EX-33.4
(logo) OCWEN
Certification Regarding Compliance with Applicable Servicing Criteria
1. Ocwen Loan Servicing, LLC ("Ocwen") is responsible for assessing compliance
with the servicing criteria applicable to it under paragraph (d) of Item
1122 of Regulation AB, as of and for the 12-month period ending December 31,
2007 (the "Reporting Period"), as set forth in Appendix A hereto. The
transactions covered by this report include asset-backed securities
transactions for which Ocwen acted as servicer involving residential
mortgage loans other than transactions closing prior to the effective date
of Regulation AB (the "Platform") as set forth in Appendix B hereto;
2. Ocwen has engaged certain vendors, which are not servicers as defined in
Item 1101 (j) of Regulation AB (the "Vendors") to perform specific, limited
or scripted activities, and Ocwen elects to take responsibility for
assessing compliance with the servicing criteria or portion of the servicing
criteria applicable to such Vendors' activities as set forth in Appendix A
hereto;
3. Except as set forth in paragraph 4 below, Ocwen used the criteria set forth
in paragraph (d) of Item 1122 of Regulation AB to assess the compliance with
the applicable servicing criteria;
4. The criteria listed in the column titled "Inapplicable Servicing Criteria"
on Appendix A hereto are inapplicable to Ocwen based on the activities it
performs, directly or through its Vendors, with respect to the Platform;
5. Ocwen has complied, in all material respects, with the applicable servicing
criteria as of December 31, 2007 and for the Reporting Period with respect
to the Platform taken as a whole;
6. Ocwen has not identified and is not aware of any material instance of
noncompliance by the Vendors with the applicable servicing criteria as of
December 31, 2007 and for the Reporting Period with respect to the Platform
taken as a whole;
7. Ocwen has not identified any material deficiency in its policies and
procedures to monitor the compliance by the Vendors with the applicable
servicing criteria as of December 31, 2007 and for the Reporting Period with
respect to the Platform taken as a whole; and
8. Crowe Chizek and Company LLC, a registered public accounting firm, has
issued an attestation report on Ocwen's assessment of compliance with the
applicable servicing criteria for the Reporting Period.
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March 6, 2008
Ocwen Loan Servicing, LLC
By: /s/ Ronald M. Faris
Name: Ronald M. Faris
Title: President
A-2
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APPENDIX A
INAPPLICABLE
APPLICABLE SERVICING
SERVICING CRITERIA SERVICING CRITERIA CRITERIA
Performed by
subservicer(s)
Performed by or Vendor(s)
Vendor(s) for for which
Performed which Ocwen Ocwen is
Directly is the NOT the
by Responsible Responsible
Reference Criteria Ocwen Party Party
General Servicing Considerations
1122(d)(1)(i) Policies and procedures are instituted X^1
to 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 X
are 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 X
omissions policy is in effect on the
party 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 X^2 X^2
into 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 investor are
made only by authorized personnel.
1122(d)(2)(iii) Advances of funds or guarantees X
regarding 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 X
transaction, 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.
1122(d)(2)(v) Each custodial account is maintained at X
a 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 Section 240.13k-1(b)(1)
of the Securities Exchange Act.
INAPPLICABLE
APPLICABLE SERVICING
SERVICING CRITERIA SERVICING CRITERIA CRITERIA
Performed by
subservicer(s)
Performed by or Vendor(s)
Vendor(s) for for which
Performed which Ocwen Ocwen is
Directly is the NOT the
by Responsible Responsible
Reference Criteria Ocwen Party Party
1122(d)(2)(vi) Unissued checks are safeguarded so as X^3 X^3
to prevent unauthorized access.
1122(d)(2)(vii) Reconciliations are prepared on a X
monthly basis for all asset-backed
securities related bank accounts,
including custodial accounts and related
bank clearing accounts. These
reconciliations: (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 X^4
to be 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 the investors' or
trustee's records as to the total unpaid
principal balance and number of pool
assets serviced by the Servicer.
1122(d)(3)(ii) Amounts due to investors are allocated X^4
and 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 X^4
posted 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 X
is maintained as required by the
transaction agreements or related mortgage
loan documents.
1122(d)(4)(ii) Pool assets and related documents are X
safeguarded as required by the
transaction agreements.
INAPPLICABLE
APPLICABLE SERVICING
SERVICING CRITERIA SERVICING CRITERIA CRITERIA
Performed by
subservicer(s)
Performed by or Vendor(s)
Vendor(s) for for which
Performed which Ocwen Ocwen is
Directly is the NOT the
by Responsible Responsible
Reference Criteria Ocwen Party Party
1122(d)(4)(iii) Any additions, removals or X
substitutions to the 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^5 X^5
payoffs, made in accordance with 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.
1122(d)(4)(v) The Servicer's records regarding the X
pool 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 X
status of an obligor's pool asset (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 X
(e.g., 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 X
are 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 X
of 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 X
an 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 asset, or such other number
of days specified in the transaction
agreements.
INAPPLICABLE
APPLICABLE SERVICING
SERVICING CRITERIA SERVICING CRITERIA CRITERIA
Performed by
subservicer(s)
Performed by or Vendor(s)
Vendor(s) for for which
Performed which Ocwen Ocwen is
Directly is the NOT the
by Responsible Responsible
Reference Criteria Ocwen Party Party
1122(d)(4)(xi) Payments made on behalf of an obligor X^6 X^6
(such 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 X^7 X^7
connection with 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 X^8 X^8
obligor 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 X
uncollectible accounts are recognized and
recorded in accordance with the
transaction agreements.
1122(d)(4)(xv) Any external enhancement or other X
support, identified in Item
1114(a)(1) through (3) or Item 1115 of
this Regulation AB, is maintained as set
forth in the transaction agreements.
<FN>
1 Ocwen's duties under the applicable transaction agreements are limited to
providing the required information to the party tasked with monitoring any
defaults under the Agreements.
2 Both Regulus Group LLC and Ocwen perform aspects of this servicing criteria.
Regulus is responsible for depositing any checks received into the payment
deposit account. Ocwen is responsible for other forms of payments, and the
sweeping of funds deposited in the payment deposit account to the appropriate
deal level custodial bank accounts.
3 Assurant, Inc. and Ocwen each issue checks and maintain unissued checks.
Assurant issues checks for the insurance advances, while Ocwen issues all other
checks.
4 Ocwen has determined for purposes of assessing the servicing criteria listed
in Items 1122(d)(3(i)-(iv) that, pursuant to the Securities and Exchange
Commission Telephone Interpretation 11.03, the term "investor" as used in those
Items does not pertain to the entity to which Ocwen provides the applicable
information (i.e. Master Servicer, Trustee, etc.) and includes certificate and
bond holders. Consequently, the information regarding such Items provided
herein relates to Ocwen's provision of such information to the entity who
ultimately disseminates such information to the investors.
5 Regulus transmits a daily data file that represents payments received for the
current day to Ocwen. Ocwen then loads the data file received from Regulus in
its servicing system, which then applies the funds in accordance with the terms
of the related transaction agreements.
6 Assurant, Inc. and First American Real Estate Solutions of Texas, L.P.
("First American") transmit daily data files for insurance and taxes,
respectively, which represent payments received for the current day to Ocwen.
Ocwen loads the data files into its servicing system, which records the
disbursements in the system and then sends the applicable funds via mail or
wire.
7 First American identifies late payments and includes them as part of the
daily data transmissions. Ocwen identifies late payments in the data
transmissions and credits to the borrower's applicable account on its servicing
system. Ocwen also maintains control reports to identify any late payments not
identified by First American.
8 First American transmits daily data files that represent disbursements
required to be made by Ocwen. Ocwen loads the stat file into its servicing
system and records the disbursements on the system.
</FN>
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