Attached files
the
activities required by these servicing criteria. The Company has
determined that none of these vendors
is considered a "servicer" as defined in Item llOlU) of Regulation AB, and the Company has elected to
take responsibility for assessing compliance with the servicing criteria applicable to each vendor as
pkermitted 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 eligibility to apply Interpretation 17.06..
In our opinion, management's assessment that the Company complied with the aforementioned servicing
criteria, including servicing criteria 1122(d)(l)(i), 1122(d)(3)(i)(A), 1122(d)(4)(i), and 1122(d)(4)(vi), for
which compliance is determined based on Interpretation 17.06 as described above, as of and for the year
ended December 31,2013 is fairly stated, in all material respects.
San Francisco, California
March 7, 2014
is considered a "servicer" as defined in Item llOlU) of Regulation AB, and the Company has elected to
take responsibility for assessing compliance with the servicing criteria applicable to each vendor as
pkermitted 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 eligibility to apply Interpretation 17.06..
In our opinion, management's assessment that the Company complied with the aforementioned servicing
criteria, including servicing criteria 1122(d)(l)(i), 1122(d)(3)(i)(A), 1122(d)(4)(i), and 1122(d)(4)(vi), for
which compliance is determined based on Interpretation 17.06 as described above, as of and for the year
ended December 31,2013 is fairly stated, in all material respects.
San Francisco, California
March 7, 2014