Exhibit 33.1

          ASSERTION OF COMPLIANCE WITH APPLICABLE SERVICING CRITERIA

The Bank of New York, The Bank of New York Trust Company, N. A. and The Bank
of New York (Delaware) (collectively, the "Company") provides this
platform-level assessment of compliance with the servicing criteria specified
in Item 1122(d) of Regulation AB promulgated by the Securities and Exchange
Commission.

Management has determined that the following servicing criteria are applicable
in regards to the following servicing platform for the following period:

Platform: Publicly-issued (i.e., transaction-level reporting initially
required under the Securities Exchange Act of 1934, as amended) asset-backed
securities issued on or after January 1, 2006 (and like-kind transactions
issued prior to January 1, 2006) for which the Company provides trustee,
securities administration, or paying agent services, other than residential
mortgage-backed securities and other mortgage-related asset-backed securities.
The platform includes like-kind transactions for which the Company provided
trustee, securities administrator, or paying agent services as a result of the
Company's acquisition as of October 1, 2006 of portions of JPMorgan Chase
Bank, N.A.'s corporate trust business, including structured finance agency and
trust transactions.

Applicable Servicing Criteria: All servicing criteria set forth in Item
1122(d), to the extent required by the related transaction agreements as to
any transaction, except for the following criteria: 1122 (d) (1) (ii), (iii),
(iv), (2) (iii), (vi), (4) (vi), (vii), (viii), (x), (xi), (xii), (xiii) and
(xiv).

Period: Twelve months ended December 31, 2006.

With respect to the Platform and the Period, the Company provides the
following assessment of compliance in respect of the Applicable Servicing
Criteria:

o     The Company is responsible for assessing its compliance with the
      Applicable Servicing Criteria.

o     The Company has assessed compliance with the Applicable Servicing
      Criteria.

o     As of December 31, 2006 and for the Period, the Company was in material
compliance with the Applicable Servicing Criteria.

Ernst & Young LLP, an independent registered public accounting firm, has
issued an attestation report with respect to the Company's foregoing
assessment of compliance.

        The Bank of New York                       The Bank of New York
        The Bank of New York Trust                 The Bank of New York Trust
        Company, N.A.                              Company, NA
        The Bank of New York (Delaware)


        /s/ Robert L. Griffin                       /s/ Patrick S. Tadie
        ------------------------------              --------------------
            Robert L. Griffin                           Patrick S. Tadie
            Authorized Signer                           Authorized Signer

March 1, 2007