Attached files
EX-34.1
(logo)PRICEWATERHOUSECOOPERS
PricewaterhouseCoopers LLP
214 North Tryon Street
Suite 3600
Charlotte, NC 28202
Phone (704) 344 4326
Fax (813) 207 3972
www.pwc.com
Report of Independent Registered Public Accounting Firm
To the Board of Directors of Bank of America, National Association:
We have examined Bank of America, National Association and its affiliates
HomeFocus Tax Services LLC ("HomeFocus Tax") and Newport Management Corporation
("Newport Management"), and such companies collectively (the "Company's")
compliance with the servicing criteria set forth in Item 1122(d) of the
Securities and Exchange Commission's Regulation AB for the domestic asset backed
securities transactions for which the Company acted as servicer involving
residential mortgage loans, other than government sponsored entities, or
transactions that do not have scheduled interest and/or scheduled principal
remittance schedules as outlined in their respective transaction agreements,
with the exception of certain non-registered transactions (the "Platform")
described in the accompanying Management Assertion of Compliance with Applicable
Servicing Criteria, as of and for the period January 1, 2009 to November 13,
2009, excluding criterion 1122(d)(1)(iii), which the Company has determined is
not applicable to the servicing activities performed by it with respect to the
Platform. As described in Schedule A to management's assertion, for servicing
criteria 1122 (d)(2)(ii), 1122 (d)(4)(iv), 1122 (d)(4)(xi), 1122 (d)(4)(xii) and
1122 (d)(4)(xiii), the Company has engaged various vendors to perform the
activities required by these servicing criteria. The Company has determined that
these vendors are not considered "servicers" as defined in Item 1101(j) of
Regulation AB, and the Company has elected to take responsibility for assessing
compliance with the servicing criteria applicable to each vendor as permitted
by Interpretation 17.06 of the SEC Division of Corporation Finance Manual of
Publicly Available Telephone Interpretations ("Interpretation 17.06"). As
permitted by Interpretation 17.06, the Company has asserted that it has policies
and procedures in place designed to provide reasonable assurance that the
vendors' activities comply in all material respects with the servicing criteria
applicable to each vendor. The Company is solely responsible for determining
that it meets the SEC requirements to apply Interpretation 17.06 for the vendors
and related criteria as described in its assertion, and we performed no
procedures with respect to the Company's determination of its eligibility to use
Interpretation 17.06. Management is responsible for the Company's compliance
with the servicing criteria. Our responsibility is to express an opinion on the
Company's compliance with the servicing criteria based on our examination.
Our examination was conducted in accordance with attestation standards of the
Public Company Accounting Oversight Board (United States) and, accordingly,
included examining, on a test basis, evidence about the Company's compliance
with the applicable servicing criteria and performing such other procedures as
we considered necessary in the circumstances. Our examination included testing
of selected asset-backed transactions and securities that comprise the Platform,
testing of selected servicing activities related to the Platform, and
determining whether the Company processed those selected transactions and
performed those selected activities in compliance with the applicable servicing
criteria. Our procedures were limited to the selected transactions and
servicing activities performed by the Company during the period covered by this
report. Our procedures were not designed to detect noncompliance arising from
errors that may have occurred prior to or subsequent to our tests that may have
affected the balances or amounts calculated or reported by the Company
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during the period covered by this report. We believe that our examination
provides a reasonable basis for our opinion. Our examination does not provide a
legal determination on the Company's compliance with the servicing criteria.
We have been informed that, under the Company's interpretation of
1122(d)(4)(vii), in absence of specific investor/insurer timeframe standards,
the Company generally services loans in accordance with Fannie Mae guidelines
which are generally considered the accepted industry standard. In those cases
where loss mitigation or recovery actions were not initiated, conducted and
concluded within the specific timeframes set forth in the Fannie Mae guidelines
or transaction agreements that contain them, the Company does not consider
foreclosure initiation delays to be instances of non-compliance when the Company
has made contact with the obligor and is actively engaged in negotiations
regarding a loan modification or other loss mitigation alternative, and the
Company does not consider delays in the timeframe to conduct and conclude
foreclosures to be instances of non-compliance when the foreclosure process is
interrupted or impeded by a bankruptcy filing, automatic stay, court delay,
delay in service of process, skip trace, probate, foreclosure moratorium,
natural or man-made disaster, legal proceeding or government seizure.
Our examination disclosed the following material noncompliance with the
servicing criteria set forth in Item 1122(d)(4)(vi) and 1122(d)(4)(vii) of
Regulation AB applicable to the Company during the period ended November 13,
2009. For criterion 1122(d)(4)(vi), in certain instances, loan modifications
were not made, reviewed and/or approved in accordance with provisions of the
transaction agreements. For criterion 1122(d)(4)(vii), certain loss mitigation
or recovery actions were not initiated, conducted or concluded in accordance
with the required timeframes established under the transaction agreements.
In our opinion, except for the material noncompliance described in the preceding
paragraph, the Company complied with the aforementioned applicable servicing
criteria as of and for the period ended November 13, 2009 for the Platform,
in all material respects.
/s/ PricewaterhouseCoopers LLP
February 26, 2010
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(logo)PRICEWATERHOUSECOOPERS
PricewaterhouseCoopers LLP
350 S. Grand Ave.
Los Angeles CA 90071
Telephone (213) 356 6000
Facsimile (813) 637 4444
www.pwc.com
Report of Independent Registered Public Accounting Firm
To the Board of Directors of Bank of America Home Loan Servicing L.P.:
We have examined BAC Home Loans Servicing, LP ("BAC Servicing LP") and its
affiliates Bank of America, National Association ("BANA"), Countrywide Home
Loans, Inc. ("CHL"), BAC Tax Services Corporation ("BAC Tax Services") and
Newport Management Corporation ("Newport Management," and such companies
collectively, the ("Company") compliance with the servicing criteria set forth
in Item 1122(d) of the Securities and Exchange Commission's Regulation AB for
publicly issued (i.e. registered with the Securities and Exchange Commission
pursuant to the Securities Act of 1933, as amended) residential mortgage-backed
securities (securities collateralized by residential mortgage loans, (including
prime, alternative loan products, sub-prime, HELOC and closed seconds), issued
on or after January 1, 2006 for which the Company provides applicable services
(the "Platform") described in the accompanying Assessment of Compliance with SEC
Regulation AB Servicing Criteria, as of and for the period November 14, 2009 to
December 31, 2009, excluding criterion 1122(d)(1)(iii), which the Company has
determined are not applicable to the servicing activities performed by it with
respect to the Platform. In addition, the Platform includes (i) the domestic
transactions established prior to the November 13, 2009 involving Residential
Mortgage Loans for which BANA and Newport Management provide the services
covered by the applicable servicing criteria (the "Applicable Services") and
that provide for scheduled interest and/or scheduled principal remittances in
their respective transaction agreements, and (ii) any transactions involving
Residential Mortgage Loans for which the Company provides Applicable Services
that are not publicly issued residential mortgage-backed securities but
specifically require the Company to deliver an annual platform-level assessment
of compliance in respect of the Applicable Servicing Criteria. The Platform
excluded any transactions issued by any government sponsored enterprise for
which the Company provides the servicing functions described in the preceding
sentence. Management is responsible for the Company's compliance with the
servicing criteria. Our responsibility is to express an opinion on the Company's
compliance with the servicing criteria based on our examination.
Our examination was conducted in accordance with attestation standards of the
Public Company Accounting Oversight Board (United States) and, accordingly,
included examining, on a test basis, evidence about the Company's compliance
with the applicable servicing criteria and performing such other procedures as
we considered necessary in the circumstances. Our examination included testing
of selected asset-backed transactions and securities that comprise the Platform,
testing of selected servicing activities related to the Platform, and
determining whether the Company processed those selected transactions and
performed those selected activities in compliance with the applicable servicing
criteria. Our procedures were limited to the selected transactions and servicing
activities performed by the Company during the period covered by this report.
Our procedures were not designed to detect noncompliance arising from errors
that may have occurred prior to or subsequent to our tests that may have
affected the balances or amounts calculated or reported by the Company during
the period covered by this report. We believe that our examination provides a
reasonable basis for our opinion. Our examination does not provide a legal
determination on the Company's compliance with the servicing criteria.
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We have been informed that, under the Company's interpretation of
1122(d)(4)(vii), in absence of specific investor/insurer timeframe standards,
the Company services loans in accordance with Fannie Mae guidelines which is
considered the accepted industry standard. In those cases where loss mitigation
or recovery actions were not initiated, conducted and concluded within the
specific timeframes set forth in the Fannie Mae guidelines or transactions
agreements that contain specific timeframes, the Company does not consider
foreclosure initiation delays to be instances of noncompliance when the Company
has made contact with the obligor and is actively engaged in negotiations
regarding a loan modification or other loss mitigation alternative, and the
Company does not consider delays in the timeframe to conduct and conclude
foreclosures to be instances of noncompliance when the foreclosure process is
interrupted or impeded by a bankruptcy filing, automatic stay, court delay,
delay in service of process, skip trace, probate, foreclosure moratorium,
natural or man-made disaster, legal proceeding or government seizure.
For criterion 1122(d)(4)(x)(B), the Company generally pays interest on borrower
funds held in escrow; however, even though some state laws require such payments
of interest, the Company represents that Federal pre-emption rules for
nationally chartered banks under 12 CFR Section 34.4 would be available to it if
conditions arose that necessitated invoking pre-emption and such Federal
pre-emption alone represents compliance for loans for which the Company pays
interest and for those for which the Company may decide not to pay interest
on borrower funds held in escrow.
Our examination disclosed the following material noncompliance with the
servicing criteria set forth in Item 1122(d)(4)(vi) of Regulation AB applicable
to the Company during the period November 14, 2009 to December 31, 2009. For
criterion 1122(d)(4)(vi), loan modifications were not made, reviewed, and/or
approved in accordance with the provisions of the transaction agreements.
In our opinion, except for the material noncompliance described in the preceding
paragraph, the Company complied with the aforementioned applicable servicing
criteria as of and for the period November 14, 2009 to December 31, 2009 for the
Platform, in all material respects.
/s/ PricewaterhouseCoopers LLP
February 26, 2010
