Attached files

  EX-33.6
(logo) WELLS FARGO

Brian W. Bartlett
Executive Vice President
and Business Manager

Corporate Trust Services
MAC N2702-011
9062 Old Annapolis Road
Columbia, MD 21045
410 884-2087
410 715-1690 Fax
brian.bartlett@wellsfargo.com

Wells Fargo Bank, N.A.


ASSESSMENT OF COMPLIANCE WITH THE APPLICABLE SERVICING CRITERIA

Corporate Trust Services division of Wells Fargo Bank, National Association (the
"Company") is responsible for assessing compliance with the servicing criteria
set forth in Item 1122(d) of Regulation AB promulgated by the Securities and
Exchange Commission. The Company has determined that the servicing criteria are
applicable in regards to the servicing platform for the period as follows:

Platform: Publicly-issued (i.e., transaction-level reporting initially required
under the Securities Exchange Act of 1934, as amended) and certain
privately-issued (i.e., for which transaction-level reporting is required
pursuant to contractual obligation) residential mortgage-backed securities,
commercial mortgage-backed securities and other asset-backed securities, for
which the Company provides master servicing, trustee, securities administration
or paying agent services, excluding any such securities issued by any agency or
instrumentality of the U.S. government (other than the Federal Deposit Insurance
Company) or any government sponsored entity, and further excluding the
transactions issued prior to 2006 for which Wells Fargo outsources all material
servicing activities (as defined by Regulation AB)(the "Platform").

Applicable Servicing Criteria: All servicing criteria set forth in Item
1122(d), to the extent required in the related transaction agreements, or
required by the Item 1122(d) servicing criteria in regards to the activities
performed by the Company, except for the following criteria: 1122(d)(4)(ii),
1122(d)(4)(iv), 1122(d)(4)(v), 1122(d)(4)(viii), 1122(d)(4)(ix),
1122(d)(4)(x), 1122(d)(4)(xi), 1122(d)(4)(xii) and 1122(d)(4)(xiii), which
Management has determined are not applicable to the activities the Company
performs with respect to the Platform ("the Applicable Servicing Criteria").

Period: As of and for the twelve months ended December 31, 2011 (the "Period").

Third parties classified as vendors: With respect to servicing criterion
1122(d)(4)(i), the Company has engaged a vendor to handle certain Uniform
Commercial Code filing functions required by the servicing criterion. The
Company has determined that this vendor is not considered a "servicer" as
defined in Item 1101(j) of Regulation AB, and the Company elects to take
responsibility for assessing compliance with the portion of the servicing
criterion applicable to this vendor as permitted by Interpretation 17.06 of the
SEC Division of Corporation Finance Manual of Publicly Available Telephone
Interpretations ("Interpretation 17.06"). The Company has policies and
procedures in place to provide reasonable assurance that the vendor's
activities comply in all material respects with the servicing criterion
applicable to the vendor. The Company is solely responsible for determining
that it meets the SEC requirements to apply Interpretation 17.06 for the vendor
and related criterion.

With respect to the Platform and the Period, the Company provides the following
assessment of compliance with respect to 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,
including the servicing criterion for which compliance is determined based on
Interpretation 17.06 as described above. In performing this assessment,
management used the criteria set forth by the Securities and Exchange
Commission in paragraph (d) of Item 1122 of Regulation AB.

3. Based on such assessment, the Company has complied, in all material respects
with the Applicable Servicing Criteria, except as described in Schedule A
hereto.

4. Schedule B hereto includes Management's discussion of the exceptions noted in
Schedule A, including remediation efforts taken by the Company.

KPMG LLP, an independent registered public accounting firm, has issued an
attestation report on the Company's compliance with the Applicable Servicing
Criteria for the Period.


WELLS FARGO BANK, National Association

By: /s/ Brian Bartlett
Brian Bartlett

Its: Executive Vice President

Dated: February 27, 2012


(page)


Schedule A

Material Instances of Noncompliance by the Company

Management's assessment of compliance with the Applicable Servicing Criteria
set forth by the Securities and Exchange Commission in paragraph (d) of Item
1122 of Regulation AB as of December 31, 2011 and for the Period, disclosed
that material noncompliance occurred with servicing criteria 1122(d)(3)(i)(B)
and 1122(d)(3)(ii), as fol1ows:

* With respect to servicing criterion 1122(d)(3)(i)(B), certain reports to
  investors did not provide information calculated in accordance with the terms
  specified in the transaction agreements.

* With respect to servicing criterion 1122(d)(3)(ii), certain amounts due to
  investors were not allocated and remitted in accordance with timeframes,
  distribution priority and other terms set forth in the transaction agreements.


Schedule B

Management's Discussion on Material Instances of Noncompliance by the Company

Disclosure: During the Period, (i) certain amounts allocated and remitted to
investors were not calculated in accordance with the terms specified in the
transaction agreements, and (ii) certain reports to investors did not provide
information calculated in accordance with the terms specified in the
transaction agreements with respect to waterfall calculations and/or reporting
disclosures. As part of its assessment of compliance with the Applicable
Servicing Criteria, Management identified that in certain instances the
material noncompliance reported in Schedule A hereto was attributable to errors
in the models impacting payments to investors and reporting disclosures,
including those for a subset of RMBS transactions in the Platform that contain
multi-group features, herein referred to as "Subject Transactions". As
Management has determined the modeling errors for Subject Transactions to be
the most significant issue resulting in material instances of noncompliance,
Management's analysis of this issue's impact on the Platform for the Period is
described below in the "Scope".

Scope: Management reviewed all of the distributions to investors during the
Period for the Subject Transactions and all of the models used to prepare
reports to investors for the Subject Transactions and determined that (i) the
total dollar amount of payment errors in excess of $5,000 for any particular
distribution during the Period when aggregating the payment errors for each
affected CUSIP, herein referred to as "Disclosed Errors", for the Subject
Transactions represented approximately one one-thousandth of one percent
(.001%) of the total dollar amount allocated and remitted to investors in all
transactions across the Platform during the Period, (ii) the tranches with
payment errors above $200 for the Subject Transactions with Disclosed Errors
comprised less than one-tenth of one percent (0.1%) of the number of tranches in
the Platform as of December 31, 2011, (iii) there were 17 Subject Transactions
with Disclosed Errors comprising less than one percent (1%) of the total number
of transactions in the Platform as of December 31, 2011, and (iv) 340 of the
Subject Transactions, including those transactions with Disclosed Errors,
required model revisions.

Remediation: For each of the instances of material noncompliance identified by
Management, including Subject Transactions, adjustments have been made to the
waterfall models, as applicable so that the models, in all material respects,
are expected to prepare the investor reports in accordance with the terms
specified in the transaction agreements. Revisions also have been made so that
the investor reports associated with the instances of material noncompliance
are expected to provide information that is, in all material respects,
calculated in accordance with the terms specified in the transaction
agreements.