leasing challenges.
Across all property sectors, the availability of debt capital
continues to improve with monetary policy expected to remain
supportive and interest rate hikes postponed. Moody's central
global macroeconomic scenario reflects an overall downward
revision of forecasts since last quarter, amidst ongoing fiscal
consolidation efforts, household and banking sector deleveraging,
persistently high unemployment levels, and weak housing markets
that will continue to constrain growth.

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 noted that on November 22, 2011, it released a Request for
Comment, in which the rating agency has requested market feedback
on potential changes to its rating methodology for Interest-Only
Securities. If the revised methodology is implemented as proposed
the rating on Salomon Brothers Mortgage Securities VII, Inc.,
Commercial Mortgage Pass-Through Certificates, Series 2002-KEY2
Class X1 may be negatively affected. Please refer to Moody's
request for Comment, titled "Proposal Changing the Global Rating
Methodology for Structured Finance Interest-Only Securities," for
further details regarding the implications of the proposed
methodology change on Moody's rating.

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 pay down analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Moody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade credit estimates is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
underlying rating of the loan which corresponds to a range of
credit enhancement levels. Actual fusion credit enhancement levels
are selected based on loan level diversity, pool leverage and
other concentrations and correlations within the pool. Negative
pooling, or adding credit enhancement at the underlying rating
level, is incorporated for loans with similar credit estimates in
the same transaction.

Moody's 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 12, down from 16 at last review.

In cases where the Herf falls below 20, Moody's also employs the
large loan/single borrower methodology. This methodology uses the
excel based Large Loan Model v 8.0 and then reconciles and weights
the results from the two models in formulating a rating
recommendation. The large loan model derives credit enhancement
levels based on an aggregation of adjusted loan level proceeds
derived from Moody's loan level LTV ratios. Major adjustments to
determining proceeds include leverage, loan structure, property
type, and sponsorship. These aggregated proceeds are then further
adjusted for any pooling benefits associated with loan level
diversity, other concentrations and correlations. 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 February 24, 2011.

DEAL PERFORMANCE

As of the January 18, 2012 distribution date, the
transaction's aggregate certificate balance had decreased by 55%
to $423.3 million from $932.8 million at securitization. The
Certificates are collateralized by 36 mortgage loans which range
in size from less than 1% to 16% of the pool, with the top ten
loans representing 66% of the pool. The pool contains two loans
with investment grade credit estimates, representing 25% of the
pool. Six loans representing 13% of the pool have defeased and are
collateralized with U.S. Government securities. Approximately 86%
of the pool matures within the next six months based on their
scheduled maturity dates.

Eighteen loans, representing 32% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, Moody's reviews the
watchlist to assess which loans have material issues that could
impact performance.

Three loans have been liquidated from the pool since
securitization, resulting in approximately a $6.9 million loss
(24% loss severity on average). There are currently two loans,
representing 2% in special servicing. The largest specially
serviced loan is The Commons at Sauk Trail Shopping Center Loan
($8.1 million --1.9% of the pool), which is secured by a 97,000
square foot (SF) retail center located approximately 10 miles
southwest of Ann Arbor, Michigan. The loan was transferred to
special servicing in August 2010 as a result of payment default.
As of February 2012, the borrower has submitted a discounted pay
off offer which is currently under review. The remaining specially
serviced loan is secured by an industrial property located in
Hicksville, New York and is currently in foreclosure. Moody's has
estimated an aggregate $5.9 million loss (61% expected loss on
average) for the specially serviced loans.

Moody's has assumed a high default probability for one poorly
performing loan representing 1% of the pool and has estimated a
$1.3 million loss (25% expected loss based on a 50% probability
default) from this troubled loan.

Moody's was provided with full year 2010 financials for 95%, and
partial year 2011 financials for 90% of the pool's non-defeased
and non-specially serviced loans.

Excluding specially serviced and troubled loans, Moody's weighted
average LTV is 76% compared to 83% at Moody's prior review.
Moody's net cash flow reflects a weighted average haircut of 10.9%
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 are 1.37X and 1.46X, respectively, compared to
1.29X and 1.34X at last review. Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The largest loan with a credit estimate is the Westfarms Mall Loan
($67.9 million -- 16.1% of the pool), which represents a 50%
participation interest in a $135.9 million first mortgage loan.
The loan is also encumbered with $45.7 million in subordinate
debt. The loan is secured by the borrower's interest in a
1.3 million SF super-regional mall located in Farmington,
Connecticut. The property is anchored by Filene's (two stores),
J.C. Penney, Lord & Taylor and Nordstrom. As of September 2011,
in-line space was 92% leased, the same as at last review. The loan
sponsor is Taubman Centers Inc. Performance has been stable and
the has benefited from 2% amortization since last review. The loan
is scheduled to mature in July 2012. Moody's current credit
estimate and stressed DSCR are Aaa and 2.38X, respectively,
compared to Aa2 and 1.98X at last review.

The second loan with a credit estimate is the Jefferson Mall Loan
($35.9 million -- 8.5% of the pool), which is secured by the
borrower's interest in a 875,000 square foot regional mall located
in Louisville, Kentucky. The property is anchored by Sears,
Macy's, J.C. Penney and Dillard's. All the anchors own their own
land and improvements. The collateral for the loan consists of
270,000 SF of in-line space. As of September 2011, the in-line
space was 97% leased compared to 90% at last review. The loan is
structured on a 25-year amortization schedule and has amortized by
approximately 3% since last review. The loan sponsor is CBL &
Associates Properties. The loan is scheduled to mature in July
2012. Due to an improvement in performance, Moody's current credit
estimate and stressed DSCR are A3 and 2.11X, respectively,
compared to Baa1 and 1.74X at last review.

The top three performing conduit loans represent 26% of the
pool balance. The largest conduit loan is the Westgate Mall Loan
($44.6 million -- 10.5% of the pool), which is secured by the
borrower's interest in a 1.1 million SF regional mall located in
Spartanburg, South Carolina. The property is anchored by Sears,
Belk, Dillard's and J.C. Penney. The collateral consists of only
the in-line stores, JC Penny and a cinema, totaling 432,900 SF.
As of September 2011, the in-line stores were 95% leased
compared to 99% at last review. The loan is structured on a 25-
year amortization schedule and has amortized by approximately
3% since last review. The loan sponsor is CBL & Associates
Properties. The loan is scheduled to mature in July 2012. Moody's
current LTV and stressed DSCR are 91% and 1.16X, respectively,
compared to 95% and 1.11X at last review.

The second largest conduit loan is the Northland Multifamily
Portfolio Loan ($35.7 million -- 8.4% of the pool), which is
secured by five Class B garden style apartment complexes totaling
1,056 units. The properties are located in Florida (3) and Texas
(2). As of September 2011, the portfolio was 94% leased,
essentially the same as at last review. Performance has improved
due to increased rental rates. The loan has amortized an
additional 2% since last review. Moody's LTV and stressed DSCR are
67% and 1.50X, respectively, compared to 82% and 1.23X at last
review.

The third largest conduit loan is the Regency Mall Loan
($28.1 million -- 6.6% of the pool), which is secured by the
borrower's interest in a 924,000 square foot regional mall located
in Racine, Wisconsin. The property is anchored by J.C. Penney,
Boston Store, Burlington Coat Factory, Sears and Target. All the
anchors own their respective land and improvements. The collateral
for the loan consists of 269,000 square feet of in-line space. As
of September 2011, the in-line space was 89% leased compared to
92% at last review. The loan is structured with a 25-year
amortization schedule and has amortized by 3% since last review.
The loan sponsor is CBL & Associates Properties. The loan is
scheduled to mature in July 2012. Moody's current LTV and stressed
DSCR are 88% and 1.19X, respectively, compared to 112% and 0.95X
at last review.


SEAWALL 2006-4: Moody's Affirms Super Senior Rating at 'Caa3'
-------------------------------------------------------------
Moody's has downgraded the ratings of one class and affirmed the
ratings of nine classes of Notes issued by Seawall 2006-4, Ltd.
The downgrade is due to the deterioration in the credit quality of
the underlying portfolio of reference obligations as evidenced by
a negative migration in key credit parameters. The affirmations
are due to the key transaction parameters performing within levels
commensurate with the existing ratings levels. The ratings on
classes D-2, E-1, E-2, E-3 and E-4 will subsequently be withdrawn
as they have been fully written down to $0 par balance. The rating
action is the result of Moody's on-going surveillance of
commercial real estate collateralized debt obligation (CRE CDO
Synthetic) transactions.

Moody's rating action is:

Super Senior, Affirmed at Caa3 (sf); previously on Apr 12, 2011
Downgraded to Caa3 (sf)

Cl. A, Downgraded to C (sf); previously on Apr 12, 2011 Downgraded
to Ca (sf)

Cl. B, Affirmed at C (sf); previously on Apr 12, 2011 Downgraded
to C (sf)

Cl. C, Affirmed at C (sf); previously on Apr 12, 2011 Downgraded
to C (sf)

Cl. D-1, Affirmed at C (sf); previously on May 13, 2010 Downgraded
to C (sf)

Cl. D-2, Affirmed at C (sf); previously on May 13, 2010 Downgraded
to C (sf)

Cl. E-1, Affirmed at C (sf); previously on May 13, 2010 Downgraded
to C (sf)

Cl. E-2, Affirmed at C (sf); previously on May 13, 2010 Downgraded
to C (sf)

Cl. E-3, Affirmed at C (sf); previously on May 13, 2010 Downgraded
to C (sf)

Cl. E-4, Affirmed at C (sf); previously on May 13, 2010 Downgraded
to C (sf)

RATINGS RATIONALE

Seawall 2006-4, Ltd., is a static synthetic CRE CDO transaction
backed by a portfolio of credit default swaps on commercial
mortgage backed securities (CMBS) (100.0% of the reference
obligation balance). The notional balance of the reference
obligation pool has decreased to $280.0 million from
$300.0 million at issuance, due to write-downs of two of
the reference obligations.

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 reference obligations. The bottom-dollar WARF is a measure
of the default probability within a reference obligation pool.
Moody's modeled a bottom-dollar WARF of 7,959 compared to 7,720 at
last review. The distribution of current ratings and credit
estimates is as follows: Ba1-Ba3 (0.0% compared to 3.3% at last
review), B1-B3 (14.3% compared to 16.7% at last review) and Caa1-C
(85.7% compared to 80.0% at last review).

WAL acts to adjust the probability of default of the reference
obligations in the pool for time. Moody's modeled to a WAL of 5.0
years compared to 5.5 years at last review.

WARR is the par-weighted average of the mean recovery values for
the reference obligations in the pool. Moody's modeled a variable
WARR with a mean of 0.7% compared to 1.2% at last review.

MAC is a single factor that describes the pair-wise asset
correlation to the default distribution among the instruments
within the reference obligation pool (i.e. the measure of
diversity). Moody's modeled a MAC of 99.9%, the same as 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.

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. In general, the rated Notes are particularly
sensitive to rating changes within the reference obligations.
However, in light of the performance indicators noted above,
Moody's believes that it is unlikely that the ratings announced
are sensitive to further change.

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 extent of the
slowdown in growth in the current macroeconomic environment and
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 in
recovery and improvements in the office sector continue, with
fundamentals in Gateway cities outperforming their suburban
counterparts. However, office demand is closely tied to
employment, where fundamentals remain weak, so significant
improvement may be delayed. Performance in the retail sector has
been mixed with on-going rent deflation and leasing challenges.
Across all property sectors, the availability of debt capital
continues to improve with monetary policy expected to remain
supportive and interest rate hikes postponed. Moody's central
global macroeconomic scenario reflects an overall downward
revision of forecasts since last quarter, amidst ongoing fiscal
consolidation efforts, household and banking sector deleveraging,
persistently high unemployment levels, and weak housing markets
that will continue to constrain growth.

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


SEAWALL 2006-4A: Moody's Affirms Rating of Cl. D-1 Notes at 'C'
---------------------------------------------------------------
Moody's has affirmed the ratings of six classes of Notes issued
by Seawall 2006-4a, Ltd. The affirmations are due to the key
transaction parameters performing within levels commensurate with
the existing ratings levels. The ratings on classes D-2, E-1, E-2,
E-3 and E-4 will subsequently be withdrawn as they have been fully
written down to $0 par balance. The rating action is the result of
Moody's on-going surveillance of commercial real estate
collateralized debt obligation (CRE CDO Synthetic) transactions.

Moody's rating actions:

Cl. D-1, Affirmed at C (sf); previously on May 13, 2010 Downgraded
to C (sf)

Cl. D-2, Affirmed at C (sf); previously on May 13, 2010 Downgraded
to C (sf)

Cl. E-1, Affirmed at C (sf); previously on May 13, 2010 Downgraded
to C (sf)

Cl. E-2, Affirmed at C (sf); previously on May 13, 2010 Downgraded
to C (sf)

Cl. E-3, Affirmed at C (sf); previously on May 13, 2010 Downgraded
to C (sf)

Cl. E-4, Affirmed at C (sf); previously on May 13, 2010 Downgraded
to C (sf)

RATINGS RATIONALE

Seawall 2006-4a, Ltd. is a static synthetic CRE CDO transaction
backed by a portfolio of credit default swaps on commercial
mortgage backed securities (CMBS) (100.0% of the reference
obligation balance). The notional balance of the reference
obligation pool has decreased to $280.0 million from
$300.0 million at issuance, due to write-downs of two of
the reference obligations.

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 reference obligations. The bottom-dollar WARF is a measure
of the default probability within a reference obligation pool.
Moody's modeled a bottom-dollar WARF of 7,959 compared to 7,720 at
last review. The distribution of current ratings and credit
estimates is as follows: Ba1-Ba3 (0.0% compared to 3.3% at last
review), B1-B3 (14.3% compared to 16.7% at last review) and Caa1-C
(85.7% compared to 80.0% at last review).

WAL acts to adjust the probability of default of the reference
obligations in the pool for time. Moody's modeled to a WAL of 5.0
years compared to 5.5 years at last review.

WARR is the par-weighted average of the mean recovery values for
the reference obligations in the pool. Moody's modeled a variable
WARR with a mean of 0.7% compared to 1.2% at last review.

MAC is a single factor that describes the pair-wise asset
correlation to the default distribution among the instruments
within the reference obligation pool (i.e. the measure of
diversity). Moody's modeled a MAC of 99.9%, the same as 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.

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. In general, the rated Notes are particularly
sensitive to rating changes within the reference obligations.
However, in light of the performance indicators noted above,
Moody's believes that it is unlikely that the ratings are
sensitive to further change.

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 extent of the
slowdown in growth in the current macroeconomic environment and
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 in
recovery and improvements in the office sector continue, with
fundamentals in Gateway cities outperforming their suburban
counterparts. However, office demand is closely tied to
employment, where fundamentals remain weak, so significant
improvement may be delayed. Performance in the retail sector has
been mixed with on-going rent deflation and leasing challenges.
Across all property sectors, the availability of debt capital
continues to improve with monetary policy expected to remain
supportive and interest rate hikes postponed. Moody's central
global macroeconomic scenario reflects an overall downward
revision of forecasts since last quarter, amidst ongoing fiscal
consolidation efforts, household and banking sector deleveraging,
persistently high unemployment levels, and weak housing markets
that will continue to constrain growth.

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


SENIOR ABS: Fitch Affirms Rating on $6.6 Mil. Certs at 'Bsf'
------------------------------------------------------------
Fitch Ratings has affirmed the certificates issued by Senior ABS
Repack Trust, series 2002-1 (Senior ABS Repack Trust 2002-1):

  -- $6,600,000 certificates at 'Bsf'; Outlook Negative.

The rating on the certificates, which addresses timely payment of
interest and ultimate payment of principal is based on the
anticipated cash flow from the E*TRADE ABS CDO I, Ltd.(E*Trade I)
class  A-2 notes held as collateral by the Senior ABS Repack Trust
2002-1.  The rating on the certificates correlates directly with
the rating on the class A-2 notes of E*TRADE I.  The E*TRADE I
class A-2 notes were affirmed at 'Bsf'; Outlook Negative by Fitch.


SHASTA CLO: S&P Ups Rating on Class B-2L Notes From 'CCC-' to 'BB'
------------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-2L, A-3L, B-1L, and B-2L notes from Shasta CLO I Ltd., a U.S.
collateralized loan obligation (CLO) transaction managed by Apidos
Capital Management LLC. "Simultaneously, we removed our ratings on
these notes from CreditWatch, where we had placed them with
positive implications on Nov. 14, 2011. At the same time, we
affirmed our ratings on the class X, A-1L, and A-1LV notes," S&P
said.

"The upgrades reflect improved performance in the deal's
underlying asset portfolio and an increase in the credit support
available to the notes since we lowered our ratings on all the
classes in February 2010 following the application of our
September 2009 corporate collateralized debt obligation (CDO)
criteria," S&P said.

"As of the January 2012 trustee report, the transaction's asset
portfolio had $6.581 million in defaulted assets, down from
$32.801 million in the January 2010 trustee report, which we used
for the analysis in the February 2010 rating actions. Many of the
defaults were sold at prices higher than the assumed recovery
rates," S&P said.

In addition, the transaction's overcollateralization (O/C) ratios
have increased since January 2010. The trustee reported the O/C
ratios in the January 2012 monthly report:

   The class A-2L O/C ratio was 123.62%, compared with a reported
   ratio of 119.25% in January 2010;

   The class A-3L O/C ratio was 115.46% compared with a reported
   ratio of 111.44% in January 2010;

   The class B-1L O/C ratio was 110.42%, compared with a reported
   ratio of 106.6% in January 2010; and

   The class B-2L O/C ratio was 105.80%, compared with a reported
   ratio of 102.08% in January 2010.

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

             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 Represent ations,
warranties and enforcement mechanisms in issuances of similar
securities. The Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Reports
included in this credit rating report are available at:

            http://standardandpoorsdisclosure-17g7.com

Ratings Raised

Shasta CLO I Ltd.
                        Rating
Class              To           From
A-2L               AA (sf)      A- (sf)/Watch Pos
A-3L               A (sf)       BBB (sf)/Watch Pos
B-1L               BBB (sf)     BB (sf)/Watch Pos
B-2L               BB (sf)      CCC- (sf)/Watch Pos

Ratings Affirmed

Class        Rating
X            AAA (sf)
A-1L         AA+ (sf)
A-1LV        AA+ (sf)

Transaction Information
Issuer:             Shasta CLO I Ltd.
Coissuer:           Shasta CLO I (Delaware) Corp.
Collateral Manager: Apidos Capital Management LLC
Underwriter:        Bear Stearns Cos. LLC
Indenture Trustee:  Bank of New York Mellon (The)
Transaction type:   Cash flow CDO


SILVERADO CLO: S&P Raises Class D Note Rating From 'B+' to 'BB'
---------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on
the class C and D notes from Silverado CLO 2006-I Ltd., a U.S.
collateralized loan obligation (CLO) transaction managed by Wells
Capital Management Inc. "At the same time, we affirmed our ratings
on the class A-1-S, A-1-J, A-1, A-2, and B notes," S&P said.

"The upgrades reflect improved performance we have observed in
the transaction's underlying asset portfolio since we last
downgraded the classes on Dec. 2, 2009. As of the Jan. 5,
2012 trustee report, the transaction's asset portfolio had
no defaulted obligations and approximately $3.74 million in
assets from obligors rated in the 'CCC' range. This was down
from $4.28 million in defaulted obligations and approximately
$23.60 million in assets from obligors rated in the 'CCC' range
noted in the Oct. 6, 2009 trustee report, which we used for our
December 2009 rating actions," S&P said.

"We also observed an increase in the overcollateralization (O/C)
available to support the rated notes," S&P said. The trustee
reported the O/C ratios in the Jan. 5, 2012 monthly report:

   The A O/C ratio was 123.73%, compared with a reported ratio of
   122.64% in October 2009;

   The B O/C ratio was 115.58%, compared with a reported ratio of
   114.56% in October 2009;

   The C O/C ratio was 109.05%, compared with a reported ratio of
   108.09% in October 2009; and

   The D O/C ratio was 105.47%, compared with a reported ratio of
   104.55% in October 2009.

"We affirmed our ratings on the class A-1-S, A-1-J, A-1, A-2, and
B notes to reflect our belief that the credit support available is
commensurate with the current ratings," S&P said.

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.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

          http://standardandpoorsdisclosure-17g7.com

Rating Actions

Silverado CLO 2006-I Ltd.
                        Rating
Class              To           From
C                  BBB (sf)     BBB- (sf)
D                  BB (sf)      B+ (sf)

Ratings Affirmed

Silverado CLO 2006-I Ltd.
Class              Rating
A-1-S              AAA (sf)
A-1-J              AA+ (sf)
A-1                AA+ (sf)
A-2                AA (sf)
B                  A (sf)


SONOMA VALLEY: Moody's Lowers Rating of Series 114/2007 to 'Caa1'
-----------------------------------------------------------------
Moody's has downgraded two classes of Notes issued by Sonoma
Valley 2007-4 Synthetic CDO of CMBS Variable Rate Notes Due 2051
due to the deterioration in the credit quality of the underlying
portfolio of reference obligations as evidenced by an increase in
the weighted average rating factor (WARF). The rating action is
the result of Moody's on-going surveillance of commercial real
estate collateralized debt obligation (CRE CDO Synthetic)
transactions.

Series 114/2007, Downgraded to Caa1 (sf); previously on Feb 23,
2011 Downgraded to B3 (sf)

Series 115/2007, Downgraded to B3 (sf); previously on Feb 23, 2011
Downgraded to B2 (sf)

RATINGS RATIONALE

Sonoma Valley 2007-4 Synthetic CDO of CMBS Variable Rate Notes
Due 2051 is a static credit linked notes transaction backed
by a portfolio of tranched credit default swaps referencing
$2.3 billion notional amount of commercial mortgage backed
securities (CMBS). All of the CMBS reference obligations were
securitized in 2006 (45.2%) and 2007 (55.8%). Currently, all
of the reference obligations are rated by Moody's.

Moody's has identified the following parameters as key indicators
of the expected loss within CRE CDO transactions: WARF, weighted
average life (WAL), weighted average recovery rate (WARR), and
Moody's asset correlation (MAC). These parameters are typically
modeled as actual parameters for static deals and as covenants for
managed deals.

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's has completed updated credit estimates for the non-Moody's
rated reference obligations. The bottom-dollar WARF is a measure
of the default probability within a reference pool. Moody's
modeled a bottom-dollar WARF of 105 compared to 81 at last review.
The distribution of current ratings is as follows: Aaa (31.3%
compared to 38.3% at last review), Aa1-Aa3 (33.0% compared to
33.9% at last review), A1-A3 (17.4% compared to 7.8% at last
review), Baa1-Baa3 (16.5% compared to 20.0% at last review), and
Ba1-Ba3 (1.8% compared to 0.0% at last review).

WAL acts to adjust the probability of default of the reference
obligations in the pool for time. Moody's modeled to a WAL of 4.9
years compared to 5.7 at last review.

WARR is the par-weighted average of the mean recovery values for
the reference obligations in the pool. Moody's modeled a variable
WARR with a mean of 55.8%, compared to 63.9% at last review.

MAC is a single factor that describes the pair-wise asset
correlation to the default distribution among the instruments
within the reference obligations pool (i.e. the measure of
diversity). Moody's modeled a MAC of 40.8% compared to 50.0% at
last review.

Moody's review incorporated CDOROM(R) v2.8, one of Moody's CDO
rating models, which was released on January 24, 2011.

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
rating changes within the reference pool. Holding all other key
parameters static, changing all reference obligations' ratings or
credit estimates by one notch downward or by one notch upward,
would result in average rating movement on the rated notes of 0 to
2 notches downward and 0 to 1 notche 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 extent of the
slowdown in growth in the current macroeconomic environment and
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 in
recovery and improvements in the office sector continue, with
fundamentals in Gateway cities outperforming their suburban
counterparts. However, office demand is closely tied to
employment, where fundamentals remain weak, so significant
improvement may be delayed. Performance in the retail sector has
been mixed with on-going rent deflation and leasing challenges.
Across all property sectors, the availability of debt capital
continues to improve with monetary policy expected to remain
supportive and interest rate hikes postponed. Moody's central
global macroeconomic scenario reflects an overall downward
revision of forecasts since last quarter, amidst ongoing fiscal
consolidation efforts, household and banking sector deleveraging,
persistently high unemployment levels, and weak housing markets
that will continue to constrain growth.

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


SOUTHPORT CLO: S&P Raises Rating on Class 2 Notes From 'BB+'
------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1, A-3, C, D, and 2 notes from Southport CLO Ltd., a cash flow
collateralized loan obligation (CLO) transaction managed by
Pacific Investment Management Co. "At the same time, we affirmed
our  ratings on the class A-2 and B notes and removed the ratings
on the class A-1, A-3, B, C ,and D notes from CreditWatch, where
we placed them with positive implications on Nov, 14, 2011," S&P
said.

"The class 2 note is a combination security backed by the class B
and C notes and a portion of the class D note and equity
tranches," S&P said.

The transaction is in its amortization phase and continues to use
its principal proceeds to pay down the senior notes in the payment
sequence, as specified in the indenture.

"The class A-1 and A-2 notes received payments of $3.93 million
and $7.74 million on the Jan. 17, 2012 payment date, decreasing
the notes' outstanding balances to 38.86% and 23.59% from 89.84%
and 87.30%, in January 2011, when we last upgraded the class B
notes," S&P said.

"The transaction's payment structure pays interest pari passu to
all three class A tranches; however, class A-2 is scheduled to
receive principal payments ahead of class A-3. As a result, class
A-2 has a chance of getting fully paid before classes A-1 and A-3,
and thus can support a higher rating," S&P said.

The overcollateralization (O/C) ratios improved for all classes
due to the paydowns. The trustee reported the O/C ratios as of the
Jan. 4, 2012 monthly report, which are prior to the paydowns:

   The class A O/C ratio was 155.46%, compared with a reported
   ratio of 123.80% in January 2011;

   The class B O/C ratio was 126.22%, compared with a reported
   ratio of 112.57% in January 2011;

   The class C O/C ratio test was 112.16%, compared with a
   reported ratio of 106.15% in January 2011; and

   The class D O/C ratio test was 106.53%, compared with a
   reported ratio of 103.35% in January 2011.

"The ratios should increase once we factor in the Jan. 17, 2012
paydowns," S&P said.

The current balance of the class D note is 79.18% of its original
balance due to paydowns of approximately $2.8 million in the past
after the class had failed its O/C test. The class D O/C cure in
the interest proceeds section of the waterfall diverts available
interest proceeds -- after payment of any class D deferred
interest -- to pay down the class D note until the test is cured.

All coverage tests are currently passing. The paydowns improved
the credit support to the rated tranches leading to the upgrades.
The affirmations reflect adequate credit support at the current
ratings.

The obligor concentration supplemental test (which is part of our
criteria for rating corporate CDO transactions) affected the
ratings on the class B, C, D, and 2 notes.

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.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

              http://standardandpoorsdisclosure-17g7.com

Rating And Creditwatch Actions

Southport CLO Ltd.
                      Rating
Class             To          From
A-1               AAA (sf)    AA+ (sf)/Watch Pos
A-3               AAA (sf)    AA+ (sf)/Watch Pos
B                 A+ (sf)     A+ (sf)/Watch Pos
C                 BB+ (sf)    B+ (sf)/Watch Pos
D                 CCC+ (sf)   CCC- (sf)/Watch Pos
2                 BBB+ (sf)   BB+ (sf)

Rating Affirmed
Southport CLO Ltd.
Class             Rating
A-2               AAA (sf)


SPARKS REGIONAL: Moody's Affirms Rating of Notes Due 2012 at 'B1'
-----------------------------------------------------------------
Moody's Investors Service affirmed the ratings of three
certificates of Sparks Regional Medical Center Lease Certificates
of Participation Series 2002:

Term certificates due June 15, 2012, $2,190,000; Affirmed at B1
(sf); previously on Mar 31, 2010 Upgraded to B1 (sf)

Term certificates due June 15, 2017, $14,570,000; Affirmed at B1
(sf); previously on Mar 31, 2010 Upgraded to B1 (sf)

Term certificates due June 15, 2022, $10,175,000; Affirmed at B2
(sf); previously on Mar 31, 2010 Upgraded to B2 (sf)

RATINGS RATIONALE

The ratings of the two of certificates due June 15, 2012 and June
15, 2017, respectively, are affirmed at B1 (sf) based on the
current rating of Health Management Associates, Inc. (HMA; long
term issuer rating B1; stable outlook), which acquired
substantially all of the assets of Sparks Regional Medical Center
(Sparks), the original lessee of the facilities supporting the
transaction. The third certificate is rated lower than HMA's
rating becuase HMA's primary lease term expires prior to the final
payment date of the third certificate and the residual payment is
guaranteed by a non-rated entity. The rating of this class is
affirmed at B2 (sf).

The principal methodology used in this rating was "Commercial Real
Estate Finance: Moody's Approach to Rating Credit Tenant Lease
Financings" published in November 2011.

There was no model used in the analysis of this transaction.

Moody's ratings are determined by a committee process that
considers both quantitative and qualitative factors.

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
prior full review is summarized in a press release dated March 17,
2011.

DEAL PERFORMANCE

As of February 2, 2012, the transaction's aggregate Certificate
balance was $26.9 million. The transaction consists of three
Certificates which are due June 15, 2012, June 15, 2017, and June
15, 2022, respectively. The Certificates evidence proportionate
undivided interests in 19 medical facilities which were originally
leased to Sparks. On December 1, 2009, HMA acquired substantially
all of Sparks assets, including the assignment of Sparks' interest
under the lease supporting this transaction. The lease expires on
June 30, 2017, subject to a five-year extension option.

The scheduled lease payments are sufficient to completely pay off
the Certificates due June 2012 and June 2017. Because there still
will be an outstanding balance for the Certificates due June 2022
at the end of the tenant's initial lease term, the transaction was
structured with a residual value insurance policy issued by R.V.I.
America Insurance Company (RVI). The policy is for $10,750,000,
which is the principal amount of the Certificates due June 2022.
On February 4, 2009, Moody's downgraded RVI's financial strength
rating to Baa3 from A3 and subsequently withdrew the rating. The
rating on the Certificates due June 2022 is notched down from
HMA's rating due to the size of the loan balance at maturity
relative to the value of the collateral assuming the existing
tenant is no longer in occupancy (the "dark" value).


ST. JAMES RIVER: S&P Hikes Class E Note Rating From 'CCC+' to 'B+'
------------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-R, A-T, B, C, D, and E notes from St. James River CLO Ltd., a
collateralized loan obligation (CLO) transaction managed by Babson
Capital Management LLC. "At the same time, we removed these
ratings from CreditWatch, where we placed them with positive
implications on Nov. 14, 2011," S&P said.

"The upgrades reflect the improved performance we have observed in
the deal's underlying asset portfolio since our January 2010
rating actions. According to the Jan. 4, 2012 trustee report, the
transaction's asset portfolio held approximately $3 million of
defaulted assets, down from the $8 million noted in the December
2009 trustee report. Additionally, about 3% of the collateral pool
consisted of assets from obligors rated in the 'CCC' category in
January 2012, down from about 8% in December 2009," 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.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

          http://standardandpoorsdisclosure-17g7.com

Rating And Creditwatch Actions

St. James River CLO Ltd.
                         Rating
Class                To           From
A-R                  AA (sf)      A+ (sf)/Watch Pos
A-T                  AA (sf)      A+ (sf)/Watch Pos
B                    A+ (sf)      BBB+ (sf)/Watch Pos
C                    BBB+ (sf)    BBB (sf)/Watch Pos
D                    BBB- (sf)    BB+ (sf)/Watch Pos
E                    B+ (sf)      CCC+ (sf)/Watch Pos


STONE TOWER: S&P Raises Ratings on 2 Classes of Notes to 'BB+'
--------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-2, B, C-1, and C-2 notes from Stone Tower CLO IV Ltd., a U.S.
collateralized loan obligation (CLO) transaction managed by Stone
Tower Debt Advisors LLC. "At the same time, we affirmed our
ratings on the class A-1 and D notes," S&P said.

"The upgrades mainly reflect the improved credit performance of
the transaction's underlying asset portfolio since we lowered our
ratings on all of the notes in November 2009, following the
application of our September 2009 collateralized debt obligation
(CDO) criteria," S&P said.

"As of the January 2012 trustee report, the transaction's
collateral pool had $2.05 million in defaulted assets. This
was down from the $19.36 million in defaulted assets noted in
the October 2009 trustee report, which we referenced for our
November 2009 rating actions. Additionally, the trustee reported
$23.52 million in assets from obligors rated in the 'CCC' category
in January 2012, compared with $53.27 million in October 2009,"
S&P said.

The upgrades also reflect a slight improvement in the
overcollateralization (O/C) available to support the notes since
our November 2009 rating actions. The trustee reported the O/C
ratios in the January 2012 monthly report:

    The class A O/C ratio was 118.48%, compared with a reported
    ratio of 116.82% in October 2009;

    The class B O/C ratio was 112.30%, compared with a reported
    ratio of 110.74% in October 2009;

    The class C O/C ratio was 107.14%, compared with a reported
    ratio of 105.64% in October 2009; and

    The class D O/C ratio was 104.65%, compared with a reported
    ratio of 103.19% in October 2009.

"We affirmed our ratings on the class A-1 and D notes to reflect
the availability of credit support at the current rating levels,"
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.

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

            http://standardandpoorsdisclosure-17g7.com

Ratings Raised

Stone Tower CLO IV Ltd.
                   Rating
Class         To           From
A-2           AA (sf)      A+ (sf)
B             A (sf)       BBB+ (sf)
C-1           BB+ (sf)     B+ (sf)
C-2           BB+ (sf)     B+ (sf)

Ratings Affirmed

Stone Tower CLO IV Ltd.
Class         Rating
A-1           AA+ (sf)
D             CCC+ (sf)

Transaction Information
Issuer:             Stone Tower CLO IV Ltd.
Underwriter:        Credit Suisse AG
Collateral manager: Stone Tower Debt Advisors LLC
Trustee:            U.S. Bank N.A.
Transaction type:   Cash flow CDO


STONE TOWER: S&P Raises Rating on Class A-3L From 'CCC+' to 'B+'
----------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on 12
classes from Stone Tower CDO Ltd., Stone Tower CDO II Ltd., and
Zais Investment Grade Ltd. VI. "All three transactions are
U.S. collateralized debt obligation (CDO) transactions
predominantly backed by tranches from other CDOs of corporate
securities (CDO of corporate CDOs). The two Stone Tower deals,
managed by Stone Tower Debt Advisors LLC, also have a significant
presence of corporate bonds in their asset pools. Zais Investment
Grade Ltd. VI is managed by Zais Group LLC. At the same time, we
affirmed our ratings on class B-1L from Stone Tower CDO Ltd., and
on classes A-3L and B-1L from Stone Tower CDO II Ltd.," S&P said.

"The upgrades reflect an improvement in the underlying
performance, as well as significant paydowns to the senior notes
in all three transactions since our last rating actions," S&P
said.

"Stone Tower CDO Ltd. had $12.80 million in defaulted assets as of
the Dec. 20, 2011 trustee report, compared with the $32.69 million
noted in the Feb. 22, 2010, report, which we referenced for our
last downgrade in June 2010. The A-1LA notes of Stone Tower CDO
have paid down $52.89 million since February 2010 and have just
$62.67 million, or 42.34% of their original balance, remaining
according to the Dec. 20, 2011, trustee report," S&P said.

"Stone Tower CDO II Ltd. had $25.51 million in defaulted
assets as of the Jan. 10, 2012 trustee report, compared with the
$45.03 million noted in the March 10, 2010, report, which we
referenced for our June 2010 affirmation. Stone Tower CDO II Ltd.
hit an event of default and declared acceleration in August 2009.
Since the acceleration, the transaction has been paying down the
senior class A-1LA notes (which have paid down $99.99 million
since March 2010). They currently have just $39.11 million, or
21.14% of their original balance remaining, according to the
Jan. 10, 2012 trustee report," S&P said.

"Zais Investment Grade Ltd. VI had $54.26 million in defaulted
assets as of the Jan. 19, 2012 trustee report, compared with
$130.21 million in the March 18, 2010 report, which we referenced
for our last downgrade in May 2010. The A-1 notes have paid down
$110.17 million since March 2010 and have just $30.33 million,
or 14.72% of their original balance remaining, according to the
Jan. 19, 2012 trustee report," S&P said.

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 said.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

             http://standardandpoorsdisclosure-17g7.com

Rating Actions

Stone Tower CDO Ltd.
                      Rating
Class            To           From
A-1LA            AA (sf)      BBB+ (sf)
A-1LB            A (sf)       BBB- (sf)
A-2L             BB+ (sf)     BB- (sf)
A-3L             B+ (sf)      CCC+ (sf)

Stone Tower CDO II Ltd.
                      Rating
Class            To           From
A-1LA            AA+ (sf)     BB (sf)
A-1LB            BB+ (sf)     CCC (sf)

Zais Investment Grade Ltd. VI
                      Rating
Class            To           From
A-1              AA+ (sf)     A+ (sf)
A-2a             A+ (sf)      A- (sf)
A-2b             A+ (sf)      A- (sf)
A-3              A (sf)       BBB (sf)
B-1              B+ (sf)      B- (sf)
B-2              B+ (sf)      B- (sf)

Ratings Affirmed

Stone Tower CDO Ltd.
Class        Rating
B-1L         CCC- (sf)

Stone Tower CDO II Ltd.
Class            Rating
A-3L             CC (sf)
B-1L             CC (sf)

Other Rating Outstanding

Stone Tower CDO II Ltd.
Class            Rating
A-2L             D (sf)


STONE TOWER: S&P Upgrades Ratings on 2 Classes of Notes to 'B+'
---------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the eight
classes of notes from Stone Tower CLO III Ltd., a collateralized
loan obligation (CLO) transaction backed by U.S. corporate loans
and managed by Stone Tower Debt Advisors LLC.

The upgrades reflect an increase in the overall credit support
available to the rated notes since our December 2009 rating action
on the notes.

"Since the September 2009 monthly report, which we used for our
December 2009 action, the defaulted assets in the transaction has
decreased as of the December 2011 trustee report, which we used in
our current analysis," S&P said. As a result, the O/C ratios
increased for all classes except class D:

   The A O/C ratio was 125.99% in December 2011, compared to
   122.32% in September 2009;

   The B O/C ratio was 116.43% in December 2011, compared to
   114.92% in September 2009;

   The C O/C ratio was 109.62% in December 2011, compared to
   109.49% in September 2009; and

   The D O/C ratio was 105.59% in December 2011, compared to
   106.22% in September 2009.

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

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

          http://standardandpoorsdisclosure-17g7.com

Ratings Raised

Stone Tower CLO III Ltd.
              Rating
Class     To           From
A-1       AAA (sf)     AA+ (sf)
A-2       AAA (sf)     AA+ (sf)
A-3       AA+ (sf)     AA- (sf)
B         A+ (sf)      A- (sf)
C-1       BBB- (sf)    BB+ (sf)
C-2       BBB- (sf)    BB+ (sf)
D-1       B+ (sf)      CCC+(sf)
D-2       B+ (sf)      CCC+ (sf)


SUNRISE CDO: Moody's Raises Rating of Class A Notes to 'B2'
-----------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Sunrise CDO I, Ltd:

US$222,600,000 Class A Notes Due January 29, 2037 (current
outstanding balance of $6,665,260), Upgraded to B2 (sf);
previously on May 7, 2010 Downgraded to Caa2 (sf);

RATINGS RATIONALE

According to Moody's, the rating upgrade is the result of
deleveraging of the Class A Notes and an increase in the
transaction's overcollateralization ratio. Moody's notes that
the Class A Notes have been paid down by approximately 70% or
$15.6 million since the rating action in May 2010. As a result of
the deleveraging, the overcollateralization ratios have increased
since the rating action in May 2010. Based on the latest trustee
report dated January 24 2012, the Class A overcollateralization
ratio is reported at 170.53%, versus March 31 2010 level of
132.69. Additionally, the Trustee reported a WARF of 3747 in March
2010 compared to a WARF of 4877 in January 2012.

Sunrise CDO I, issued in December 2001, is a collateralized debt
obligation backed primarily by a large pool of corporate bonds and
some ABS securities originated from 1997 to 2000. The corporate
bond pool contributes to 62% of the collateral pool and consists
of two large corporate obligors, one of which is investment grade.

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

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

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

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

Moody's Caa Assets notched up by 2 rating notches:

Class A: +1

Moody's Caa Assets notched down by 2 rating notches:

Class A: -0


SYMPHONY CLO: S&P Raises Rating on Class D Notes to 'BB'
--------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1A, A-1B, A-2, B, C, and D notes from Symphony CLO I Ltd., a
collateralized loan obligation (CLO) transaction managed by
Symphony Asset Management LLC. "At the same time, we removed these
ratings from CreditWatch, where we placed them with positive
implications on Dec. 20, 2011," S&P said.

"The upgrades reflect the improved performance we have observed in
the deal's underlying asset portfolio since our November 2009
rating actions. According to the Jan. 12, 2012, trustee report,
the transaction's asset portfolio held approximately $0.9 million
of defaulted assets, down from the $13.4 million noted in the
October 2009 trustee report, which we referenced for our November
2009 rating actions. Additionally, about 4% of the collateral pool
consisted of assets from obligors rated in the 'CCC' category in
January 2012, down from about 8% in October 2009," 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.

             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 Represent ations,
warranties and enforcement mechanisms in issuances of similar
securities. The Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Reports
included in this credit rating report are available at:

             http://standardandpoorsdisclosure-17g7.com

Rating And Creditwatch Actions

Symphony CLO I Ltd.
                         Rating
Class                To           From
A-1A                 AA+ (sf)     AA (sf)/Watch Pos
A-1B                 AA+ (sf)     AA (sf)/Watch Pos
A-2                  AA- (sf)     A+ (sf)/Watch Pos
B                    A- (sf)      BBB+ (sf)/Watch Pos
C                    BBB- (sf)    BB+ (sf)/Watch Pos
D                    BB (sf)      B+ (sf)/Watch Pos


TELOS CLO: S&P Raises Rating on Class E Notes to 'BB'
-----------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1, A-2, B, C, D, and E notes from Telos CLO 2007-2 Ltd. Telos
CLO 2007-2 Ltd. is a collateralized loan obligation (CLO)
transaction managed by Tricadia CDO Management LLC.

"The upgrades reflect the improved performance we have
observed in the deal since our December 2009 rating actions. The
transaction has used reinvestment proceeds to build additional
overcollateralization (O/C) to support the rated notes," S&P said.
The trustee reported the principal coverage tests in its Jan. 5,
2012 trustee report:

   The class A/B O/C test was 130.71%, compared with a reported
   test of 127.92% in October 2009;

   The class C O/C test was 122.01%, compared with a reported test
   of 119.41% in October 2009;

   The class D O/C test was 114.39%, compared with a reported test
   of 111.95% in October 2009; and

   The class E O/C test was 109.43%, compared with a reported test
   of 107.09% in October 2009.

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

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

             http://standardandpoorsdisclosure-17g7.com

Rating Actions

Telos CLO 2007-2 Ltd.
                       Rating
Class               To           From
A-1                 AAA (sf)     AA+ (sf)
A-2                 AA+ (sf)     AA (sf)
B                   AA (sf)      A+ (sf)
C                   A (sf)       BBB+ (sf)
D                   BBB (sf)     BB+ (sf)
E                   BB (sf)      B+ (sf)


TERRA II: DBRS Places 'BB' Rating of Class B3 Under Review
----------------------------------------------------------
DBRS Ratings Limited has placed six ratings Under Review with
Developing Implications from the following four CLOs and CDOs
backed by non-granular portfolios of large corporate obligors.

  Figaro II Mezzanine CLO LLC
  Mesena CLO 2011-1 B.V.
  SCUTE Bali B.V.
  Terra II Mezzanine CLO LLC

The rating actions reflect the February 7, 2012 release of an
updated methodology to rate and monitor collateralized loan
obligations and collateralized debt obligations backed by non-
granular portfolios of large corporate credits.

DBRS will undertake a review to determine the impact of the
updated methodology on a transaction-by-transaction basis and will
publish updated rating actions that may either result in an
upgrade, confirmation or downgrade.

The principal methodology is that will be used is "Rating
Methodology for CLOs and CDOs of Large Corporate Credit", which
can be found on the DBRS website under Methodologies.

Ratings assigned by DBRS Ratings Limited are subject to EU
regulations only.

Terra II Mezzanine CLO LLC Class B3 CDS UR-Dev. BB (low) (sf) --
Feb 8, 2012


TIAA SEASONE: Fitch Affirms Rating on 14 Certificate Classes
------------------------------------------------------------
Fitch Ratings has affirmed 14 classes of commercial mortgage pass-
through certificates from TIAA Seasoned Commercial Mortgage Trust,
series 2007-C4 and downgraded five distressed classes.

The downgrades reflect increased Fitch modeled losses attributed
primarily to the transfer of two loans to special servicing for
declining performance.  Fitch modeled losses of 5.6% on the
current pool, compared to 5.2% of the then pool balance at Fitch's
last review.

As of the January 2012 distribution date, the pool's aggregate
principal balance has decreased 36.5% to $1.32 billion from
$2.09 billion at issuance.  Fitch has designated 11 loans (16.4%)
as Fitch Loans of Concern which includes eight specially serviced
assets (8.9%).

Fitch expects classes Q through T may be fully depleted, and class
P to be impaired, due to losses associated with the specially
serviced assets.  As of January 2012, cumulative interest
shortfalls in the amount of $1.1 million are affecting classes P
through T.

The largest contributor to Fitch expected loss consists of
two pari passu notes that are secured by two phases of a
shopping center in Algonquin, IL.  The loans, which are cross
collateralized and cross defaulted, transferred to special
servicing in August 2009 due to imminent default.  The Phase 1
loan was modified and both loans returned to the master servicer
as corrected mortgage loans in Sept. 2010.  Servicer-reported 2Q10
DSCR for Phase I was 0.73x with year-end (YE) 2011 occupancy at
84.6%, compared to 88.7% at YE 2010; 2Q11 DSCR for Phase II was
0.15x with YE 2011 occupancy at 100%, compared to 76.7% at 2Q 2011
and 51.2% at YE 2010. Occupancy of Phase II has increased due to
two new leases signed in June and August 2011.

The second largest contributor to Fitch expected loss is secured
by an 184,991 square-foot (SF) office property in King of Prussia,
PA.  The loan transferred to special servicing in Dec. 2010 due to
imminent default.  The loan subsequently defaulted on the Jan.
2011 payment.  The special servicer is in discussion with the
Borrower for workout resolutions while duel tracking with
foreclosure proceeding. The most recent valuation obtained by the
special servicer indicates losses upon liquidation of the asset.

The third largest contributor to Fitch expected loss is secured by
a 117, 936 SF office property in White Plains, N.Y.  The loan
transferred to Special Servicing in June 2009 for imminent
default. The loan remains current with the Borrower funding
operating costs and debt service shortfalls.  A loan modification
closed in June 2011 splitting the loan into a $7.5 million
interest-only A note and a $4.2 million zero interest B note.  The
loan returned to the master servicer in January 2012.

Fitch has downgraded these classes:

  -- $7.8 million class K to 'CC/RE0%' from 'CCC/RE100%';
  -- $7.8 million class L to 'CC/RE0%' from 'CCC/RE100%';
  -- $7.9 million class M to 'C/RE0%' from 'CC/RE100%';
  -- $2.6 million class N to 'C/RE0%' from 'CC/RE100%';
  -- $7.9 million class P to 'C/RE0%' from 'CC/RE60%'.

Fitch has affirmed these classes with revised Outlook and Recovery
Estimates:

  -- $130.9 million class A-2 at 'AAA'; Outlook Stable;
  -- $686 million class A-3 at 'AAA; Outlook Stable;
  -- $92.8 million class A-1A at 'AAA; Outlook Stable;
  -- $227.5 million class A-J at 'AA'; Outlook Stable;
  -- $10.5 million class B at 'A'; Outlook Stable;
  -- $28.8 million class C at 'BBB'; Outlook Stable;
  -- $18.3 million class D at 'BBB-'; Outlook Stable;
  -- $5.2 million class E at 'BB'; Outlook Stable;
  -- $15.7 million class F at 'BB'; Outlook Stable;
  -- $20.9 million class G at 'B'; Outlook Stable;
  -- $13.1 million class H at 'B-'; Outlook to Negative from
     Stable;
  -- $23.5 million class J at 'CCC'; recovery estimates to '15%'
     from '100%';
  -- $2.6 million class Q at 'C/RE0%';
  -- $2.6 million class S at 'C/RE0%'.

Class A-1 has paid in full.  Fitch does not rate the $15.7 million
class T.  Fitch withdrawn the rating on the Interest-only class X
at the previous review.


TIMES SQUARE: S&P Raises Rating on Mortgage Certs. From 'BB+'
-------------------------------------------------------------

Standard & Poor's Ratings Services raised its rating on Times
Square Hotel Trust's mortgage and lease amortizing certificates to
'BBB-' from 'BB+'. The outlook is stable.

The action follows the Feb. 14, 2012, raising of the corporate
credit rating on Starwood Hotels & Resorts Worldwide Inc. (BBB-
/Stable/--).

"We based our rating on the Times Square Hotel Trust transaction
on the payments and obligations made by Starwood pursuant to a
triple-net-lease for the W New York - Times Square Hotel on
Broadway at 47th Street in Manhattan," S&P said.

             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 Represent ations,
warranties and enforcement mechanisms in issuances of similar
securities. The Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Reports
included in this credit rating report are available at:

            http://standardandpoorsdisclosure-17g7.com


VERTICAL CRE: Fitch Affirms Junk Ratings on Seven Note Classes
--------------------------------------------------------------
Fitch Ratings has downgraded one and affirmed seven classes issued
by Vertical CRE CDO 2006-1 Ltd./Corp. (Vertical 2006-1).

Since Fitch's last rating action in March 2011, approximately 11%
of the collateral has been downgraded.  Currently, 85.9% of the
portfolio has a Fitch derived rating below investment grade and
79% has a rating in the 'CCC' category and below, compared to
81.5% and 63.6%, respectively, at the last rating action.
Additionally, the class A notes have received $45.9 million in
paydowns since the last rating action for a total of $74.3 million
in principal repayment since issuance.

On the Sept. 22, 2009 payment date, the overcollateralization (OC)
Default Trigger fell below 105% which resulted in an Event of
Default.  On Oct. 8, 2009, the Holder of a majority in Aggregate
Principal Amount of the class A notes and the class B notes,
voting together as a single class, declared the principal of the
notes to be immediately due and payable.  As a result of the
acceleration, the class B notes have missed their interest payment
since the Oct. 22, 2009 payment date.  Therefore, the class B
notes, rated to the timely receipt of interest, have been affirmed
at 'Dsf'.

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 Rating Loss Rates (RLR)
were then compared to the credit enhancement of the classes.
Based on the credit enhancement the class A notes fall below the
'CCC' RLR. Fitch then analyzed the class' sensitivity to the
default of the distressed assets ('CCC' and below).  For the class
A notes, Fitch analyzed the recovery prospects for the remaining
collateral and determined that while significant recoveries are
possible, it is probable that the class will not recover its
current balance in full.  Thus, the class A notes have been
downgraded to 'CCsf'.  For the class C through H notes, default
continues to seem inevitable as the notes are reliant on
collateral with limited recovery prospects rated 'C' or 'D' to
perform.

Vertical 2006-1 is a collateralized debt obligation (CDO) issued
in May 2006.  The portfolio is composed of 49.4% of large loan
commercial mortgage backed securities (CMBS), 30.8% of structured
finance CDOs, 12.1% of commercial real estate loans (CREL), and
7.7% of single borrower or conduit CMBS assets.  In general, Fitch
treats CMBS Rake bonds and single-borrower CMBS as CREL. There are
36 assets from 20 obligors remaining.

Fitch has downgraded this class:

  -- $97,643,811 class A notes to 'CCsf' from 'CCCsf'.

Fitch has affirmed these classes:

  -- $29,000,000 class B notes at 'Dsf';
  -- $10,000,000 class C notes at 'Csf';
  -- $4,000,000 class D notes at 'Csf';
  -- $12,000,000 class E notes at 'Csf';
  -- $5,000,000 class F notes at 'Csf';
  -- $10,500,000 class G notes at 'Csf';
  -- $4,000,000 class H notes at 'Csf'.


WACHOVIA BANK: S&P Cuts Ratings on 2 Cert. Classes to 'D'
---------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on three
classes of commercial mortgage pass-through certificates from
Wachovia Bank Commercial Mortgage Trust's series 2006-C23, a U.S.
commercial mortgage-backed securities (CMBS) transaction. "At the
same time, we lowered our ratings on four classes and affirmed our
ratings on 13 other classes from the same transaction," S&P said.

"The upgrades primarily reflect increased credit enhancement
levels due to deleveraging of the pool balance and improved
performance of several of the top 10 loans, including the Prime
Outlets Pool loan (8.2%), the 620 Avenue of the Americas loan
(5.6%), the Hyatt Center loan (4.4%), and the Marriott -Irving, TX
loan (1.5%)," S&P said.

"The downgrades primarily reflect credit support erosion that
we anticipate will occur upon the eventual resolution of 17
($211.0 million, 5.8%) of the transaction's 19 ($303.0 million,
8.3%) assets with the special servicer, and reduced liquidity
support available to theses classes due to interest shortfalls.
As of the Jan. 18, 2012 trustee remittance report, the trust
experienced net monthly interest shortfalls totaling $307,241,
which reflected one-time appraisal subordinate entitlement
reduction (ASER) recoveries totaling $91,197. The shortfalls were
primarily due to ASER amounts ($264,822, exclusive of the ASER
recoveries), loan interest rate modifications ($57,951), and
special servicing and workout fees ($75,666)," S&P said.

"The net interest shortfalls affected all classes subordinate
to and including class K. Our analysis indicated that the total
anticipated recurring monthly interest shortfalls will cause
continued interest shortfalls for class M and the classes
subordinate to it for the foreseeable future. We also expect
that recurring interest shortfalls will lead to a reduction in
the liquidity support available to the classes senior to class M.
As a result of our analysis, we lowered our ratings on classes M
and N to 'D (sf)'," S&P said.

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

"Our analysis included a review of the credit characteristics
of all of the remaining assets in the pool. Using servicer-
provided financial information, we calculated an adjusted debt
service coverage (DSC) of 1.53x and a loan-to-value (LTV) ratio
of 105.1%. We further stressed the loans' cash flows under our
'AAA' scenario to yield a weighted average DSC of 0.92x and an
LTV ratio of 144.3%. The implied defaults and loss severity
under the 'AAA' scenario were 85.4% and 35.2%. All of the DSC
and LTV calculations exclude 17 ($211.0 million, 5.8%) of the
transaction's 19 ($303.0 million, 8.3%) specially serviced assets,
one loan ($4.0 million, 0.1%) we determined to be credit-impaired,
and two defeased loans ($13.9 million, 0.4%). We separately
estimated losses for the excluded specially serviced and credit-
impaired assets and included them in the 'AAA' scenario implied
default and loss severity figures," S&P said.

                     Transaction Summary

As of the Jan. 18, 2012 trustee remittance report, the collateral
pool had a trust balance of $3.65 billion, down from $4.23 billion
at issuance. The pool currently includes 274 loans and 13 REO
assets. The master servicer, Wells Fargo Bank N.A., provided
financial information for 94.5% of the loans in the pool, the
majority of which was full-year 2010 (53.5%) or interim 2011
(38.8%) data.

"We calculated a weighted average DSC of 1.34x for the pool based
on the reported figures. Our adjusted DSC and LTV ratio were 1.53x
and 105.1%, which exclude 17 ($211.0 million, 5.8%) of the
transaction's 19 ($303.0 million, 8.3%) specially serviced assets,
one loan ($4.0 million, 0.1%) we determined to be credit-impaired,
and two defeased loans ($13.9 million, 0.4%). We separately
estimated losses for the excluded specially serviced and credit-
impaired assets. We considered the recent expiration of a free
rent period for the largest tenant at the property securing the
620 Avenue of the Americas loan ($205.0 million, 5.6%) in our
adjusted DSC and LTV ratio. To date, the trust has experienced
$46.6 million in principal losses related to six assets. Sixty-
three loans ($915.3 million, 25.1%), including three of the top 10
loans in the pool, are on the master servicer's watchlist. Sixty
loans ($966.3 million, 26.5%) have reported DSC of less than
1.10x, 35 of which ($503.0 million, 13.8%) have reported DSC below
1.00x," S&P said.

                     Summary of Top 10 Loans

"The top 10 loans have an aggregate outstanding trust balance
of $1.19 billion (32.8%). Using servicer-reported numbers, we
calculated a weighted average DSC of 1.23x for the top 10 loans.
Our adjusted DSC and LTV ratio for the top 10 loans were 1.41x and
107.3%. We considered the recent expiration of a free rent period
for the largest tenant at the property securing the 620 Avenue of
the Americas loan ($205.0 million, 5.6%) in our adjusted DSC and
LTV ratio. Three ($402.9 million, 11.1%) of the top 10 loans are
on the master servicer's watchlist," S&P said.

"The 620 Avenue of the Americas loan ($205.0 million, 5.6%), the
second-largest loan in the pool, is secured by a 669,513-sq.-ft.
office building in Manhattan. The loan appears on the master
servicer's watchlist due to a low reported DSC, which was 0.59x
for year-to-date September 2011. Reported occupancy was 90.5% for
the same period. According to the master servicer's comments, the
low DSC is due to a free rent period associated with tenant NYC
Union Building Services (249,833-sq.-ft.). The free rent period
has since expired, and the tenant currently pays $38 per sq. ft.,
which we considered in our analysis of the loan," S&P said.

"The Belmar loan ($125.5 million, 3.4%), the fourth-largest loan
in the pool, is secured by an 813,357-sq.-ft., mixed-use center
in Lakewood, Colo. The loan appears on the master servicer's
watchlist due to a low reported DSC, which was 1.08x as of year-
end 2010. Reported occupancy was 93.0% as of June 30, 2011.
According to the master servicer, the low DSC is due to a decrease
in base rent and concessions for existing retail tenants," S&P
said.

"The InterContinental Hotel - Kansas City, MO loan ($72.3 million,
2.0%), the sixth-largest loan in the pool, is secured by a 366-
room, full-service hotel in Kansas City, Mo. The loan appears on
the master servicer's watchlist due to a low reported DSC, which
was 1.19x as of the trailing-12-months ended September 2011.
Reported occupancy was 65.5% as of the same period. According
to the master servicer, the low DSC is due to the loan payments
converting to principal and interest payments (from interest-only)
in March 2011," S&P said.

                          Credit Considerations

As of the Jan. 18, 2012 trustee remittance report, 19
($303.0 million, 8.3%) assets in the pool were with the
special servicer, CWCapital Asset Management LLC (CWCapital).
The reported payment status of the specially serviced assets
is: 13 ($122.1 million, 3.3%) are real estate-owned (REO), one
($24.3 million, 0.7%) is in foreclosure, two ($30.6 million, 0.8%)
are three or more months delinquent, two ($80.5 million, 2.2%) are
less than one month delinquent, and one ($45.5 million, 1.25%) is
current. Appraisal reduction amounts (ARAs) totaling $84.4 million
were in effect for 15 of the specially serviced assets. The three
largest specially serviced assets are set forth:

The 3500 Maple loan is the largest loan with the special servicer,
and has a trust balance of $46.4 million (1.3%) and total exposure
of $46.7 million.

The loan is secured by a 376,862-sq.-ft. office building in
Dallas. The loan was transferred to CWCapital on Nov. 9, 2011, for
imminent monetary default. The reported payment status of the loan
is late, but less than one month delinquent. CWCapital is
currently reviewing the loan file to determine a workout strategy.
The most recent reported DSC and occupancy were 1.08x and 85.0% as
of year-end 2010.

The Highland and Lodge Pool loan is the second-largest loan
reported as being specially serviced as per the Jan. 18, 2012,
trustee remittance report. The loan has a trust balance and total
exposure of $45.5 million (1.3%). The loan is secured by two
multifamily properties totaling 918 units in Overland Park, Kan.
The loan was transferred to the special servicer on Nov. 19 2010,
due to imminent default. The reported payment status of the loan
is current. According to both the master and special servicer, the
loan was modified, extended, and returned to the master servicer
on Nov. 17, 2011, and will be reflected in the February 2012
trustee remittance report. The most recent reported DSC and
occupancy were 1.52x and 95.0% as of year-to-date September 2011.

"The Monteverde Apartments loan is the third-largest asset with
the special servicer, and has a trust balance of $37.6 million
(1.0%) and total exposure of $42.1 million. The collateral is a
435-unit multifamily property in Phoenix. The loan was transferred
to the special servicer on April 22, 2009, due to imminent
monetary default, and the asset became REO on Oct. 8, 2009.
Recent financial reporting information was not available. A
$13.1 million ARA is in effect against the asset. We expect a
significant loss upon the resolution of this asset," S&P said.

"The 16 remaining assets with the special servicer have individual
balances that represent less than 1.0% of the total pool balance.
ARAs totaling $71.3 million are in effect against 14 of these
assets. We estimated losses for the 16 assets, arriving at a
weighted average loss severity of 47.5%," S&P said.

"According to the master servicer, nine loans totaling
$380.7 million (9.0% of initial pool balance) were previously with
the special servicer and have since been returned to the master
servicer. Pursuant to the transaction documents, the special
servicer is entitled to a workout fee that is 1.0% of all future
principal and interest payments if the loans perform and remain
with the master servicer," S&P said.

Standard & Poor's stressed the assets in the pool according to its
current criteria, and the analysis is consistent with its rating
actions.

             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 Represent ations,
warranties and enforcement mechanisms in issuances of similar
securities. The Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Reports
included in this credit rating report are available at:

             http://standardandpoorsdisclosure-17g7.com

Ratings Raised

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2006-C23

            Rating
Class    To        From        Credit enhancement (%)
A-4      AAA (sf)  AA- (sf)                     33.51
A-5      AAA (sf)  AA- (sf)                     33.51
A-1A     AAA (sf)  AA- (sf)                     33.51

Ratings Lowered

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2006-C23

            Rating
Class    To        From        Credit enhancement (%)
J        B- (sf)   B (sf)                        4.38
K        CCC- (sf) CCC (sf)                      2.93
M        D (sf)    CCC- (sf)                     2.06
N        D (sf)    CCC- (sf)                     1.62

Ratings Affirmed

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2006-C23

Class    Rating                Credit enhancement (%)
A-PB     AAA (sf)                               33.51
A-M      A- (sf)                                21.91
A-J      BBB- (sf)                              14.38
B        BB+ (sf)                               13.36
C        BB (sf)                                11.91
D        BB- (sf)                               10.90
E        B+ (sf)                                10.03
F        B+ (sf)                                 8.87
G        B+ (sf)                                 7.42
H        B (sf)                                  5.97
L        CCC- (sf)                               2.64
X-P      AAA (sf)                                 N/A
X-C      AAA (sf)                                 N/A

N/A -- Not applicable.


WACHOVIA BANK: S&P Downgrades Ratings on Class 37 Ratings
---------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 37
classes from 14 U.S. residential mortgage-backed securities
(RMBS) transactions and removed one of them from CreditWatch with
negative implications. "In addition, we affirmed our ratings on
155 classes from 28 of the transactions reviewed and removed five
of them from CreditWatch negative. We subsequently withdrew five
of the lowered ratings and 35 of the affirmed ratings due to the
small number of loans remaining and the potential for performance
volatility. We also withdrew our ratings on two additional classes
from two transactions: one based on our IO criteria and one
because it received its full amount of principal," S&P said.

The complete rating list is available for free at:

    http://bankrupt.com/misc/S&P_Ratings_02162012.pdf

"The 30 RMBS transactions included in our review are backed by
prime jumbo, Alternative-A (Alt-A), and subprime mortgage loan
collateral. A combination of subordination, overcollateralization,
excess spread, bond insurance, and pool insurance provides credit
support for the affected transactions," S&P said.

"The downgrades reflect our belief that projected credit
enhancement for the affected classes will likely be insufficient
to cover the projected losses we applied at the previous rating
stresses. The affirmations reflect our belief that projected
credit enhancement available for these classes will likely be
sufficient to cover projected losses associated with these rating
levels," S&P said.

"We subsequently withdrew our ratings on certain affected
classes that are backed by a pool with a small number of
remaining loans. If any of the remaining loans in these pools
default, the resulting loss could have a greater effect on the
pool's performance than if the pool consisted of a larger number
of loans. Because this performance volatility may have an adverse
affect on our outstanding ratings, we withdrew our ratings on the
related transactions," S&P said.

"In order to maintain a 'B' rating on a class from a prime jumbo
transaction, we assessed whether, in our view, a class could
absorb the remaining base-case loss assumptions we used in our
analysis. In order to maintain a rating higher than 'B', we
assessed whether a class could withstand losses exceeding the
base-case loss assumptions at a percentage specific to each rating
category, up to 235% of remaining losses for an 'AAA' rating. For
example, in general, we would assess whether one class could
withstand approximately 127% of our remaining base-case loss
assumption to maintain a 'BB' rating, while we would assess
whether a different class could withstand approximately 154% of
our remaining base-case loss assumption to maintain a 'BBB'
rating. Each class that we affirmed at 'AAA (sf)' can, in our
view, withstand approximately 235% of our remaining base-case loss
assumption under our analysis," S&P said.

"In order to maintain a 'B' rating on a class from an Alt-A or
subprime transaction, we assessed whether, in our view, a class
could absorb the remaining base-case loss assumptions we used in
our analysis. In order to maintain a rating higher than 'B', we
assessed whether a class could withstand losses exceeding the
base-case loss assumptions at a percentage specific to each rating
category, up to 150% of remaining losses for an 'AAA' rating. For
example, in general, we would assess whether one class could
withstand approximately 110% of our remaining base-case loss
assumption to maintain a 'BB' rating, while we would assess
whether a different class could withstand approximately 120% of
our remaining base-case loss assumption to maintain a 'BBB'
rating. Each class that we affirmed at 'AAA (sf)' can, in our
view, withstand approximately 150% of our remaining base-case loss
assumption under our analysis," S&P said.

"Classes rated 'CCC (sf)' and 'CC (sf)' reflect our assessment
that the credit enhancement for these classes will remain
insufficient to cover projected losses," S&P said.

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

Losses And Delinquencies*

Citibank N.A.
        Original    Pool    Cum.          Total         Severe
         balance  factor  losses  delinquencies  delinquencies
Series  (mil. $)     (%)     (%)            (%)            (%)
1987- B      125    0.32    1.25          31.45          10.53
1987- F      126    0.39    2.74          26.86          26.86

Citicorp Mortgage Securities Inc.
        Original    Pool    Cum.          Total         Severe
         balance  factor  losses  delinquencies  delinquencies
Series  (mil. $)     (%)     (%)            (%)            (%)
1987- 3       78    0.35    1.99          25.81           6.86
1987-10       75    0.34    3.30           0.00           0.00

Credit Suisse First Boston Mortgage Securities Corp.
        Original    Pool    Cum.          Total         Severe
         balance  factor  losses  delinquencies  delinquencies
Series  (mil. $)     (%)     (%)            (%)            (%)
2005-7       315   34.19    0.61           7.91           6.70
2005-7       191   38.82    3.19          15.92          12.41
2005-7       302   20.79    0.17           6.96           6.03

DLJ Mortgage Acceptance Corp.
        Original    Pool    Cum.          Total         Severe
         balance  factor  losses  delinquencies  delinquencies
Series  (mil. $)     (%)     (%)            (%)            (%)
1991- 3       65    0.96    2.17           0.00           0.00

First Alliance Mortgage Loan Trust
        Original    Pool    Cum.          Total         Severe
         balance  factor  losses  delinquencies  delinquencies
Series  (mil. $)     (%)     (%)            (%)            (%)
1999-2        35    1.21    0.76           0.00           0.00
1999-2        55    2.68    0.51           9.27           9.27

First Horizon Mortgage Pass Through Trust
        Original    Pool    Cum.          Total         Severe
         balance  factor  losses  delinquencies  delinquencies
Series  (mil. $)     (%)     (%)            (%)            (%)
2006-AR1     213   36.20    3.39          11.88          10.21

GSR Mortgage Loan Trust
        Original    Pool    Cum.          Total         Severe
         balance  factor  losses  delinquencies  delinquencies
Series  (mil. $)     (%)     (%)            (%)            (%)
2006-AR2     907   45.46    4.81          18.51          13.65
2006-AR2      56    6.25    1.08           0.00           0.00

Housing Securities Inc.
        Original    Pool    Cum.          Total         Severe
         balance  factor  losses  delinquencies  delinquencies
Series  (mil. $)     (%)     (%)            (%)            (%)
1992-SL1      71    0.54    0.00           3.41           1.23
1992-SL1      25    0.98    0.00           4.25           0.00

Lehman ABS Corp.
        Original    Pool    Cum.          Total         Severe
         balance  factor  losses  delinquencies  delinquencies
Series  (mil. $)     (%)     (%)            (%)            (%)
2004-1       228   30.63    0.75           6.36           5.16
2004-1       301   31.06    0.75           6.16           3.74

MASTR Adjustable Rate Mortgages Trust
        Original    Pool    Cum.          Total         Severe
         balance  factor  losses  delinquencies  delinquencies
Series  (mil. $)     (%)     (%)            (%)            (%)
2003-1       163    0.86    0.00          22.37          22.37
2003-1        92    2.89    0.19           2.03           2.03

MASTR Asset Securitization Trust
        Original    Pool    Cum.          Total         Severe
         balance  factor  losses  delinquencies  delinquencies
Series  (mil. $)     (%)     (%)            (%)            (%)
2002-8       860    2.63    0.00          10.30           8.51
2004-6       109    30.75   0.00           0.00           0.00
2004-6       732    22.10   0.05           2.54           1.27

MASTR Seasoned Securitization Trust
        Original    Pool    Cum.          Total         Severe
         balance  factor  losses  delinquencies  delinquencies
Series  (mil. $)     (%)     (%)            (%)            (%)
2005-1       428   13.14    0.23          13.53           8.87

Mellon Residential Funding Corp.
        Original    Pool    Cum.          Total         Severe
         balance  factor  losses  delinquencies  delinquencies
Series  (mil. $)     (%)     (%)            (%)            (%)
1998-2       524    0.10    0.00           0.00           0.00

Morgan Stanley Mortgage Loan Trust
        Original    Pool    Cum.          Total         Severe
         balance  factor  losses  delinquencies  delinquencies
Series  (mil. $)     (%)     (%)            (%)            (%)
2004-9       337   28.79    1.01          20.00          12.29

Nomura Asset Securities Corp.
        Original    Pool    Cum.          Total         Severe
         balance  factor  losses  delinquencies  delinquencies
Series  (mil. $)     (%)     (%)            (%)            (%)
1994-3       311    0.29    0.12          16.02          16.02

RAMP Trust
        Original    Pool    Cum.          Total         Severe
         balance  factor  losses  delinquencies  delinquencies
Series  (mil. $)     (%)     (%)            (%)            (%)
2004-SL2     499   11.45    1.08          11.00           9.18

Ryland Mortgage Securities Corp.
        Original    Pool    Cum.          Total         Severe
         balance  factor  losses  delinquencies  delinquencies
Series  (mil. $)     (%)     (%)            (%)            (%)
1991-16      284    0.25    0.00          10.74           0.00

Salomon Brothers Mortgage Securities VII Inc.
        Original    Pool    Cum.          Total         Severe
         balance  factor  losses  delinquencies  delinquencies
Series  (mil. $)     (%)     (%)            (%)            (%)
1996-5        56    1.60    2.90          34.36          30.38

Structured Asset Securities Corp.
        Original    Pool    Cum.          Total         Severe
         balance  factor  losses  delinquencies  delinquencies
Series  (mil. $)     (%)     (%)            (%)            (%)
2002-16A     400    2.46    0.47          18.25          18.25
2003-2A      550    4.23    0.26          16.25          16.25

Structured Mortgage Asset Residential Trust
        Original    Pool    Cum.          Total         Severe
         balance  factor  losses  delinquencies  delinquencies
Series  (mil. $)     (%)     (%)            (%)            (%)
1992- 6      125    0.00    0.00           0.00           0.00
1992- 6      400    0.12    0.00           0.00           0.00
1992- 8      350    0.12    0.00           0.00           0.00
1992-11      100    0.00    0.00           0.00           0.00
1992-11      300    0.05    0.00           0.00           0.00
1993- 4      250    0.13    0.00           0.00           0.00
1993- 5        9    0.00    0.00           0.00           0.00
1993- 5       11    0.00    0.00           0.00           0.00
1993- 5      271    0.18    0.00           0.00           0.00
1993- 6      154    0.39    0.00           6.90           6.90
1993- 6        9    2.26    0.00           0.00           0.00

*Cumulative losses represent the percentage of the original pool
balance, and total and severe delinquencies represent the
percentage of the current pool balance.

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Report
included in this credit rating report is available at;

           http://standardandpoorsdisclosure-17g7.com


WACHOVIA BANK: S&P Lowers Rating on Class E Cert. to 'D'
--------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on five
classes of commercial mortgage pass-through certificates from
Wachovia Bank Commercial Mortgage Trust's series 2006-C29, a U.S.
commercial mortgage-backed securities (CMBS) transaction. "In
addition we affirmed our ratings on seven other classes from the
same transaction," S&P said.

"The downgrades primarily reflect credit support erosion that
we anticipate will occur upon the eventual resolution of 15
($283.5 million, 9.4%) of the transaction's 18 ($481.5 million,
16.0%) specially serviced assets, and a reduction in the liquidity
support available to these classes due to interest shortfalls.
As of the Jan. 18, 2012, trustee remittance report, the pool
experienced monthly interest shortfalls totaling $1.1 million,
primarily due to appraisal subordinate entitlement reduction
(ASER) amounts ($592,123), loan interest rate modifications
($237,612), interest not advanced on assets that have been deemed
nonrecoverable by the master servicer ($117,053), and special
servicing and workout fees ($100,271). The interest shortfalls
affected all classes subordinate to and including class E. Our
analysis indicated that the total anticipated recurring monthly
interest shortfalls will cause class E and the classes subordinate
to it to continue to experience interest shortfalls for the
foreseeable future, and lead to a reduction in the liquidity
support available to the classes senior to it. As a result of our
analysis, we lowered our rating on class E to 'D (sf)'," S&P said.

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

"Our analysis included a review of the credit characteristics of
all of the remaining assets in the pool. Using servicer-provided
financial information, we calculated an adjusted debt service
coverage (DSC) of 1.65x and a loan-to-value (LTV) ratio of 115.1%.
We further stressed the loans' cash flows under our 'AAA' scenario
to yield a weighted average DSC of 0.87x and an LTV ratio of
148.3%. The implied defaults and loss severity under the 'AAA'
scenario were 89.7% and 37.5%, respectively. All of the DSC and
LTV calculations we exclude 15 ($283.5 million, 9.4%) of the
transaction's 18 ($481.5 million, 16.0%) specially serviced
assets. We separately estimated losses for the excluded specially
serviced assets and included them in the 'AAA' scenario implied
default and loss severity figures," S&P said.

                   Credit Considerations

"As of the Jan. 18, 2012 trustee remittance report, and based on
our subsequent discussions with the special servicer, Situs Asset
Management (Situs), 18 ($481.5 million, 16.0%) assets in the pool
were with the special servicer, including the First Common
Industrial Buildings loan ($6.2 million, 0.2%), which was
transferred subsequent to the January report date due to monetary
default. One specially serviced loan, the Hilton - Providence, RI
loan ($49.0 million, 1.6%), was modified to an A/B note structure
with the A note ($25.0 million, 0.8%) being reported as late, but
less than 30 days delinquent, and the B note ($24.0 million, 0.8%)
being reported as current. The reported payment status for the
remaining 17 specially serviced assets is: nine ($189.5 million,
6.3%) are real estate-owned (REO); six ($214.4 million, 7.1%) are
90-plus days delinquent; one ($6.2 million, 0.2%) is 60 days
delinquent; and one ($22.4 million, 0.7%) is a matured balloon
loan. Appraisal reduction amounts (ARAs) totaling $182.1 million
were in effect for 16 of the specially serviced assets," S&P said.

"The Renaissance Tower Office Building loan ($129.0 million,
4.3%), the largest specially serviced asset and sixth-largest loan
in the pool, is secured by a 1.7 million-sq.-ft. office building
built in 1974 and located in the Dallas central business district.
The loan was transferred to the special servicer on May 13, 2011,
for imminent monetary default and has total trust exposure of
$133.4 million. The loan was reported as being 90-plus-days
delinquent. There is an ARA of $32.3 million in effect against the
asset. According to Situs, they are in ongoing modification
discussions with the borrower. The loan had a reported DSC of
1.42x as year end 2010, with reported occupancy of 73.9% as of
the same period; however, reported occupancy has since declined to
61.3% according to the December 2011 rent roll," S&P said.

"The 17 remaining specially serviced assets have individual
balances that represent less than 1.7% of the total pool balance.
ARAs totaling $149.9 million are in effect against 15 of the
assets. We estimated losses for 15 of the assets, arriving at a
weighted average loss severity of 47.3%," S&P said.

                   Transaction Summary

"As of the Jan. 18, 2012 trustee remittance report, the
collateral pool had a trust balance of $3.02 billion, down from
$3.37 billion at issuance. The pool currently includes 123 loans
and nine REO assets. The master servicer, Wells Fargo Commercial
Mortgage Servicing, provided financial information for 90.5% of
the pool (by balance), the majority of which reflected full-year
2010 or partial-year 2011 data," S&P said.

"We calculated a weighted average DSC of 1.45x for the pool
based on the reported figures. Our adjusted DSC and LTV ratio
were 1.65x and 115.1%, and exclude 15 ($283.5 million, 9.4%) of
the transaction's 18 ($481.5 million, 16.0%) specially serviced
assets. We separately estimated losses for the excluded assets.
Our adjusted figures consider more recent operating information,
as compared to the reported figures. To date, the trust has
experienced $9.3 million in principal losses related to five
assets. Thirty-eight loans ($540.8 million, 17.9%), including one
($100.0 million, 3.3%) of the top 10 loans in the pool, are on the
master servicer's watchlist. Twenty-five ($406.7 million, 13.5%)
loans have reported DSC under 1.10x, 19 ($332.7 million, 11.0%) of
which have reported DSC under 1.00x," S&P said.

                      Summary of Top 10 Loans

"The top 10 loans have an aggregate outstanding trust balance of
$1.40 billion (46.5%). Using servicer-reported numbers, we
calculated a weighted average DSC of 1.54x for the top 10 loans.
Our adjusted DSC and LTV ratio for the top 10 loans were 1.68x
and 114.9% based on more recent operating information. One
($129.0 million, 4.3%) of the top 10 loans is specially serviced,
while another ($100.0 million, 3.3%) is on the master servicer's
watchlist," S&P said.

"The 21-25 West 34th Street loan ($100.0 million, 3.3%),
the seventh-largest loan in the pool, appears on the master
servicer's watchlist due to a low reported DSC, which was 0.98x as
of June 30, 2011. The loan is secured by 27,900 sq. ft. of retail
space in New York City, which, according to the master servicer's
comments, is 100% leased by Apple Corp. and subleased to Espirit
until Jan. 31, 2022," S&P said.

Standard & Poor's stressed the assets in the pool according to its
current criteria, and the analysis is consistent with the lowered
and affirmed ratings.

             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 Represent ations,
warranties and enforcement mechanisms in issuances of similar
securities. The Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Reports
included in this credit rating report are available at:

             http://standardandpoorsdisclosure-17g7.com

Ratings Lowered

Wachovia Bank Commercial Mortgage Securities Trust
Commercial mortgage pass-through certificates series 2006-C29

             Rating
Class  To              From          Credit enhancement (%)
A-J    BB (sf)         BB+ (sf)                       11.96
B      BB- (sf)        BB  (sf)                       11.13
C      B+ (sf)         BB- (sf)                       10.01
D      B- (sf)         B+  (sf)                        9.04
E      D (sf)          CCC- (sf)                       7.50

Ratings Affirmed

Wachovia Bank Commercial Mortgage Securities Trust
Commercial mortgage pass-through certificates series 2006-C29

Class    Rating                Credit enhancement (%)
A-2      AAA (sf)                               33.16
A-3      AAA (sf)                               33.16
A-PB     AAA (sf)                               33.16
A-4      AAA (sf)                               33.16
A-1A     AAA (sf)                               33.16
A-M      A- (sf)                                22.01
IO       AAA (sf)                                 N/A

N/A -- Not applicable.


WASATCH CLO: S&P Lowers Class IV Note Rating From 'B' to 'CCC-'
---------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1a, A-1b, A-2, B, C, and D notes from Wasatch CLO Ltd., a U.S.
collateralized loan obligation (CLO) transaction managed by
INVESCO Senior Secured Management Inc. "Simultaneously, we removed
our ratings on these notes from CreditWatch, where we had placed
them with positive implications on Nov. 14, 2011. At the same
time, we lowered our rating on the class type IV notes to 'CCC-
(sf)' from 'B (sf)'," S&P said.

"The upgrades reflect improved performance in the deal's
underlying asset portfolio and an increase in the credit support
available to the notes since we lowered our ratings on all the
classes in March 2010 following the application of our September
2009 corporate collateralized debt obligation (CDO) criteria," S&P
said.

"As of the January 2012 trustee report, the transaction's asset
portfolio had $3.474 million in defaulted assets, down from
$39.157 million in the February 2010 trustee report, which we used
for the analysis in the March 2010 rating actions. Many of the
defaults were sold at prices higher than the assumed recovery
rates," S&P said.

In addition, the transaction's overcollateralization (O/C) ratios
have increased since February 2010. The trustee reported the O/C
ratios in the January 2012 monthly report:

   The class A-2 O/C ratio was 123.85%, compared with a reported
   ratio of 120.07% in February 2010;

   The class B O/C ratio was 114.27% compared with a reported
   ratio of 110.79% in February 2010;

   The class C O/C ratio was 108.55%, compared with a reported
   ratio of 105.24% in February 2010; and

   The class D O/C ratio was 106.16%, compared with a reported
   ratio of 102.92% in February 2010.

"The class type IV notes are backed by a Fermat CSO note ('CCC-
(sf)') and a subordinated note component of Wasatch CLO Ltd. Given
class type IV's reliance on some portion of Fermat CSO notes'
principal and interest distributions, we lowered our rating on the
class type IV notes to 'CCC- (sf)'," S&P said.

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

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

             http://standardandpoorsdisclosure-17g7.com

Rating Actions

Wasatch CLO Ltd.
                        Rating
Class              To           From
A-1a               AA+ (sf)     AA- (sf)/Watch Pos
A-1b               AA+ (sf)     AA- (sf)/Watch Pos
A-2                AA (sf)      A+ (sf)/Watch Pos
B                  A- (sf)      BBB+ (sf)/Watch Pos
C                  BBB- (sf)    BB+ (sf)/Watch Pos
D                  BB (sf)      B+ (sf)
Type IV            CCC- (sf)    B (sf)

Transaction Information
Issuer:             Wasatch CLO Ltd.
Co-Issuer:          Wasatch CLO Corp.
Collateral Manager: INVESCO Senior Secured Management Inc.
Underwriter:        JPMorgan Securities Inc.
Indenture Trustee:  Bank of New York Mellon (The)
Transaction type:   Cash flow CDO


* Fitch Lowers Ratings on 31 CMBS Bonds to 'D'
----------------------------------------------
Fitch Ratings has downgraded 31 bonds in 18 U.S. commercial
mortgage-backed securities (CMBS) transactions to 'D', as the
bonds have incurred a principal write-down.  The bonds were all
previously rated 'CC' or 'C' which indicates that Fitch expected a
default.

The action is limited to just the bonds with write-downs.  The
remaining bonds in these transactions have not been analyzed as
part of this review.  Fitch has downgraded the bonds to 'D' as
part of the ongoing surveillance process and will continue to
monitor these transactions for additional defaults.


* S&P Lowers Ratings on 12 Classes from 4 U.S. RMBS re-REMIC Deals
------------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 12
classes from four residential mortgage-backed securities (RMBS)
resecuritized real estate mortgage investment conduit (re-REMIC)
transactions issued in 2009-2010 and removed one of them from
CreditWatch with negative implications. "In addition, we affirmed
our ratings on 276 classes from the transactions with lowered
ratings and seven other transactions and removed 28 of them from
CreditWatch negative," S&P said.

"In performing our ratings analysis, we reviewed the interest and
principal amounts due on the underlying securities, which are then
passed through to the applicable re-REMIC classes. We applied our
loss projections, incorporating our loss assumptions, to the
underlying collateral to identify the principal and interest
amounts that could be passed through from the underlying
securities under our rating scenario stresses. We stressed our
loss projections at various rating categories to assess whether
the re-REMIC classes could withstand the stressed losses
associated with their ratings while receiving timely payment of
interest and principal consistent with our criteria," S&P said.

"As a result of this review, our lowered ratings are based on our
belief that that the amount of credit enhancement within the re-
REMIC will be insufficient to cover projected principal losses
being passed through from the underlying securities. The
affirmations reflect our assessment that the re-REMIC classes
will likely receive timely interest and the ultimate payment of
principal under the applicable stressed assumptions," S&P said.

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

            http://standardandpoorsdisclosure-17g7.com

Rating Actions

ASG Resecuritization Trust 2010-4
Series      2010-4
                               Rating
Class      CUSIP       To                   From
2-G23      00190UAX1   BB (sf)              BB (sf)/Watch Neg
2-A26      00190UBE2   B (sf)               B (sf)/Watch Neg
2-A23      00190UBD4   BB (sf)              BB (sf)/Watch Neg
2-G26      00190UAY9   B (sf)               B (sf)/Watch Neg

BCAP LLC 2009-RR10 Trust
Series      2009-RR10
                               Rating
Class      CUSIP       To                   From
VII-A2     05532EAP0   CCC (sf)             BBB (sf)
V-A2       05532EAK1   CCC (sf)             B (sf)
IV-A1      05532EAG0   AA (sf)              AAA (sf)

BCAP LLC 2009-RR11 Trust
Series      2009-RR11
                               Rating
Class      CUSIP       To                   From
VI-A1      05532FAN2   AAA (sf)             AAA (sf)/Watch Neg

BCAP LLC 2009-RR6-II Trust
Series      2009-RR6-II
                               Rating
Class      CUSIP       To                   From
II-A1      05531YAC6   BBB+ (sf)            AAA (sf)/Watch Neg
II-A4      05531YAK8   BBB+ (sf)            AAA (sf)

BCAP LLC 2010-RR1 Trust
Series      2010-RR1
                               Rating
Class      CUSIP       To                   From
I-A1       05532TAA0   AA (sf)              AA (sf)/Watch Neg
X-A7       05532TEF5   BBB (sf)             BBB (sf)/Watch Neg
X-A11      05532TEK4   BBB (sf)             BBB (sf)/Watch Neg
X-A9       05532TEH1   AA (sf)              AA (sf)/Watch Neg
X-A1       05532TDZ2   AAA (sf)             AAA (sf)/Watch Neg
X-A8       05532TEG3   BBB (sf)             BBB (sf)/Watch Neg
X-A10      05532TEJ7   A (sf)               A (sf)/Watch Neg

BCAP LLC 2010-RR4-II Trust
Series      2010-RR4-II
                               Rating
Class      CUSIP       To                   From
XII-A8     05532XFG3   BBB (sf)             BBB (sf)/Watch Neg
VIII-A10   05532XBH5   A (sf)               A (sf)/Watch Neg

BCAP LLC 2010-RR6 Trust
Series      2010-RR6
                               Rating
Class      CUSIP       To                   From
2A3        05533CAZ1   A (sf)               A (sf)/Watch Neg
19A3       05533CLJ5   A (sf)               A (sf)/Watch Neg
2A2        05533CAY4   AA (sf)              AA (sf)/Watch Neg
23A4       05533CNR5   BBB (sf)             BBB (sf)/Watch Neg
19A2       05533CLH9   AA (sf)              AA (sf)/Watch Neg
19A4       05533CLK2   BBB (sf)             BBB (sf)/Watch Neg
2A4        05533CBA5   BBB (sf)             BBB (sf)/Watch Neg
23A1       05533CNN4   AAA (sf)             AAA (sf)/Watch Neg
2A1        05533CAX6   AAA (sf)             AAA (sf)/Watch Neg
19A1       05533CLG1   AAA (sf)             AAA (sf)/Watch Neg
23A2       05533CNP9   AA (sf)              AA (sf)/Watch Neg
23A3       05533CNQ7   A (sf)               A (sf)/Watch Neg

BNPP Mortgage Securities LLC 2009-1 Trust
Series      2009-1
                               Rating
Class      CUSIP       To                   From
A-5        05570WAE8   BB+ (sf)             A- (sf)
A-4        05570WAD0   BBB+ (sf)            AA- (sf)
A-2        05570WAB4   AA- (sf)             AA+ (sf)
A-1        05570WAA6   AA- (sf)             AA+ (sf)
A-6        05570WAJ7   BB- (sf)             BBB (sf)
A-3        05570WAC2   A (sf)               AA (sf)

Citigroup Mortgage Loan Trust 2010-7
Series      2010-7
                               Rating
Class      CUSIP       To                   From
3A2        17317EAG6   AAA (sf)             AAA (sf)/Watch Neg
4AX        17317EAN1   AA+ (sf)             AAA (sf)

Jefferies Resecuritization Trust 2010-R3
Series      2010-R3
                               Rating
Class      CUSIP       To                   From
1-A1       47233MAA9   AA (sf)              AA (sf)/Watch Neg

RATINGS AFFIRMED

ASG Resecuritization Trust 2010-4
Series      2010-4
Class      CUSIP       Rating
2-G14      00190UAU7   AA (sf)
2-A20      00190UBC6   BBB (sf)
2-A17      00190UBB8   A (sf)
2-G17      00190UAV5   A (sf)
2-G20      00190UAW3   BBB (sf)

BCAP LLC 2009-RR10 Trust
Series      2009-RR10
Class      CUSIP       Rating
XVII-A1    05532ECL7   AAA (sf)
XIV-A1-A   05532EAZ8   AAA (sf)
II-A1      05532EAC9   AAA (sf)
XI-A1-A    05532EAU9   AAA (sf)
XIV-A4     05532ECK9   BBB (sf)
XIV-A1-C   05532ECV5   BBB (sf)
XI-A1-B    05532EAV7   AAA (sf)
XIV-A6     05532ECY9   BBB (sf)
VII-A1     05532EAN5   AAA (sf)
XIV-A1-B   05532ECU7   A (sf)
V-A1       05532EAJ4   AAA (sf)
XIV-A3     05532ECJ2   A (sf)

BCAP LLC 2009-RR11 Trust
Series      2009-RR11
Class      CUSIP       Rating
VII-A1     05532FAQ5   AAA (sf)
II-A1      05532FAE2   AAA (sf)
I-A2       05532FAB8   BBB (sf)
V-A1       05532FAL6   AAA (sf)

BCAP LLC 2009-RR6-I Trust
Series      2009-RR6-I
Class      CUSIP       Rating
I-A1       05531YAA0   AAA (sf)
I-A4       05531YAH5   AAA (sf)
I-A3       05531YAG7   AAA (sf)

BCAP LLC 2009-RR6-II Trust
Series      2009-RR6-II
Class      CUSIP       Rating
II-A3      05531YAJ1   AAA (sf)

BCAP LLC 2010-RR1 Trust
Series      2010-RR1
Class      CUSIP       Rating
X-A3       05532TEB4   AA (sf)
X-A5       05532TED0   A (sf)

BCAP LLC 2010-RR4-II Trust
Series      2010-RR4-II
Class      CUSIP       Rating
VIII-A5    05532XBD4   A (sf)
VIII-A8    05532XBF9   BBB (sf)
XII-A1     05532XEZ2   AAA (sf)
XII-A3     05532XFB4   AA (sf)
XII-A7     05532XFF5   BBB (sf)
VIII-A11   05532XBJ1   BBB (sf)
VIII-A7    05532XEN9   BBB (sf)
VIII-A9    05532XBG7   AA (sf)
VIII-A3    05532XBB8   AA (sf)
XII-A5     05532XFD0   A (sf)
XII-A11    05532XFK4   BBB (sf)
XII-A9     05532XFH1   AA (sf)
XII-A10    05532XFJ7   A (sf)
VIII-A1    05532XAZ6   AAA (sf)

BCAP LLC 2010-RR6 Trust
Series      2010-RR6
Class      CUSIP       Rating
2A7        05533CBD9   BBB (sf)
2A9        05533CBF4   BBB (sf)
19A6       05533CLM8   A (sf)
18A5       05533CKW7   AA (sf)
22A1       05533CMW5   AAA (sf)
1A3        05533CAC2   A (sf)
8A8        05533CEB0   BBB (sf)
3A3        05533CBN7   A (sf)
17A6       05533CKA5   A (sf)
12A1       05533CFZ6   AAA (sf)
3A5        05533CBQ0   AA (sf)
8A9        05533CEC8   BBB (sf)
14A2       05533CGP7   AA (sf)
21A6       05533CMN5   A (sf)
10A4       05533CFE3   BBB (sf)
15A4       05533CHE1   BBB (sf)
19A9       05533CLQ9   BBB (sf)
18A7       05533CKY3   A (sf)
16A18      05533CJS8   BBB (sf)
15A9       05533CHK7   BBB (sf)
22A4       05533CMZ8   AAA (sf)
4A1        05533CBZ0   AAA (sf)
14A1       05533CGN2   AAA (sf)
18A6       05533CKX5   A (sf)
18A9       05533CLA4   BBB (sf)
10A7       05533CFH6   BBB (sf)
17A19      05533CKQ0   BBB (sf)
14A8       05533CGV4   BBB (sf)
21A5       05533CMM7   AA (sf)
14A5       05533CGS1   AA (sf)
15A19      05533CHW1   BBB (sf)
7A3        05533CDH8   A (sf)
7A6        05533CDL9   A (sf)
4A2        05533CCA4   AA (sf)
22A14      05533CNK0   BBB (sf)
7A7        05533CDM7   BBB (sf)
21A4       05533CML9   BBB (sf)
15A7       05533CHH4   BBB (sf)
21A8       05533CMQ8   BBB (sf)
8A2        05533CDV7   AA (sf)
3A1        05533CBL1   AAA (sf)
10A9       05533CFK9   BBB (sf)
14A3       05533CGQ5   A (sf)
17A7       05533CKB3   BBB (sf)
17A2       05533CJW9   AA (sf)
1A7        05533CAG3   BBB (sf)
8A20       05533CEQ7   BBB (sf)
5A3        05533CCQ9   A (sf)
3A4        05533CBP2   BBB (sf)
3A7        05533CBS6   BBB (sf)
19A8       05533CLP1   BBB (sf)
4A9        05533CCH9   BBB (sf)
14A6       05533CGT9   A (sf)
1A19       05533CAV0   BBB (sf)
16A5       05533CJC3   AA (sf)
15A3       05533CHD3   A (sf)
1A20       05533CAW8   BBB (sf)
21A9       05533CMR6   BBB (sf)
3A2        05533CBM9   AA (sf)
22A8       05533CND6   AAA (sf)
22A9       05533CNE4   AAA (sf)
17A4       05533CJY5   BBB (sf)
5A4        05533CCR7   BBB (sf)
8A18       05533CEN4   BBB (sf)
3A8        05533CBT4   BBB (sf)
18A8       05533CKZ0   BBB (sf)
5A7        05533CCU0   A (sf)
16A3       05533CJA7   A (sf)
10A3       05533CFD5   A (sf)
4A3        05533CCB2   A (sf)
8A7        05533CEA2   BBB (sf)
7A8        05533CDN5   BBB (sf)
21A3       05533CMK1   A (sf)
20A1       05533CLV8   AAA (sf)
5A5        05533CCS5   AA (sf)
7A5        05533CDK1   AA (sf)
15A18      05533CHV3   BBB (sf)
16A9       05533CJG4   BBB (sf)
10A6       05533CFG8   A (sf)
12A2       05533CGA0   AA (sf)
20A8       05533CMC9   BBB (sf)
19A7       05533CLN6   BBB (sf)
20A3       05533CLX4   AA (sf)
18A10      05533CLB2   BBB (sf)
16A6       05533CJD1   A (sf)
17A3       05533CJX7   A (sf)
16A7       05533CJE9   BBB (sf)
15A1       05533CHB7   AAA (sf)
21A7       05533CMP0   BBB (sf)
1A18       05533CAU2   BBB (sf)
22A15      05533CNL8   AAA (sf)
19A5       05533CLL0   AA (sf)
12A5       05533CGD4   AA (sf)
20A9       05533CMD7   AA (sf)
22A7       05533CNC8   BBB (sf)
22A10      05533CNF1   AAA (sf)
23A9       05533CNW4   BBB (sf)
4A4        05533CCC0   BBB (sf)
3A6        05533CBR8   A (sf)
1A6        05533CAF5   A (sf)
1A2        05533CAB4   AA (sf)
4A8        05533CCG1   BBB (sf)
5A8        05533CCV8   BBB (sf)
2A5        05533CBB3   AA (sf)
12A6       05533CGE2   A (sf)
7A9        05533CDP0   BBB (sf)
1A5        05533CAE8   AA (sf)
17A5       05533CJZ2   AA (sf)
15A8       05533CHJ0   BBB (sf)
2A8        05533CBE7   BBB (sf)
12A4       05533CGC6   BBB (sf)
16A8       05533CJF6   BBB (sf)
17A20      05533CKR8   BBB (sf)
1A4        05533CAD0   BBB (sf)
8A5        05533CDY1   AA (sf)
23A5       05533CNS3   AA (sf)
17A8       05533CKC1   BBB (sf)
4A6        05533CCE6   A (sf)
4A7        05533CCF3   BBB (sf)
1A9        05533CAJ7   BBB (sf)
14A4       05533CGR3   BBB (sf)
16A19      05533CJT6   BBB (sf)
22A2       05533CMX3   AAA (sf)
21A2       05533CMJ4   AA (sf)
17A9       05533CKD9   BBB (sf)
20A10      05533CME5   A (sf)
5A10       05533CCX4   BBB (sf)
18A4       05533CKV9   BBB (sf)
22A5       05533CNA2   AAA (sf)
5A6        05533CCT3   A (sf)
10A5       05533CFF0   AA (sf)
14A9       05533CGW2   BBB (sf)
10A8       05533CFJ2   BBB (sf)
8A3        05533CDW5   A (sf)
20A7       05533CMB1   BBB (sf)
7A2        05533CDG0   AA (sf)
10A2       05533CFC7   AA (sf)
15A2       05533CHC5   AA (sf)
8A6        05533CDZ8   A (sf)
8A4        05533CDX3   BBB (sf)
12A3       05533CGB8   A (sf)
12A8       05533CGG7   BBB (sf)
17A18      05533CKP2   BBB (sf)
16A2       05533CHZ4   AA (sf)
18A3       05533CKU1   A (sf)
1A1        05533CAA6   AAA (sf)
16A4       05533CJB5   BBB (sf)
14A7       05533CGU6   BBB (sf)
17A1       05533CJV1   AAA (sf)
16A1       05533CHY7   AAA (sf)
12A7       05533CGF9   BBB (sf)
15A6       05533CHG6   A (sf)
7A4        05533CDJ4   BBB (sf)
5A9        05533CCW6   BBB (sf)
5A2        05533CCP1   AA (sf)
23A7       05533CNU8   BBB (sf)
15A5       05533CHF8   AA (sf)
4A5        05533CCD8   AA (sf)
18A2       05533CKT4   AA (sf)
21A1       05533CMH8   AAA (sf)
20A11      05533CMF2   BBB (sf)
20A5       05533CLZ9   A (sf)
22A6       05533CNB0   AAA (sf)
8A1        05533CDU9   AAA (sf)
2A6        05533CBC1   A (sf)
7A1        05533CDF2   AAA (sf)
23A6       05533CNT1   A (sf)
1A8        05533CAH1   BBB (sf)
10A1       05533CFB9   AAA (sf)
16A20      05533CJU3   BBB (sf)
5A1        05533CCN6   AAA (sf)
8A19       05533CEP9   BBB (sf)
23A8       05533CNV6   BBB (sf)
12A9       05533CGH5   BBB (sf)
3A9        05533CBU1   BBB (sf)
15A20      05533CHX9   BBB (sf)
18A1       05533CKS6   AAA (sf)
22A3       05533CMY1   AAA (sf)

BNPP Mortgage Securities LLC 2009-1 Trust
Series      2009-1
Class      CUSIP       Rating
B-1        05570WAF5   CCC (sf)

Citigroup Mortgage Loan Trust 2010-7
Series      2010-7
Class      CUSIP       Rating
11A9       17317ECF6   AAA (sf)
11A4       17317ECA7   AAA (sf)
7A1        17317EBE0   BBB (sf)
11A10      17317ECG4   AAA (sf)
13A1       17317ECS8   A (sf)
11A12      17317ECJ8   AAA (sf)
2A1        17317EAD3   AAA (sf)
4A2        17317EAM3   AA+ (sf)
3A4        17317EAJ0   A (sf)
12A1       17317ECK5   AAA (sf)
11A6       17317ECC3   AAA (sf)
11A2       17317EBY6   BB (sf)
11A3       17317EBZ3   AAA (sf)
13A4       17317ECV1   A (sf)
2A2        17317EAE1   A (sf)
13A6       17317ECX7   A (sf)
11A7       17317ECD1   AAA (sf)
10A1       17317EBV2   AAA (sf)
13A3       17317ECU3   AA (sf)
11A11      17317ECH2   AAA (sf)
11A1       17317EBX8   AAA (sf)
11A5       17317ECB5   AAA (sf)
13A5       17317ECW9   AAA (sf)
11A8       17317ECE9   AAA (sf)

Jefferies Resecuritization Trust 2010-R3
Series      2010-R3
Class      CUSIP       Rating
1-A7       47233MAG6   A (sf)
1-A5       47233MAE1   BBB (sf)
1-A3       47233MAC5   A (sf)
1-A8       47233MAH4   BBB (sf)


* S&P Puts Ratings on 299 Tranches from US CDO Deals on Watch Pos
-----------------------------------------------------------------
Standard & Poor's Ratings Services placed its ratings on 299
tranches from 63 U.S. collateralized debt obligation (CDO)
transactions on CreditWatch with positive implications. "At the
same time, we placed our ratings on 12 tranches from eight U.S.
CDO transactions on CreditWatch with negative implications," S&P
said.

The tranches with ratings placed on CreditWatch positive are
from CDO transactions backed by securities issued by corporate
obligors. These tranches had an original issuance amount of
$15.99 billion.

"Most of the CreditWatch positive placements affect collateralized
loan obligations (CLOs) and reflect the continued improvement in
the credit quality of the underlying obligors. This improvement
included a reduced level of defaults that the portfolios hold due
to a continued benign corporate credit environment. The default
rate of 0.17% by principal amount and 0.62% by number of loans are
the lowest rate we observed in the past four years. These rates
compare to 1.87% and 2.86% seen in December 2010 and are
substantially lower than the rates of 9.61% and 8.07% in December
2009. Based on our fixed income research, the estimated 12-month-
trailing speculative-grade default was 2.05% in December, down
from 3.3% in the previous year and 10.9% in 2009," S&P said.

"We placed our ratings on CreditWatch positive to reflect these
improvements, as well as our view that these tranches may be able
to support higher ratings," S&P said.

"We placed our ratings on 12 tranches from 8 transactions on
CreditWatch with negative implications due to deterioration in the
credit quality of each transaction's portfolio. Five of these
transactions are CDOs backed by mezzanine structured finance CDOs.
Three of these transactions are CDOs backed by hybrid mezzanine
structured finance CDOs. The remaining deal is a CDO backed by a
high-grade structured finance CDO. The tranches with ratings
placed on CreditWatch negative had an original issuance amount of
$1.77 billion," S&P said.

"We will resolve the CreditWatch placements after we complete a
comprehensive cash flow analysis and committee review for each of
the affected transactions. We expect to resolve these CreditWatch
placements within 90 days. We will continue to monitor the CDO
transactions we rate and take rating actions, including
CreditWatch placements, as we deem appropriate," S&P said.

             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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

             http://standardandpoorsdisclosure-17g7.com

Ratings Placed On Creditwatch Positive

505 CLO I Ltd.
                            Rating
Class               To                  From
B                   A+ (sf)/Watch Pos   A+ (sf)
C                   A (sf)/Watch Pos    A (sf)

ACA CLO 2006-1 Ltd.
                            Rating
Class               To                  From
A-1                 AA+ (sf)/Watch Pos  AA+ (sf)
A-2                 A+ (sf)/Watch Pos   A+ (sf)
B                   BBB+ (sf)/Watch Pos BBB+ (sf)
C                   BB+ (sf)/Watch Pos  BB+ (sf)
D                   B+ (sf)/Watch Pos   B+ (sf)

ACA CLO 2007-1 Ltd.
                            Rating
Class               To                  From
A                   A+ (sf)/Watch Pos   A+ (sf)
B                   BBB+ (sf)/Watch Pos BBB+ (sf)
C                   BB+ (sf)/Watch Pos  BB+ (sf)
D                   B+ (sf)/Watch Pos   B+ (sf)
E                   CCC- (sf)/Watch Pos CCC- (sf)

AMMC CLO III Ltd.
                            Rating
Class               To                  From
A                   AA+ (sf)/Watch Pos  AA+ (sf)
BRevolving          BB+ (sf)/Watch Pos  BB+ (sf)
C                   B+ (sf)/Watch Pos   B+ (sf)
D                   CCC- (sf)/Watch Pos CCC- (sf)

Apidos CDO II
                            Rating
Class               To                  From
A-3                 A+ (sf)/Watch Pos   A+ (sf)
B                   BBB+ (sf)/Watch Pos BBB+ (sf)
C                   BB+ (sf)/Watch Pos  BB+ (sf)
D                   B+ (sf)/Watch Pos   B+ (sf)

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

Ares Enhanced Loan Investment Strategy II Ltd.
                            Rating
Class               To                  From
A-1                 AA (sf)/Watch Pos   AA (sf)
A-2                 AA (sf)/Watch Pos   AA (sf)
B-1                 BBB+ (sf)/Watch Pos BBB+ (sf)
B-2                 BBB+ (sf)/Watch Pos BBB+ (sf)
C-1                 BB+ (sf)/Watch Pos  BB+ (sf)
C-2                 BB+ (sf)/Watch Pos  BB+ (sf)

Ares X CLO Ltd.
                            Rating
Class               To                  From
B                   AA+ (sf)/Watch Pos  AA+ (sf)
C-1                 A (sf)/Watch Pos    A (sf)
C-2                 A (sf)/Watch Pos    A (sf)
D-1                 B+ (sf)/Watch Pos   B+ (sf)
D-2                 B+ (sf)/Watch Pos   B+ (sf)

Avenue CLO III Ltd.
                            Rating
Class               To                  From
A1L                 AA+ (sf)/Watch Pos  AA+ (sf)
A2L                 A (sf)/Watch Pos    A (sf)
A3L                 BB+ (sf)/Watch Pos  BB+ (sf)
B1L                 CCC- (sf)/Watch Pos CCC- (sf)

Babson Loan Opportunity CLO Ltd.
                            Rating
Class               To                  From
A                   AA+ (sf)/Watch Pos  AA+ (sf)
B                   AA (sf)/Watch Pos   AA (sf)
C                   A (sf)/Watch Pos    A (sf)
D                   BBB+ (sf)/Watch Pos BBB+ (sf)
E                   BB+ (sf)/Watch Pos  BB+ (sf)

Battalion CLO 2007-1 Ltd.
                            Rating
Class               To                  From
A                   AA+ (sf)/Watch Pos  AA+ (sf)
B                   AA (sf)/Watch Pos   AA (sf)
C                   A- (sf)/Watch Pos   A- (sf)
D                   BBB- (sf)/Watch Pos BBB- (sf)
E                   B+ (sf)/Watch Pos   B+ (sf)

Black Diamond CLO 2005-2 Ltd.
                            Rating
Class               To                  From
B                   AA (sf)/Watch Pos   AA (sf)
C                   A (sf)/Watch Pos    A (sf)
D                   BB+ (sf)/Watch Pos  BB+ (sf)
E-1                 CCC- (sf)/Watch Pos CCC- (sf)
E-2                 CCC- (sf)/Watch Pos CCC- (sf)

BlueOrchard Loans for Development S.A. (Compartment 1)
                            Rating
Class               To                  From
A1                  A+ (sf)/Watch Pos   A+ (sf)
A2                  A+ (sf)/Watch Pos   A+ (sf)
A3                  A+ (sf)/Watch Pos   A+ (sf)
B1                  BBB (sf)/Watch Pos  BBB (sf)
B2                  BBB (sf)/Watch Pos  BBB (sf)
B3                  BBB (sf)/Watch Pos  BBB (sf)

Carlyle Vantage CLO Ltd.
                            Rating
Class               To                  From
A-1                 AA+ (sf)/Watch Pos  AA+ (sf)
A-3                 AA+ (sf)/Watch Pos  AA+ (sf)
B                   AA (sf)/Watch Pos   AA (sf)
C                   A+ (sf)/Watch Pos   A+ (sf)
D                   BBB- (sf)/Watch Pos BBB- (sf)

Cent CDO 10 Ltd.
                            Rating
Class               To                  From
B                   A (sf)/Watch Pos    A (sf)
C                   BBB- (sf)/Watch Pos BBB- (sf)
D                   BB (sf)/Watch Pos   BB (sf)
E                   CCC+ (sf)/Watch Pos CCC+ (sf)

Centurion CDO 8 Ltd.
                            Rating
Class               To                  From
A                   AA- (sf)/Watch Pos  AA- (sf)
B-1                 BB+ (sf)/Watch Pos  BB+ (sf)
B-2                 BB+ (sf)/Watch Pos  BB+ (sf)
C                   BB- (sf)/Watch Pos  BB- (sf)
CompositeSecurities BB- (sf)/Watch Pos  BB- (sf)
D                   CCC+ (sf)/Watch Pos CCC+ (sf)

Chatham Light II CLO Ltd.
                            Rating
Class               To                  From
A-1                 AA+ (sf)/Watch Pos  AA+ (sf)
A-2                 AA (sf)/Watch Pos   AA (sf)
B                   A (sf)/Watch Pos    A (sf)
C                   BBB- (sf)/Watch Pos BBB- (sf)
D                   B+ (sf)/Watch Pos   B+ (sf)

CIFC Funding 2006-I Ltd.
                            Rating
Class               To                  From
A-1L                AA+ (sf)/Watch Pos  AA+ (sf)
A-1LR               AA+ (sf)/Watch Pos  AA+ (sf)
A-2L                A+ (sf)/Watch Pos   A+ (sf)
A--3L               BBB+ (sf)/Watch Pos BBB+ (sf)
B-1L                BB+ (sf)/Watch Pos  BB+ (sf)
B-2L                B+ (sf)/Watch Pos   B+ (sf)

CIFC Funding 2006-II Ltd. 2006-II
                            Rating
Class               To                  From
A-1L                AA (sf)/Watch Pos   AA (sf)
A-1LAr              AA+ (sf)/Watch Pos  AA+ (sf)
A-1LAt              AA+ (sf)/Watch Pos  AA+ (sf)
A-1LB               AA (sf)/Watch Pos   AA (sf)
A-2L                A+ (sf)/Watch Pos   A+ (sf)
A-3L                BBB+ (sf)/Watch Pos BBB+ (sf)
B-1L                BB+ (sf)/Watch Pos  BB+ (sf)
B-2L                B+ (sf)/Watch Pos   B+ (sf)

Ares XVIII CLO Ltd.
                            Rating
Class               To                  From
A-2                 AA+ (sf)/Watch Pos  AA+ (sf)
B-1                 A- (sf)/Watch Pos   A- (sf)
B-2                 A- (sf)/Watch Pos   A- (sf)

Columbus Park CDO Ltd.
                            Rating
Class               To                  From
A-1                 AA+ (sf)/Watch Pos  AA+ (sf)
A-2                 AA (sf)/Watch Pos   AA (sf)
B                   A (sf)/Watch Pos    A (sf)
C                   BBB (sf)/Watch Pos  BBB (sf)
D                   BB (sf)/Watch Pos   BB (sf)

ColumbusNova CLO Ltd. 2006-II
                            Rating
Class               To                  From
A                   AA+ (sf)/Watch Pos  AA+ (sf)
B                   AA- (sf)/Watch Pos  AA- (sf)
C                   A- (sf)/Watch Pos   A- (sf)

Comstock Funding Ltd.
                            Rating
Class               To                  From
A-1A                AA+ (sf)/Watch Pos  AA+ (sf)
A-1B                AA+ (sf)/Watch Pos  AA+ (sf)
A-2                 AA+ (sf)/Watch Pos  AA+ (sf)
A-3                 AA- (sf)/Watch Pos  AA- (sf)

Del Mar CLO I Ltd.
                            Rating
Class               To                  From
B                   AA- (sf)/Watch Pos  AA- (sf)
C                   A- (sf)/Watch Pos   A- (sf)
D                   BB+ (sf)/Watch Pos  BB+ (sf)
E                   CCC- (sf)/Watch Pos CCC- (sf)

Essex Park CDO Ltd.
                            Rating
Class               To                  From
B-1                 AA (sf)/Watch Pos   AA (sf)
B-2                 AA (sf)/Watch Pos   AA (sf)
C-1                 A (sf)/Watch Pos    A (sf)
C-2                 A (sf)/Watch Pos    A (sf)
D                   BBB (sf)/Watch Pos  BBB (sf)

Flagship CLO III
                            Rating
Class               To                  From
B                   A+ (sf)/Watch Pos   A+ (sf)
C                   BBB- (sf)/Watch Pos BBB- (sf)
D                   B+ (sf)/Watch Pos   B+ (sf)

Foothill CLO I Ltd.
                            Rating
Class               To                  From
A                   AA+ (sf)/Watch Pos  AA+ (sf)

Freeport Ln Trust 2006-1
                            Rating
Class               To                  From
C                   AA (sf)/Watch Pos   AA (sf)
D                   A+ (sf)/Watch Pos   A+ (sf)

FriedbergMilstein Private Capital Fund I
                            Rating
Class               To                  From
B-1                 AA+ (sf)/Watch Pos  AA+ (sf)
B-2                 AA+ (sf)/Watch Pos  AA+ (sf)
C-1                 A+ (sf)/Watch Pos   A+ (sf)
C-2                 A+ (sf)/Watch Pos   A+ (sf)
D-1                 B+ (sf)/Watch Pos   B+ (sf)
D-2                 B+ (sf)/Watch Pos   B+ (sf)

Golden Knight II CLO Ltd.
                            Rating
Class               To                  From
A                   AA+ (sf)/Watch Pos  AA+ (sf)
B                   AA- (sf)/Watch Pos  AA- (sf)
C                   A- (sf)/Watch Pos   A- (sf)
D                   BB+ (sf)/Watch Pos  BB+ (sf)
E                   CCC- (sf)/Watch Pos CCC- (sf)

Granite Ventures III Ltd.
                            Rating
Class               To                  From
A-2                 AA+ (sf)/Watch Pos  AA+ (sf)
B                   A- (sf)/Watch Pos   A- (sf)
C                   BB+ (sf)/Watch Pos  BB+ (sf)
D                   B+ (sf)/Watch Pos   B+ (sf)

Greywolf CLO I Ltd.
                            Rating
Class               To                  From
A                   AA+ (sf)/Watch Pos  AA+ (sf)
B                   AA (sf)/Watch Pos   AA (sf)
C                   A (sf)/Watch Pos    A (sf)
D                   BBB (sf)/Watch Pos  BBB (sf)
E                   BB (sf)/Watch Pos   BB (sf)

GSC Investment Corp CLO 2007 Ltd.
                            Rating
Class               To                  From
A                   AA- (sf)/Watch Pos  AA- (sf)
B                   A+ (sf)/Watch Pos   A+ (sf)
C                   BBB+ (sf)/Watch Pos BBB+ (sf)
D                   BB+ (sf)/Watch Pos  BB+ (sf)
E                   BB- (sf)/Watch Pos  BB- (sf)

HarbourView CLO 2006-1
                            Rating
Class               To                  From
A-1                 AA (sf)/Watch Pos   AA (sf)
A-2                 A+ (sf)/Watch Pos   A+ (sf)
B                   BBB+ (sf)/Watch Pos BBB+ (sf)
C                   B+ (sf)/Watch Pos   B+ (sf)
D                   CCC- (sf)/Watch Pos CCC- (sf)

Harch CLO III Ltd.
                            Rating
Class               To                  From
A-2                 AA+ (sf)/Watch Pos  AA+ (sf)
B                   A+ (sf)/Watch Pos   A+ (sf)
C                   BBB+ (sf)/Watch Pos BBB+ (sf)
D                   BB+ (sf)/Watch Pos  BB+ (sf)
E                   CCC+ (sf)/Watch Pos CCC+ (sf)

Hudson Straits CLO 2004 Ltd.
                            Rating
Class               To                  From
B                   AA+ (sf)/Watch Pos  AA+ (sf)
C                   A+ (sf)/Watch Pos   A+ (sf)
D-1                 BB+ (sf)/Watch Pos  BB+ (sf)
D-2                 BB+ (sf)/Watch Pos  BB+ (sf)
E                   B- (sf)/Watch Pos   B- (sf)

Kingsland V Ltd.
                            Rating
Class               To                  From
A-1                 A+ (sf)/Watch Pos   A+ (sf)
A-2B                A+ (sf)/Watch Pos   A+ (sf)
A-2R                AA+ (sf)/Watch Pos  AA+ (sf)
B                   BBB+ (sf)/Watch Pos BBB+ (sf)
C                   BB+ (sf)/Watch Pos  BB+ (sf)
D-1                 B+ (sf)/Watch Pos   B+ (sf)
D-2                 B+ (sf)/Watch Pos   B+ (sf)
E                   CCC- (sf)/Watch Pos CCC- (sf)

KKR Financial CLO 2007-A Ltd.
                            Rating
Class               To                  From
A                   AA+ (sf)/Watch Pos  AA+ (sf)
B                   AA (sf)/Watch Pos   AA (sf)
C                   A (sf)/Watch Pos    A (sf)
D                   BBB (sf)/Watch Pos  BBB (sf)
E                   BB (sf)/Watch Pos   BB (sf)
F                   B (sf)/Watch Pos    B (sf)

Knightsbridge CLO 2007-1 Ltd.
                            Rating
Class               To                  From
A2                  AA+ (sf)/Watch Pos  AA+ (sf)
B                   AA (sf)/Watch Pos   AA (sf)
C                   A (sf)/Watch Pos    A (sf)
D                   BBB (sf)/Watch Pos  BBB (sf)
E                   BB (sf)/Watch Pos   BB (sf)

Landmark V CDO Ltd.
                            Rating
Class               To                  From
A-1L                AA+ (sf)/Watch Pos  AA+ (sf)
A-2L                A+ (sf)/Watch Pos   A+ (sf)
A-3L                BBB+ (sf)/Watch Pos BBB+ (sf)
B-1L                BB+ (sf)/Watch Pos  BB+ (sf)
B-2L                CCC- (sf)/Watch Pos CCC- (sf)

MAPS CLO Fund II Ltd.
                            Rating
Class               To                  From
A-1                 A+ (sf)/Watch Pos   A+ (sf)
A-1J                A+ (sf)/Watch Pos   A+ (sf)
A-1R                AA+ (sf)/Watch Pos  AA+ (sf)
A-1S                AA+ (sf)/Watch Pos  AA+ (sf)
A-2                 A+ (sf)/Watch Pos   A+ (sf)
B                   BBB (sf)/Watch Pos  BBB (sf)
C                   BB (sf)/Watch Pos   BB (sf)
D                   CCC+ (sf)/Watch Pos CCC+ (sf)

Marathon CLO I Ltd.
                            Rating
Class               To                  From
C                   A+ (sf)/Watch Pos   A+ (sf)
D                   BBB+ (sf)/Watch Pos BBB+ (sf)
E                   BB+ (sf)/Watch Pos  BB+ (sf)

Mountain View CLO III Ltd.
                            Rating
Class               To                  From
A-2                 AA (sf)/Watch Pos   AA (sf)
B                   A+ (sf)/Watch Pos   A+ (sf)
C                   BBB+ (sf)/Watch Pos BBB+ (sf)
D                   BB+ (sf)/Watch Pos  BB+ (sf)
E                   CCC+ (sf)/Watch Pos CCC+ (sf)

Northwoods Capital VII Ltd.
                            Rating
Class               To                  From
A-1                 AA+ (sf)/Watch Pos  AA+ (sf)
A-2                 AA+ (sf)/Watch Pos  AA+ (sf)
A-4                 AA+ (sf)/Watch Pos  AA+ (sf)
B                   AA- (sf)/Watch Pos  AA- (sf)
C                   A (sf)/Watch Pos    A (sf)
D                   BBB (sf)/Watch Pos  BBB (sf)
E                   BB (sf)/Watch Pos   BB (sf)

Northwoods Capital VIII Ltd.
                            Rating
Class               To                  From
A-1                 AA+ (sf)/Watch Pos  AA+ (sf)
A-2                 AA+ (sf)/Watch Pos  AA+ (sf)
B                   AA (sf)/Watch Pos   AA (sf)
C                   A (sf)/Watch Pos    A (sf)
D                   BBB (sf)/Watch Pos  BBB (sf)
E                   BB+ (sf)/Watch Pos  BB+ (sf)

Oak Hill Credit Partners III Ltd.
                            Rating
Class               To                  From
B-2                 AA+ (sf)/Watch Pos  AA+ (sf)
C-1                 BBB+ (sf)/Watch Pos BBB+ (sf)
C-2                 BBB+ (sf)/Watch Pos BBB+ (sf)
Type 1 CMP          AA+ (sf)/Watch Pos  AA+ (sf)
Type 3 CMP          BBB+ (sf)/Watch Pos BBB+ (sf)
D                   BBB (sf)/Watch Pos  BBB (sf)

Octagon Investment Partners IX Ltd.
                            Rating
Class               To                  From
A-2                 AA- (sf)/Watch Pos  AA- (sf)
B                   A (sf)/Watch Pos    A (sf)
C                   BBB- (sf)/Watch Pos BBB- (sf)

Octagon Investment Partners VIII Ltd.
                            Rating
Class               To                  From
A-1                 AA+ (sf)/Watch Pos  AA+ (sf)
A-2                 AA+ (sf)/Watch Pos  AA+ (sf)
B                   A+ (sf)/Watch Pos   A+ (sf)
C                   BBB (sf)/Watch Pos  BBB (sf)
D                   BB- (sf)/Watch Pos  BB- (sf)
E                   CCC- (sf)/Watch Pos CCC- (sf)

Olympic CLO I Ltd.
                            Rating
Class               To                  From
A-2L                AA+ (sf)/Watch Pos  AA+ (sf)
A-3L                A+ (sf)/Watch Pos   A+ (sf)
B-1L                B- (sf)/Watch Pos   B- (sf)
B-2L                CCC- (sf)/Watch Pos CCC- (sf)

Pacifica CDO II Ltd.
                            Rating
Class               To                  From
A-2                 AA+ (sf)/Watch Pos  AA+ (sf)
B-1                 BBB- (sf)/Watch Pos BBB- (sf)
B-2                 BBB- (sf)/Watch Pos BBB- (sf)

Pacifica CDO IV Ltd.
                            Rating
Class               To                  From
A-2L                AA+ (sf)/Watch Pos  AA+ (sf)
A-3L                A+ (sf)/Watch Pos   A+ (sf)
B-1L                BBB+ (sf)/Watch Pos BBB+ (sf)
B-2L                BB- (sf)/Watch Pos  BB- (sf)

Primus CLO II Ltd.
                            Rating
Class               To                  From
A                   AA- (sf)/Watch Pos  AA- (sf)
B                   A+ (sf)/Watch Pos   A+ (sf)
C                   BBB (sf)/Watch Pos  BBB (sf)
D                   BB+ (sf)/Watch Pos  BB+ (sf)
E                   CCC- (sf)/Watch Pos CCC- (sf)

Race Point II CLO Ltd.
                            Rating
Class               To                  From
B-1                 A+ (sf)/Watch Pos   A+ (sf)
B-2                 A+ (sf)/Watch Pos   A+ (sf)
C-1                 A (sf)/Watch Pos    A (sf)
C-2                 A (sf)/Watch Pos    A (sf)
D-1                 BBB+ (sf)/Watch Pos BBB+ (sf)
D-2                 BBB+ (sf)/Watch Pos BBB+ (sf)
D-3                 BBB+ (sf)/Watch Pos BBB+ (sf)

Regatta Funding Ltd.
                            Rating
Class               To                  From
A-2L                AA- (sf)/Watch Pos  AA- (sf)
A-3L                A- (sf)/Watch Pos   A- (sf)
B-1L                BBB- (sf)/Watch Pos BBB- (sf)
B-2L                BB (sf)/Watch Pos   BB (sf)

Signature 7 L.P.
                            Rating
Class               To                  From
B                   BBB (sf)/Watch Pos  BBB (sf)
C                   CCC+ (sf)/Watch Pos CCC+ (sf)

Stone Tower CLO III Ltd.
                            Rating
Class               To                  From
A-1                 AA+ (sf)/Watch Pos  AA+ (sf)
A-2                 AA+ (sf)/Watch Pos  AA+ (sf)
A-3                 AA- (sf)/Watch Pos  AA- (sf)
B                   A- (sf)/Watch Pos   A- (sf)
C-1                 BB+ (sf)/Watch Pos  BB+ (sf)
C-2                 BB+ (sf)/Watch Pos  BB+ (sf)
D-1                 CCC+ (sf)/Watch Pos CCC+ (sf)
D-2                 CCC+ (sf)/Watch Pos CCC+ (sf)

TELOS CLO 2006-1 Ltd.
                            Rating
Class               To                  From
A-2                 AA+ (sf)/Watch Pos  AA+ (sf)
B                   A+ (sf)/Watch Pos   A+ (sf)
C                   BBB+ (sf)/Watch Pos BBB+ (sf)
D                   BB+ (sf)/Watch Pos  BB+ (sf)
E                   CCC+ (sf)/Watch Pos CCC+ (sf)

Tralee CDO I Ltd.
                            Rating
Class               To                  From
A-1                 AA+ (sf)/Watch Pos  AA+ (sf)

Tribeca Park CLO Ltd.
                            Rating
Class               To                  From
A-1                 AA+ (sf)/Watch Pos  AA+ (sf)
A-2                 AA- (sf)/Watch Pos  AA- (sf)
B                   A- (sf)/Watch Pos   A- (sf)
C                   BBB (sf)/Watch Pos  BBB (sf)
D                   BB (sf)/Watch Pos   BB (sf)

Trimaran CLO V Ltd.
                            Rating
Class               To                  From
A2                  AA+ (sf)/Watch Pos  AA+ (sf)
B                   A+ (sf)/Watch Pos   A+ (sf)
C                   BBB+ (sf)/Watch Pos BBB+ (sf)
D                   B+ (sf)/Watch Pos   B+ (sf)
E                   CCC+ (sf)/Watch Pos CCC+ (sf)

Vinacasa CLO Ltd.
                            Rating
Class               To                  From
A2                  AA+ (sf)/Watch Pos  AA+ (sf)
B                   A+ (sf)/Watch Pos   A+ (sf)
C                   BB (sf)/Watch Pos   BB (sf)

WhiteHorse I Ltd.
                            Rating
Class               To                  From
A-2L                AA (sf)/Watch Pos   AA (sf)
A-3L                BBB+ (sf)/Watch Pos BBB+ (sf)
B-1L                BB- (sf)/Watch Pos  BB- (sf)

Whitney CLO I Ltd.
                            Rating
Class               To                  From
A-2F                AA (sf)/Watch Pos   AA (sf)
A-2L                AA (sf)/Watch Pos   AA (sf)
A-3L                A+ (sf)/Watch Pos   A+ (sf)
B-1LA               BBB (sf)/Watch Pos  BBB (sf)
B-1LB               B+ (sf)/Watch Pos   B+ (sf)

RATINGS PLACED ON CREDITWATCH NEGATIVE


Anderson Mezzanine Funding 2007-1 Ltd.
                            Rating
Class               To                  From
S                   B (sf)/Watch Neg    B (sf)

C-Bass CBO VII Ltd.
                            Rating
Class               To                  From
C                   A- (sf)/Watch Neg   A- (sf)
D                   B (sf)/Watch Neg    B (sf)

Dunhill ABS CDO Ltd.
                            Rating
Class               To                  From
A-1NV               CCC (sf)/Watch Neg  CCC (sf)
A-1VA               CCC (sf)/Watch Neg  CCC (sf)
A-1VB               CCC (sf)/Watch Neg  CCC (sf)

Jupiter High Grade CDO Ltd.
                            Rating
Class               To                  From
A-1A                B- (sf)/Watch Neg   B- (sf)
A-1B                B- (sf)/Watch Neg   B- (sf)

Millerton ABS CDO Ltd.
                            Rating
Class               To                  From
A-1                 CCC+ (sf)/Watch Neg CCC+ (sf)

MKP CBO IV Ltd.
                            Rating
Class               To                  From
A-1                 CCC (sf)/Watch Neg  CCC (sf)

Saturn Ventures 2004 - Fund America Investors III Ltd.
                            Rating
Class               To                  From
A-1                 CCC+ (sf)/Watch Neg CCC+ (sf)

STAtic ResidenTial CDO 2005-A Ltd.
                            Rating
Class               To                  From
A-1                 CCC+ (sf)/Watch Neg CCC+ (sf)

                           *********

Monday's edition of the TCR delivers a list of indicative prices
for bond issues that reportedly trade well below par.  Prices are
obtained by TCR editors from a variety of outside sources during
the prior week we think are reliable.  Those sources may not,
however, be complete or accurate.  The Monday Bond Pricing table
is compiled on the Friday prior to publication.  Prices reported
are not intended to reflect actual trades.  Prices for actual
trades are probably different.  Our objective is to share
information, not make markets in publicly traded securities.
Nothing in the TCR constitutes an offer or solicitation to buy or
sell any security of any kind.  It is likely that some entity
affiliated with a TCR editor holds some position in the issuers"
public debt and equity securities about which we report.

Each Tuesday edition of the TCR contains a list of companies with
insolvent balance sheets whose shares trade higher than $3 per
share in public markets.  At first glance, this list may look like
the definitive compilation of stocks that are ideal to sell short.
Don't be fooled.  Assets, for example, reported at historical cost
net of depreciation may understate the true value of a firm's
assets.  A company may establish reserves on its balance sheet for
liabilities that may never materialize.  The prices at which
equity securities trade in public market are determined by more
than a balance sheet solvency test.

A list of Meetings, Conferences and Seminars appears in each
Wednesday's edition of the TCR.  Submissions about insolvency-
related conferences are encouraged.  Send announcements to
conferences@bankrupt.com/

On Thursdays, the TCR delivers a list of recently filed
Chapter 11 cases involving less than $1,000,000 in assets and
liabilities delivered to nation's bankruptcy courts.  The list
includes links to freely downloadable images of these small-dollar
petitions in Acrobat PDF format.

Each Friday's edition of the TCR includes a review about a book of
interest to troubled company professionals.  All titles are
available at your local bookstore or through Amazon.com.  Go to
http://www.bankrupt.com/books/to order any title today.

Monthly Operating Reports are summarized in every Saturday edition
of the TCR.

The Sunday TCR delivers securitization rating news from the week
then-ending.

For copies of court documents filed in the District of Delaware,
please contact Vito at Parcels, Inc., at 302-658-9911.  For
bankruptcy documents filed in cases pending outside the District
of Delaware, contact Ken Troubh at Nationwide Research &
Consulting at 207/791-2852.

                           *********

S U B S C R I P T I O N   I N F O R M A T I O N

Troubled Company Reporter is a daily newsletter co-published
by Bankruptcy Creditors" Service, Inc., Fairless Hills,
Pennsylvania, USA, and Beard Group, Inc., Frederick, Maryland,
USA.  Jhonas Dampog, Marites Claro, Joy Agravante, Rousel Elaine
Tumanda, Howard C. Tolentino, Joseph Medel C. Martirez, Denise
Marie Varquez, Ronald C. Sy, Joel Anthony G. Lopez, Cecil R.
Villacampa, Sheryl Joy P. Olano, Carlo Fernandez, Christopher G.
Patalinghug, and Peter A. Chapman, Editors.

Copyright 2012.  All rights reserved.  ISSN: 1520-9474.

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

The TCR subscription rate is $775 for 6 months delivered via e-
mail.  Additional e-mail subscriptions for members of the same
firm for the term of the initial subscription or balance thereof
are $25 each.  For subscription information, contact Christopher
Beard at 240/629-3300.


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