EX-33.1
(logo) Countrywide
Financial
ASSESSMENT OF COMPLIANCE WITH APPLICABLE SERVICING CRITERIA
Countrywide Financial Corporation and certain of its subsidiaries, including its
direct and indirect wholly-owned subsidiaries, Countrywide Home Loans, Inc.
("CHL"), Countrywide Tax Services Corporation, Newport Management Corporation,
and Countrywide Home Loans Servicing, L.P., a wholly-owned subsidiary of CHL
(collectively, the "Company"), provides this platform-level assessment, for
which Countrywide Financial Corporation and such subsidiaries participated in
servicing functions, as such term is described under Title 17, Section 229.1122
of the Code of Federal Regulations ("Item 1122 of Regulation AB"), of compliance
in respect of the following Applicable Servicing Criteria specified in Item
1122(d) of Regulation AB in regard to the following servicing platform for the
following period:
Platform: 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 cash collection and administration,
investor remittances and reporting (except for those activities relating
to trustee and paying agent services), and pool asset administration
(except for those activities relating to custodial operations of pool
assets and related documents), and for which the related issuer has a
fiscal year end of December 31, 2007. The platform excludes any
transactions issued by any government sponsored enterprise for which
the Company provides the servicing functions described in the preceding
sentence.
Period: as of and for the year ended December 31, 2007.
Applicable Servicing Criteria: all servicing criteria set forth in
Schedule A hereto, to the extent required in the related agreements,
except the criteria listed in the column titled "Inapplicable Servicing
Criteria" on Schedule A hereto and the portions of the criteria
footnoted on that schedule that are inapplicable to the Company based on
the activities it performs with respect to the Platform.
With respect to the Platform and the Period, the Company provides the following
assessment of compliance in respect of the Applicable Servicing Criteria:
1. The Company is responsible for assessing its compliance with the
Applicable Servicing Criteria.
2. The Company has assessed compliance with the Applicable Servicing
Criteria.
3. Other than as identified on Schedule B hereto, as of and for the
Period, the Company complied in all material respects with the
Applicable Servicing Criteria.
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KPMG LLP, an independent registered public accounting firm, has issued an
attestation report with respect to the Company's foregoing assessment of
compliance as of and for the year ended December 31, 2007.
COUNTRYWIDE FINANCIAL CORPORATION
By: /s/ Steve Bailey
Steve Bailey
Its: Senior Managing Director and Chief Executive Officer,
Loan Administration
Dated: February 28, 2008
By: /s/ Kevin Meyers
Kevin Meyers
Its: Managing Director and Chief Financial Officer,
Countrywide Home Loans, Inc. Loan Administration
Dated: February 28, 2008
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Schedule A
Applicable Servicing Criteria
INAPPLICABLE
APPLICABLE SERVICING
SERVICING CRITERIA SERVICING CRITERIA CRITERIA
Performed
by Performed by NOT
Vendor(s) subservicer(s) performed by
for which or Vendor(s) the Company
Performed the for which the or by
Directly Company is Company is subservicer(s)
by the NOT the or Vendor(s)
the Responsible Responsible retained by
Reference Criteria Company Party Party the Company
General Servicing Considerations
1122(d)(1)(i) Policies and procedures are instituted to X
monitor any performance or other triggers and
events of default in accordance with the
transaction agreements.
1122(d)(1)(ii) If any material servicing activities are X
outsourced to third parties, policies and
procedures are instituted to monitor the
third party's performance and compliance with
such servicing activities.
1122(d)(1)(iii) Any requirements in the transaction X
agreements to maintain a back-up servicer for
the pool assets are maintained.
1122(d)(1)(iv) A fidelity bond and errors and omissions
policy is in effect on the party X
participating in the servicing function
throughout the reporting period in the amount
of coverage required by and otherwise in
accordance with the terms of the transaction
agreements.
Cash Collection and Administration
1122(d)(2)(i) Payments on pool assets are deposited into X
the appropriate custodial bank accounts and
related bank clearing accounts no more than
two business days following receipt, or such
other number of days specified in the
transaction agreements.
1122(d)(2)(ii) Disbursements made via wire transfer on X
behalf of an obligor or to an investor are
made only by authorized personnel.
1122(d)(2)(iii) Advances of funds or guarantees regarding X
collections, cash flows or distributions, and
any interest or other fees charged for such
advances, are made, reviewed and approved as
specified in the transaction agreements.
1122(d)(2)(iv) The related accounts for the transaction, X
such as cash reserve accounts or accounts
established as a form of
overcollateralization, are separately
maintained (e.g., with respect to commingling
of cash) as set forth in the transaction
agreements.
INAPPLICABLE
APPLICABLE SERVICING
SERVICING CRITERIA SERVICING CRITERIA CRITERIA
Performed
by Performed by NOT
Vendor(s) subservicer(s) performed by
for which or Vendor(s) the Company
Performed the for which the or by
Directly Company is Company is subservicer(s)
by the NOT the or Vendor(s)
the Responsible Responsible retained by
Reference Criteria Company Party Party the Company
1122(d)(2)(v) Each custodial account is maintained at a X
federally insured depository institution as
set forth in the transaction agreements. For
purposes of this criterion, "federally
insured depository institution" with respect
to a foreign financial institution means a
foreign financial institution that meets the
requirements of Rule 13k-1(b)(1) of the
Securities Exchange Act.
1122(d)(2)(vi) Unissued checks are safeguarded so as to X
prevent unauthorized access.
1122(d)(2)(vii) Reconciliations are prepared on a monthly X
basis for all asset-backed securities related
bank accounts, including custodial accounts
and related bank clearing accounts. These
reconciliations are (A) mathematically
accurate; (B) prepared within 30 calendar
days after the bank statement cutoff date, or
such other number of days specified in the
transaction agreements; (C) reviewed and
approved by someone other than the person who
prepared the reconciliation; and (D) contain
explanations for reconciling items. These
reconciling items are resolved within 90
calendar days of their original
identification, or such other number of days
specified in the transaction agreements.
Investor Remittances and Reporting
1122(d)(3)(i) Reports to investors, including those to be X^1
filed with the Commission, are maintained in
accordance with the transaction agreements
and applicable Commission requirements.
Specifically, such reports (A) are prepared
in accordance with timeframes and other terms
set forth in the transaction agreements; (B)
provide information calculated in accordance
with the terms specified in the transaction
agreements; (C) are filed with the Commission
as required by its rules and regulations; and
(D) agree with investors' or the trustee's
records as to the total unpaid principal
balance and number of pool assets serviced
by the Servicer.
INAPPLICABLE
APPLICABLE SERVICING
SERVICING CRITERIA SERVICING CRITERIA CRITERIA
Performed
by Performed by NOT
Vendor(s) subservicer(s) performed by
for which or Vendor(s) the Company
Performed the for which the or by
Directly Company is Company is subservicer(s)
by the NOT the or Vendor(s)
the Responsible Responsible retained by
Reference Criteria Company Party Party the Company
1122(d)(3)(ii) Amounts due to investors are allocated and X^2
remitted in accordance with timeframes,
distribution priority and other terms set
forth in the transaction agreements.
1122(d)(3)(iii) Disbursements made to an investor are posted X^3
within two business days to the Servicer's
investor records, or such other number of
days specified in the transaction agreements.
1122(d)(3)(iv) Amounts remitted to investors per the X^4
investor reports agree with cancelled checks,
or other form of payment, or custodial bank
statements.
Pool Asset Administration
1122(d)(4)(i) Collateral or security on pool assets is X^5
maintained as required by the transaction
agreements or related mortgage loan
documents.
1122(d)(4)(ii) Pool assets and related documents are X^5
safeguarded as required by the transaction
agreements
1122(d)(4)(iii) Any additions, removals or substitutions to the X
asset pool are made, reviewed and approved in
accordance with any conditions or requirements
in the transaction agreements.
1122(d)(4)(iv) Payments on pool assets, including any X
payoffs, made in accordance with the related
pool asset documents are posted to the
Servicer's obligor records maintained no more
than two business days after receipt, or such
other number of days specified in the
transaction agreements, and allocated to
principal, interest or other items (e.g.,
escrow) in accordance with the related pool
asset documents.
INAPPLICABLE
APPLICABLE SERVICING
SERVICING CRITERIA SERVICING CRITERIA CRITERIA
Performed
by Performed by NOT
Vendor(s) subservicer(s) performed by
for which or Vendor(s) the Company
Performed the for which the or by
Directly Company is Company is subservicer(s)
by the NOT the or Vendor(s)
the Responsible Responsible retained by
Reference Criteria Company Party Party the Company
1122(d)(4)(v) The Servicer's records regarding the pool X
assets agree with the Servicer's records
with respect to an obligor's unpaid principal
balance.
1122(d)(4)(vi) Changes with respect to the terms or status X
of an obligor's pool assets (e.g., loan
modifications or re-agings) are made,
reviewed and approved by authorized personnel
in accordance with the transaction agreements
and related pool asset documents.
1122(d)(4)(vii) Loss mitigation or recovery actions (e.g., X
forbearance plans, modifications and deeds in
lieu of foreclosure, foreclosures and
repossessions, as applicable) are initiated,
conducted and concluded in accordance with
the timeframes or other requirements
established by the transaction agreements.
1122(d)(4)(viii)Records documenting collection efforts are X
maintained during the period a pool asset
is delinquent in accordance with the
transaction agreements. Such records are
maintained on at least a monthly basis, or
such other period specified in the
transaction agreements, and describe the
entity's activities in monitoring delinquent
pool assets including, for example, phone
calls, letters and payment rescheduling plans
in cases where delinquency is deemed
temporary (e.g., illness or unemployment).
1122(d)(4)(ix) Adjustments to interest rates or rates of X
return for pool assets with variable rates
are computed based on the related pool
asset documents.
1122(d)(4)(x) Regarding any funds held in trust for an X
obligor (such as escrow accounts): (A) such
funds are analyzed, in accordance with the
obligor's pool asset documents, on at least
an annual basis, or such other period
specified in the transaction agreements; (B)
interest on such funds is paid, or credited,
to obligors in accordance with applicable
pool asset documents and state laws; and
(C) such funds are returned to the obligor
within 30 calendar days of full repayment of
the related pool assets, or such other
number of days specified in the transaction
agreements.
INAPPLICABLE
APPLICABLE SERVICING
SERVICING CRITERIA SERVICING CRITERIA CRITERIA
Performed
by Performed by NOT
Vendor(s) subservicer(s) performed by
for which or Vendor(s) the Company
Performed the for which the or by
Directly Company is Company is subservicer(s)
by the NOT the or Vendor(s)
the Responsible Responsible retained by
Reference Criteria Company Party Party the Company
1122(d)(4)(xi) Payments made on behalf of an obligor (such X
as tax or insurance payments) are made on or
before the related penalty or expiration
dates, as indicated on the appropriate bills
or notices for such payments, provided that
such support has been received by the
Servicer at least 30 calendar days prior to
these dates, or such other number of days
specified in the transaction agreements.
1122(d)(4)(xii) Any late payment penalties in connection with X
any payment to be made on behalf of an
obligor are paid from the Servicer's funds
and not charged to the obligor, unless the
late payment was due to the obligor's error
or omission.
1122(d)(4)(xiii)Disbursements made on behalf of an obligor X
are posted within two business days to the
obligor's records maintained by the Servicer,
or such other number of days specified in the
transaction agreements.
1122(d)(4)(xiv) Delinquencies, charge-offs and uncollectible X
accounts are recognized and recorded in
accordance with the transaction agreements.
1122(d)(4)(xv) Any external enhancement or other support, X^6
identified in Item 1114(a)(1) through (3) or
Item 1115 of Regulation AB, is maintained as
set forth in the transaction agreements.
<FN>
1 Servicing functions performed by the Company with respect to
Item 1122(d)(3)(i)(B) do not relate to information other than that contained
in the monthly remittance reports delivered by the Company to the master
servicer, trustee, and/or bond administrator. Servicing functions performed by
the Company with respect to Item 1122(d)(3)(i)(D) do not relate to the
agreeing with investors' records as to the total unpaid principal balance and
number of pool assets serviced by the Company.
2 Servicing functions performed by the Company with respect to
Item 1122(d)(3)(ii) do not relate to amounts other than amounts remitted by
the Company to the master servicer, trustee, and/or bond administrator.
3 Servicing functions performed by the Company with respect to
Item 1122(d)(3)(iii) do not relate to records other than the applicable
custodial bank account statements maintained by the Company pursuant to the
transaction agreements.
4 Servicing functions performed by the Company with respect to
Item 1122(d)(3)(iv) do not relate to records other than custodial bank account
statements and wire records of the Company and the remittance reports prepared
and delivered by the Company.
5 Servicing functions performed by the Company with respect to
Item 1122(d)(4)(i) and Item 1122(d)(4)(ii) do not relate to the custodial
operations of the pool assets and related documents (collateral file) by the
document custodian responsible for such functions for the related transaction.
6 Servicing functions performed by the Company with respect to
Item 1122(d)(4)(xv) do not relate to Item 1115 of Regulation AB (derivative
transactions).
</FN>
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Schedule B
Material Instances of Noncompliance
No material instances of noncompliance: the Company has complied, in all
material respects, with the Applicable Servicing Criteria as of and for the year
ended December 31, 2007.