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EX-33.3
(logo)QBE FIRST
MANAGEMENT'S ASSERTION ON COMPLIANCE WITH
REGULATION AB SERVICING CRITERIA
QBE FIRST Insurance Agency, Inc. (the Asserting Party) is responsible for
assessing compliance as of and for the year ended December 31, 2011 (the
Reporting Period) with the servicing criteria set forth in Title 17, Section
229.1122(d) of the Code of Federal Regulations, excluding the inapplicable
servicing criteria set forth in Exhibit A hereto (such criteria, after giving
effect to the exclusions identified on Exhibit A, the "Applicable Servicing
Criteria"). The transactions covered by this report include all mortgage
backed securities that were registered after January 1, 2006 with the
Securities and Exchange Commission pursuant to the Securities Act of 1933 and
serviced by the Asserting Party on the QBE FIRST Integrated Product Solution
platform (the Platform Transactions). The Asserting Party used the criteria
set forth in paragraph (d) of Item 1122 of Regulation AB to assess compliance
with the Applicable Servicing Criteria.
The Asserting Party has assessed its compliance with the Applicable Servicing
Criteria for the Reporting Period and has concluded that the Asserting Party
has complied, in all material respects, with the Applicable Servicing
Criteria for the Reporting Period with respect to the Platform Transactions.
PricewaterhouseCoopers LLP, an independent registered public accounting firm,
has issued an attestation report on the assessment of compliance with the
Applicable Servicing Criteria for the Reporting Period.
QBE FIRST INSRUANCE AGENCY, INC.
By: /s/Arthur J. Castner
Arthur J. Castner
Title: Senior Vice President-Insurance and Tax Outsourcing Operations
Date: February 8, 2012
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EXHIBIT A
QBE FIRST Integrated Product Solution Platform
APPLICABLE INAPPLICABLE
SERVICING SERVICING
Reference Criteria CRITERIA CRITERIA
General Servicing Considerations
1122(d)(1)(i) Policies and procedures are instituted to monitor any X
performance or other triggers and events of default in
accordance with the transaction agreements.
1122(d)(1)(ii) If any material servicing activities are outsourced to X
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 agreements to maintain X
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 X^i
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 mortgage loans are deposited into the appropriate X
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 behalf of an obligor X
or to an investor are made only by authorized personnel.
1122(d)(2)(iii) Advances of funds or guarantees regarding collections, cash X
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, such as cash reserve X
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 federally insured X
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 prevent unauthorized X^ii
access.
1122(d)(2)(vii) Reconciliations are prepared on a monthly basis for all X
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.
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QBE FIRST Integrated Product Solution Platform
APPLICABLE INAPPLICABLE
SERVICING SERVICING
Reference Criteria CRITERIA CRITERIA
Investor Remittances and Reporting
1122(d)(3)(i) Reports to investors, including those to be filed with the X
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 mortgage loans serviced by the Servicer.
1122(d)(3)(ii) Amounts due to investors are allocated and remitted in accordance X
with timeframes, distribution priority and other terms set forth
in the transaction agreements.
1122(d)(3)(iii) Disbursements made to an investor are posted within two business X
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 investor reports agree with X
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 maintained as required X
by the transaction agreements or related mortgage loan documents.
1122(d)(4)(ii) Mortgage loan and related documents are safeguarded as required X
by the transaction agreements
1122(d)(4)(iii) Any additions, removals or substitutions to the asset pool are X
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 payoffs, made in X
accordance with the related mortgage loan 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 loan documents.
1122(d)(4)(v) The Servicer's records regarding the mortgage loans agree with X
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 of an obligor's X
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., forbearance plans, X
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 maintained during X
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).
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QBE FIRST Integrated Product Solution Platform
APPLICABLE INAPPLICABLE
SERVICING SERVICING
Reference Criteria CRITERIA CRITERIA
1122(d)(4)(ix) Adjustments to interest rates or rates of return for mortgage X
loans with variable rates are computed based on the related
mortgage loan documents.
1122(d)(4)(x) Regarding any funds held in trust for an obligor (such as X
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; (B) interest on such funds is paid, or credited,
to obligors in accordance with applicable mortgage loan documents
and state laws; and (C) such funds are returned to the obligor
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 as tax or insurance X^iii
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 any payment to X^iv
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 are posted within X^v
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 accounts are X
recognized and recorded in accordance with the transaction
agreements.
1122(d)(4)(xv) Any external enhancement or other support, identified in Item X
1114(a)(1) through (3) or Item 1115 of Regulation AB, is
maintained as set forth in the transaction agreements.
i Applicable clients include: American Home Mortgage Servicing, Inc./AHMSI,
AMS Servicing LLC, Marix Servicing, LLC, Sun Trust Mortgage, Inc., Wells
Fargo Home Mortgage, Dovenmuehle Mortgage, Inc., Rushmore Loan Management
Services f/k/a UBS Special Servicing Group
ii Applicable clients include: American Home Mortgage Servicing, Inc./AHMSI,
AMS Servicing LLC, Marix Servicing, LLC. Sun Trust Mortgage, Inc., Wells
Fargo Home Mortgage
iii Applicable clients include: American Home Mortgage Servicing, Inc./AHMSI,
AMS Servicing LLC, Marix Servicing, LLC, Sun Trust Mortgage, Inc., Wells
Fargo Home Mortgage, Dovenmuehle Mortgage, Inc., Rushmore Loan Management
Services f/k/a UBS Special Servicing Group
iv Applicable clients include: American Home Mortgage Servicing, Inc./AHMSI,
AMS Servicing LLC, Marix Servicing, LLC, Sun Trust Mortgage, Inc., Wells
Fargo Home Mortgage, Dovenmuehle Mortgage, Inc., Rushmore Loan Management
Services f/k/a UBS Special Servicing Group
v Applicable clients include: American Home Mortgage Servicing, Inc./AHMSI,
AMS Servicing LLC, Marix Servicing, LLC, Sun Trust Mortgage, Inc., Wells
Fargo Home Mortgage, Dovenmuehle Mortgage, Inc., Rushmore Loan Management
Services f/k/a UBS Special Servicing Group
