EX-33.6
LaSalle Bank N.A.
135 South LaSalle Street
Suite 1625
Chicago, IL 60603
Global Securities and Trust Services
Report on Assessment of Compliance with Servicing Criteria
LaSalle Bank National Association ("LaSalle") is responsible for assessing
compliance with the servicing criteria applicable to it under paragraph (d) of
Item 1122 of Regulation AB (17 C.F.R., 229.1122(d)), 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
mortgage-backed securities transactions for which LaSalle, as trustee, paying
agent, or custodian, performed servicing activities, which transactions were
initially closed on or after January 1, 2006, and that were registered with the
Securities and Exchange Commission pursuant to the Securities Act of 1933 (the
"Platform"). LaSalle used the criteria set forth in paragraph (d) of Item 1122
of Regulation AB to assess its compliance with the applicable servicing criteria
for the Reporting Period with respect to the Platform. The criteria listed in
the column titled "Servicing Criteria Inapplicable to LaSalle Bank National
Association (as trustee, paying agent, or custodian)" on Appendix A hereto are
inapplicable to LaSalle based on the activities it performs in its role as
trustee, paying agent, or custodian with respect to the Platform.
Except as identified on Appendix B hereto, LaSalle has complied, in all material
respects, with the applicable servicing criteria identified in Appendix A hereto
for the Reporting Period with respect to the Platform taken as a whole.
PricewaterhouseCoopers LLP, an independent registered public accounting firm has
issued an attestation report on LaSalle's compliance with the applicable
servicing criteria for the Reporting Period.
February 29, 2008
LaSalle Bank National Association
By: /s/ Barbara L. Marik
Name: Barbara L. Marik
Title: Senior Vice President
(page)
Appendix A
Servicing Servicing
Criteria Criteria
Applicable to Inapplicable to
LaSalle Bank LaSalle Bank
National National
Association Association
(as trustee, (as trustee,
Reg AB paying agent, paying agent,
Reference SERVICING CRITERIA or custodian) or custodian)
General Servicing Considerations
1122(d)(1)(i) Policies and procedures are instituted X
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^1
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
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 an investor are
made only by authorized personnel.
1122(d)(2)(iii) Advances of funds or guarantees X^2
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 Rule 13k-1(b)(1)
of the Securities Exchange Act.
1122(d)(2)(vi) Unissued checks are safeguarded so as X
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 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 X
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 the
indenture 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
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
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
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 pool
asset documents.
1122(d)(4)(ii) Pool assets and related documents are X
safeguarded as required by the
transaction agreements.
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
payoffs, made in accordance with the related
pool asset documents are posted to the
related 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 related Servicer's records regarding the X
pool assets agree with the related 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 assets, or such other number
of days specified in the transaction
agreements.
1122(d)(4)(xi) Payments made on behalf of an obligor X
(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 connection X
with any payment to be made on behalf
of an obligor are paid from the related
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
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
Regulation AB, is maintained as set
forth in the transaction agreements.
<FN>
1 No material servicing activities were outsourced to third parties during the Reporting Period
2 No advances were made during the Reporting Period.
</FN>
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Appendix B
Material Instances of Noncompliance by LaSalle
1122(d)(3)(i)(A) and (B) - During the Reporting Period, certain monthly investor
or remittance reports were not prepared in accordance with the terms set forth
in the transaction agreements and certain investor reports did not provide the
information calculated in accordance with the terms specified in the transaction
agreements for which certain individual errors may or may not have been
material.