EX-33.8
(logo) WACHOVIA SECURITIES
Wachovia Securities
201 South College Street
CP9
Charlotte, NC 28244-1075
Management Assessment
Management of the Real Estate Asset Management Business Unit of Wachovia Bank,
National Association ("the Company") is responsible for assessing compliance
with the applicable servicing criteria set forth in Item 1122(d) of Regulation
AB of the Securities and Exchange Commission relating to the servicing of
asset-backed security transactions involving commercial real estate loans issued
on or after January 1, 2006 ("the Platform"), except for servicing criteria
1122(d)(1)(iii), 1122(d)(3)(i)(C), 1122(d)(3)(ii), 1122(d)(3)(iii),
1122(d)(3)(iv), 1122(d)(4)(ix), 1122(d)(4)(x)(A), 1122(d)(4)(x)(C),
1122(d)(4)(xi), 1122(d)(4)(xii), and 1122(d)(4)(xv), which the Company has
determined are not applicable to the activities it performs with respect to the
Platform, as of and for the year ended December 31, 2007. Servicing criterion
1122(d)(4)(i) is applicable to the activities the Company performs with respect
to the Platform only as it relates to the review and approval of any release,
non-scheduled reduction or draw of letters of credit which serve as collateral
for certain individual pool assets. Servicing criterion 1122(d)(4)(ii) is
applicable to the activities the Company performs with respect to the Platform
only as it relates to the safeguarding of letters of credit which serve as
collateral for certain individual pool assets. Servicing criteria
1122(d)(4)(vi), 1122(d)(4)(vii), 1122(d)(4)(viii) and 1122(d)(4)(xiv) are
applicable to the activities the Company performs with respect to the Platform
only as it relates to the servicing of the applicable individual pool assets
until the assets are transferred to the Special Servicer, unless the Company is
designated as the Special Servicer. Servicing criterion 1122(d)(4)(xiii) is
applicable to the activities the Company performs with respect to the Platform
as it relates to disbursements made on behalf of an obligor other than for tax
payments. Appendix A identifies the individual asset-backed security
transactions defined by management as constituting the Platform.
The Company's management has assessed the Company's compliance with the
applicable servicing criteria as of and for the year ended December 31, 2007. In
making this assessment, management used the criteria set forth by the Securities
and Exchange Commission in paragraph (d) of Item 1122 of Regulation AB.
(Appendix B)
Based on such assessment, management believes that as of and for the year ended
December 31, 2007, the Company has complied in all material respects with the
servicing criteria set forth in Item 1122(d) of Regulation AB of the Securities
and Exchange Commission relating to the servicing of the Platform, except for
the material noncompliance described in the following paragraph.
Our assessment of compliance disclosed the following material noncompliance with
servicing criteria 1122(d)(2)(i) and 1122(d)(2)(ii), as applicable to the
Company during the year ended December 31, 2007:
(page)
With respect to servicing criterion 1122(d)(2)(i), certain payments on pool
assets were not deposited into the appropriate custodial bank accounts within
the timeframe as specified in the transaction agreements. Those payments were
deposited into the appropriate custodial bank accounts after those timeframes.
Management does not believe that this failure to follow the transaction
agreements resulted in any loss of control over trust assets or in any impact to
investors. The Company implemented additional controls in 2008 to better monitor
these processes and correct the non-compliance.
With respect to servicing criterion 1122(d)(2)(ii), certain disbursements made
via wire transfer were authorized by personnel for amounts greater than such
personnel's approval limits. Management does not believe that this failure to
follow internal procedures resulted in any incorrect wire transfers or in any
impact to investors. The Company implemented additional controls in 2007 to
better monitor these processes and correct the non-compliance.
KPMG LLP, a registered public accounting firm, has issued an attestation report
with respect to the Company's compliance with the applicable servicing criteria
as of and for the year ended December 31, 2007.
March 7, 2008
/s/ Leslie Fairbanks
Leslie Fairbanks
Managing Director, Wachovia Bank Real Estate Asset Management
/s/ Timothy Ryan
Timothy Ryan
Managing Director, Wachovia Bank Real Estate Asset Management
/s/ Marilyn Addison
Marilyn Addison
Director, Wachovia Bank Real Estate Asset Management
(page)
APPENDIX A
NEWCASTLE CDO IX
GREENWICH CCFC 2007-GG9
JP 2007-LDP10
MLCFC 2007-6
WACHOVIA 2007-C30
CD2007-CD4
COBALT 2007-C2
GECMC 2007-C1
CSMC 2007-C2
LB-UBS 2007-C2
WACHOVIA 2007-C31
MLCFC 2007-7
MSCI 2007-IQ14
WACHOVIA 2007-WHALE 8
WACHOVIA 2007-C32
CSMC 2007-C3
RRE CDO 2007-C1
JPMCC-LDP11
GREENWICH GOLDMAN GG10
TIAA 2007-C4
BACM 2007-3
CGCMT-2007-C6
JPMCC 2007-FL1
COBALT 2007-C3
WACHOVIA 2007-C33
LB-UBS 2007-C6
CSMC 2007-C4
GREENWICH 2007-GG11
WACHOVIA 2007-C34
CD2007-CD5
LB-UBS 2007-C7
CRF 2007-MF1
MSCI 2007-HQ13
WACHOVIA 2007-ESH
MEZZ CAP 2007-C5
NORTHSTAR CDO IV LTD
LB-UBS 2006-C1
WACHOVIA 2006-C23
CD2006-CD2
BACM 2006-1
JP MORGAN 2006 FL1
GE 2006 Cl
GS MORTGAGE SECURITIES 2006 GG6
MLCFC 2006-1
WACHOVIA 2006-C24
LB-UBS 2006 C3
LEHMAN 2006 CCL-C2
CSMS 2006-HC1
MARATHON REAL ESTATE CDO 2006-1
CSFB06C2
WACHOVIA 2006-C25
NORTHSTAR CDO VI
BACM 2006-2
MLCFC 2006-2
JPMC 2006-LDP7
LB-UBS 2006-C4
WACHOVIA 2006-C26
WACHOVIA CRE CDO 2006-1
RESOURCE REAL ESTATE FUNDING CDO-2006-1
GS MORTGAGE SEC CORP II-2006 GSFLVIII
MLMT 2006-C2
111MA2PENN
LEHMAN 2006 LLF-C5
WACHOVIA 2006-C27
WACHOVIA 2006-WHALE 7
LB-UBS 2006-C6
BACM 2006-5
COMM 2006-FL12
GS MORTGAGE SECURITIES 2006 GG8
CD 2006-CD3
WACHOVIA 2006-C28
CITIGROUP 2006-FL2
CITIGROUP 2006-C5
JPMORGAN 2006-FL2
CSFB 2006-TFL2 (TITAN)
LB-UBS 2006-C7
NORTHSTAR CDO VIII
FOUR TIMES SQUARE 2006-4TS
WACHOVIA 2006-C29
COBALT 2006C1
JPMC2006-LDP9
CONCORD REAL ESTATE CDO 2006-1
MEZZ CAP 2006-C4
GREENWICH CCFC 2006 FL4
(page)
APPENDIX B
INAPPLICABLE
APPLICABLE SERVICING
SERVICING CRITERIA SERVICING CRITERIA (1) CRITERIA
Performed Performed by NOT performed
by Vendor(s) by the Company
Vendor(s) for which the or by
Performed for which Company subservicer(s)
Directly the Company is is NOT the or Vendor(s)
by the 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 mortgage loans 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 mortgage loans 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.
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.
INAPPLICABLE
APPLICABLE SERVICING
SERVICING CRITERIA SERVICING CRITERIA (1) CRITERIA
Performed Performed by NOT performed
by Vendor(s) by the Company
Vendor(s) for which the or by
Performed for which Company subservicer(s)
Directly the Company is is NOT the or Vendor(s)
by the the Responsible Responsible retained by
Reference Criteria Company Party Party the Company
Investor Remittances and Reporting
1122(d)(3)(i)(A) Reports to investors, including those to be X(2)
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;
1122(d)(3)(i)(B) (B) provide information calculated in accordance X(2)
with the terms specified in the transaction
agreements;
1122(d)(3)(i)(C) (C) are filed with the Commission X
as required by its rules and regulations;
1122(d)(3)(i)(D) (D) agree with investors' or the trustee's X(2)
records as to the total unpaid principal
balance and number of mortgage loans serviced
by the Servicer.
1122(d)(3)(ii) Amounts due to investors are allocated and X
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
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
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 mortgage loans is X(3) X(3)
maintained as required by the transaction
agreements or related mortgage loan
documents.
1122(d)(4)(ii) Mortgage loan and related documents are X(4)
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 mortgage loans, 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 mortgage
loans documents.
1122(d)(4)(v) Servicer's records regarding the mortgage X
loans agree with the Servicer's records
with respect to an obligor's unpaid principal
balance.
INAPPLICABLE
APPLICABLE SERVICING
SERVICING CRITERIA SERVICING CRITERIA (1) CRITERIA
Performed Performed by NOT performed
by Vendor(s) by the Company
Vendor(s) for which the or by
Performed for which Company subservicer(s)
Directly the Company is is NOT the or Vendor(s)
by the the Responsible Responsible retained by
Reference Criteria Company Party Party the Company
1122(d)(4)(vi) Changes with respect to the terms or status X(5)
of an obligor's mortgage loans (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(5)
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(5)
maintained during the period a mortgage loan
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
mortgage loans 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 mortgage loans with variable rates
are computed based on the related mortgage
loan documents.
1122(d)(4)(x)(A) 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 mortgage loan documents, on at least
an annual basis, or such other period
specified in the transaction agreements;
1122(d)(4)(x)(B) (B) interest on such funds is paid, or credited, X
to obligors in accordance with applicable
mortgage loan documents and state laws; and
1122(d)(4)(x)(C) (C) such funds are returned to the obligor X
within 30 calendar days of full repayment of
the related mortgage loans, or such other
number of days specified in the transaction
agreements.
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(6) X(6)
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(5)
accounts are recognized and recorded in
accordance with the transaction agreements.
INAPPLICABLE
APPLICABLE SERVICING
SERVICING CRITERIA SERVICING CRITERIA (1) CRITERIA
Performed Performed by NOT performed
by Vendor(s) by the Company
Vendor(s) for which the or by
Performed for which Company subservicer(s)
Directly the Company is is NOT the or Vendor(s)
by the the Responsible Responsible retained by
Reference Criteria Company Party Party the Company
1122(d)(4)(xv) Any external enhancement or other support, X
identified in Item 1114(a)(1) through (3) or
Item 1115 of Regulation AB, is maintained as
set forth in the transaction agreements.
<FN>
Footnote 1 - For certain pool assets, the performance of all applicable criteria
has been outsourced to third party servicers. All servicers servicing greater
than 5% of pool assets for any transaction included in the platform (Appendix A)
has provided a separate Regulation AB 1122(d) Management Assessment.
Footnote 2 - The Company's responsibility relating to criteria 1122(d)(3)(i)(A),
1122(d)(3)(i)(B), and 1122(d)(3)(i)(D) is limited to reports sent to the
Trustee, rather than the investor, as set forth in the transaction agreements.
Footnote 3 - The Company's responsibility relating to criteria 1122(d)(4)(i) is
limited to the review and approval of any release, non-scheduled reduction or
draw of letters of credit which serve as collateral for certain individual pool
assets. The Company has outsourced all other activities related to the
maintenance of such letters of credit as well as the process of perfecting
security interests of individual pool assets to a vendor who has a separate
Regulation AB 1122(d) Management Assessment.
Footnote 4 - The Company's responsibility relating to criteria 1122(d)(4)(ii) is
limited to the safeguarding of letters of credit which serve as collateral for
individual pool assets.
Footnote 5 - For those transactions in which the Company is not designated as
the Special Servicer, the Company is only responsible for criteria
1122(d)(4)(vi), 1122(d)(4)(vii), 1122(d)(4)(viii) and 1122(d)(4)(xiv) until the
time in which the applicable pool assets are transferred to the Special Servicer
as specified by the transaction agreements. The Company has been named as
Special Servicer for the following transactions included in the Platform:
NORTHSTAR CDO IV LTD, JP MORGAN 2006 FL1, CSMS 2006-HC1, WBCMT 2007-ESH and
WACHOVIA 2007-WHALE 8.
Footnote 6 - The Company performs all activities related to criteria
1122(d)(4)(xiii), except disbursements made on behalf of an obligor for tax
payments. The Company has outsourced activities related to disbursements on
behalf of an obligor for tax payments to a vendor who has provided a separate
Regulation AB 1122(d) Management Assessment.
</FN>