Attached files
EX-33.6
(logo) SUNTRUST
Certification Regarding Compliance with Applicable Servicing Criteria
1. SunTrust Mortgage, Inc. 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, 2011
(the "Reporting Period"), as set forth in Appendix A hereto. The transactions
covered by this report include asset-backed securities transactions for which
SunTrust Mortgage, Inc. acted as servicer, involving residential mortgage
loans occurring after December 31, 2005 (the "Platform") as listed in
Appendix B;
2. SunTrust Mortgage, Inc. has engaged certain vendors, which are not deemed to
be servicers as defined in Item 1101(j) of Regulation AB (the "Vendors"), to
perform specific, limited or scripted activities, and SunTrust Mortgage, Inc.
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, SunTrust Mortgage, Inc. 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 SunTrust Mortgage, Inc. based on the
activities it performs, directly or through its Vendors, with respect to the
Platform;
5. Except as set forth on Appendix C, SunTrust Mortgage, Inc. has complied, in
all material respects, with the applicable servicing criteria as of December
31, 2011, and for the Reporting Period with respect to the Platform taken as
a whole;
6. SunTrust Mortgage, Inc. 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, 2011, and for the Reporting Period with respect
to the Platform taken as a whole;
7. SunTrust Mortgage, Inc. 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, 2011, and for the Reporting
Period with respect to the Platform taken as a whole; and
8. Ernst and Young LLP, a registered public accounting firm, has issued an
attestation report on SunTrust Mortgage, Inc.'s assessment of compliance with
the applicable servicing criteria for the Reporting Period.
SunTrust Mortgage, Inc
/s/ Michael R. Zarro, Jr.
Michael R. Zarro, Jr.
Executive VP-Default Division
Dated: March 13, 2012
SunTrust Mortgage, Inc.
/s/ Mark M. Pregmon
Mark M. Pregmon
Executive VP-Sevicing Division
Dated: March 13, 2012
(page)
APPENDIX A
INAPPLICABLE
APPLICABLE SERVICING
SERVICING CRITERIA SERVICING CRITERIA CRITERIA
NOT
Performed by performed by
Performed by subservicer(s) SunTrust
Vendor(s) for or vendor(s) Mortgage, Inc.
which for which or by
Performed SunTrust SunTrust subservicer(s)
Directly Mortgage, Inc. Mortgage, Inc. or vendor(s)
by is the is NOT the retained by
SunTrust Responsible Responsible SunTrust
Reference Criteria Mortgage, Inc. Party Party Mortgage, Inc.
General Servicing Considerations
Policies and procedures are instituted X
to monitor any performance or other
triggers and events of default in
accordance with the transaction
1122(d)(1)(i) agreements.
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
1122(d)(1)(ii) activities.
Any requirements in the transaction X
agreements to maintain a back-up servicer
1122(d)(1)(iii) for the pool assets are maintained.
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
1122(d)(1)(iv) the transaction agreements.
Cash Collection and Administration
Payments on pool assets are deposited X X^1 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
1122(d)(2)(i) agreements.
Disbursements made via wire transfer on X
behalf of an obligor or to investor are
1122(d)(2)(ii) made only by authorized personnel.
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
1122(d)(2)(iii) the transaction agreements.
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
1122(d)(2)(iv) the transaction agreements.
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)
1122(d)(2)(v) of the Securities Exchange Act.
Unissued checks are safeguarded so as X
1122(d)(2)(vi) to prevent unauthorized access.
X^1 Vendors: PayMap, CheckFree, and Western Union in aggregate are responsible for the payments component of
this criterion at levels less than 5%.
X^2 SunTrust Bank., is responsible for the lockbox payments component of this criterion.
(page)
INAPPLICABLE
APPLICABLE SERVICING
SERVICING CRITERIA SERVICING CRITERIA CRITERIA
NOT
Performed by performed by
Performed by subservicer(s) SunTrust
Vendor(s) for or vendor(s) Mortgage, Inc.
which for which or by
Performed SunTrust SunTrust subservicer(s)
Directly Mortgage, Inc. Mortgage, Inc. or vendor(s)
by is the is NOT the retained by
SunTrust Responsible Responsible SunTrust
Reference Criteria Mortgage, Inc. Party Party Mortgage, Inc.
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
1122(d)(2)(vii) agreements.
Investor Remittances and Reporting
Reports to investors, including those X^3
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;
(D) agree with the investors' or trustee's
records as to the total unpaid principal
balance and number of pool assets
1122(d)(3)(i) serviced by the Servicer.
Amounts due to investors are allocated X^3
and remitted in accordance with
timeframes, distribution priority and
other terms set forth in the transaction
1122(d)(3)(ii) agreements.
Disbursements made to an investor are X^3
posted within two business days to the
Servicer's investor records, or such other
number of days specified in the transaction
1122(d)(3)(iii) agreements.
Amounts remitted to investors per the X^3
investor reports agree with cancelled
checks, or other form of payment, or
1122(d)(3)(iv) custodial bank statements.
Pool Asset Administration
Collateral or security on pool assets X^4
is maintained as required by the
transaction agreements or related
1122(d)(4)(i) mortgage loan documents.
Pool asset and related documents are X^4
safeguarded as required by the
1122(d)(4)(ii) transaction agreements
Any additions, removals or substitutions X
to the asset pool are made, reviewed
and approved in accordance with
any conditions or requirements in the
1122(d)(4)(iii) transaction agreements.
X^3 For purposes of assessing the servicing criteria listed in Items 1122(d)(3)(i) - (iv), SunTrust Mortgage has
determined, consistent with the Securities and Exchange Commission Telephone Interpretation 11.03, that the
"investor" for these purposes is the entity to which SunTrust Mortgage provides the related information (i.e.,
master servicer, trustee, etc.).
X^4 1122(d)(4)(i),(ii) SunTrust Bank, the parent of SunTrust Mortgage, Inc., is responsible for the safeguarding and
custodial component of this criterion.
(page)
INAPPLICABLE
APPLICABLE SERVICING
SERVICING CRITERIA SERVICING CRITERIA CRITERIA
NOT
Performed by performed by
Performed by subservicer(s) SunTrust
Vendor(s) for or vendor(s) Mortgage, Inc.
which for which or by
Performed SunTrust SunTrust subservicer(s)
Directly Mortgage, Inc. Mortgage, Inc. or vendor(s)
by is the is NOT the retained by
SunTrust Responsible Responsible SunTrust
Reference Criteria Mortgage, Inc. Party Party Mortgage, Inc.
Payments on pool assets, including any X
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
1122(d)(4)(iv) with the related pool asset documents.
The Servicer's records regarding the X
pool assets agree with the Servicer's
records with respect to an obligor's
1122(d)(4)(v) unpaid principal balance.
Changes with respect to the terms or X
status of an obligor's pool assets (e.g.,
loan modifications or re-agings) are made,
reviewed and approved by authorized
personnel in accordance with the
transaction agreements and related pool
1122(d)(4)(vi) asset documents.
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
1122(d)(4)(vii) agreements.
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.,
1122(d)(4)(viii) illness or unemployment).
Adjustments to interest rates or rates X
of return for pool assets with variable
rates are computed based on the related
1122(d)(4)(ix) pool asset documents.
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
1122(d)(4)(x) agreements.
Payments made on behalf of an obligor X X^5
(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
1122(d)(4)(xi) 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.
Any late payment penalties in X
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
1122(d)(4)(xii) to the obligor's error or omission.
X^5 QBE aka Sterling National, aka ZC Sterling, Inc. is responsible for the insurance payments component of this
criterion.
(page)
INAPPLICABLE
APPLICABLE SERVICING
SERVICING CRITERIA SERVICING CRITERIA CRITERIA
NOT
Performed by performed by
Performed by subservicer(s) SunTrust
Vendor(s) for or vendor(s) Mortgage, Inc.
which for which or by
Performed SunTrust SunTrust subservicer(s)
Directly Mortgage, Inc. Mortgage, Inc. or vendor(s)
by is the is NOT the retained by
SunTrust Responsible Responsible SunTrust
Reference Criteria Mortgage, Inc. Party Party Mortgage, Inc.
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
1122(d)(4)(xiii) agreements.
Delinquencies, charge-offs, and X
uncollectible accounts are recognized and
recorded in accordance with the
1122(d)(4)(xiv) transaction agreements.
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
1122(d)(4)(xv) forth in the transaction agreements.
(page)
APPENDIX B
Year Deal ID
2006 GSAA 2006-1
2006 BAFC 2006-1
2006 SARM 2006-1
2006 LXS 2006-1
2006 BAFC 06-002
2006 JPALT 2006-SI
2006 LXS 2006-3
2006 LMT 2006-2
2006 SASCO 2006-3H
2006 MASTR 2006-1
2006 CSMC 2006-3
2006 GSAA 2006-5
2006 MALT 2006-2
2006 BAFC 2006-3
2006 SARM 2006-3
2006 JPALT 2006-S2
2006 JPMMT 2006-A3
2006 JPALT 2006-A2
2006 CSMC 2006-4
2006 LX2006-7
2006 BSABS 2006-SD2
2006 CMLTI 2006-4
2006 CSMC 2006-5
2006 JPMMT 2006-A4
2006 STALT 2006-1F
2006 MASTR 2006-2
2006 JPMMT 2006-S2
2006 JPALT 2006-S3
2006 MALT 2006-3
2006 BAFC 2006-4
2006 CSMC 2006-7
2006 JPMMT2006-A5
2006 LXS 2006-11
2006 LMT2006-4
2006 TMST 2006-5
2006 GSAA2006-14
2006 LXS 2006-15
2006 BAFC 2006-6
2006 BAFC 2006-5
2006 CSMC 2006-8
2006 JPMMT 2006-A6
2006 CSAB 06-02
2006 LMT 2006-7
2006 GSR 2006-9F
2006 MASTR 2006-3
2006 BSAB 2006-STI
(page)
2006 CSAB 2006-3
2006 BAFC 2006-7
2006 CSMC 2006-9
2006 GSAA 2006-17
2006 GSAA2006-19
2006 JPALT 2006-S4
2006 GSAA0620
2007 HALO 2007-AR1
2007 MALT 2007-1
2007 BAFC 2007-1
2007 CMLTI 2007-AR1
2007 CSMC 2007-1
2007 STARM 2007-1
2007 GSAA 2007-2
2007 BAFC 2007-2
2007 ARMT 2007-1
2007 WMLT 2007-A
2007 CSMC 2007-3
2007 JPMMT 2007-S1
2007 STARM 2007-2
2007 BAFC 2007-3TC
2007 CMLTI 2007-6
2007 CSAB 2007-1
2007 JPALT 2007-S1
2007 BAFC 2007-4
2007 ARMT 2007-2
2007 JPMMT 2007-S2
2007 CMLTI 2007-AR7
2007 HarborView 2007-4
2007 STARM 2007-3
2007 GSR 2007-4F
2007 STARM 2007-S1
2007 LMT 2007-7
2007 BAFC 2007-6
2007 CSMC 2007-5
2007 HALO 2007-AR2
2007 BAFC 2007-7
2007 STARM 2007-4
2007 BAFC 2007-8
2007 CSMC 2007-6
2007 MASTR 2007-1
2007 HALO 2007-2
2007 CMLTI 2007-10
2007 CSMC 2007-7
2007 MASTR 2007-2
2007 GSR 2007-5F
2008 BAFC 2008-1
2011 SEMT 2011-2
(page)
2005 2005-QWH13
2006 2006-QS1
2006 2006-QS10
2006 2006-QS11
2006 2006-QS12
2006 2006-QS13
2006 2006-QS14
2006 2006-QS15
2006 2006-QS16
2006 2006-QS17
2006 2006-QS18
2006 2006-QS3
2006 2006-QS4
2006 2006-QS6
2006 2006-QS7
2006 2006-QS8
2006 2006-QS9
2006 2006-RS3
2006 2006-RS4
2006 2006-RS5
2006 2006-RS6
2006 2006-S10
2006 2006-S11
2006 2006-S12
2006 2006-S5
2006 2006-S6
2006 2006-S7
2006 2006-S8
2006 2006-S9
2006 2006-WH11
2007 2007-DBALT-RAMP1
2007 2007-QA1
2007 2007-QA2
2007 2007-QS1
2007 2007-QS2
2007 2007-QS3
2007 2007-QS4
2007 2007-QS5
2007 2007-QS6
2007 2007-QS7
2007 2007-QS8
2007 2007-QS9
2007 2007-RS1
2007 2007-RS2
2007 2007-RZ1
2007 2007-S1
2007 2007-S2
2007 2007-S4
(page)
2007 2007-S7
2007 2007-S8
2007 2007-SA1
2007 2007-SARM-3 LEHMAN
2007 2007-SP2
2007 2007-SP3
(page)
APPENDIX C
1122(d)(1)(i)
In connection with our assessment of SunTrust Mortgage, Inc practices, it was
discovered that its policies and procedures to monitor performance and other
triggers and events of default related to loss mitigation and foreclosure
timelines were insufficient.
Remediation Activities
SunTrust Mortgage, Inc. has undertaken a review of these policies and
procedures and is strengthening its monitoring of any performance or other
triggers and events of default related to loss mitigation and foreclosure
timelines to ensure they comply with the transaction agreements.
1122(d)(4)(vi)
SunTrust Mortgage, Inc. discovered that it did not follow certain provisions in
transaction documents related to changes with respect to the terms or status of
an obligor's pool assets (e.g., loan modifications or re-agings).
Remediation Activities
SunTrust Mortgage, Inc. has undertaken a review of these policies and
procedures and is developing a plan to strengthen and monitor its actions
related to changes with respect to the terms or status of an obligor's pool
assets to ensure they are in compliance with transaction agreements.
1122(d)(4)(vii)
SunTrust Mortgage, Inc. discovered that it did not follow certain loss
mitigation timelines established by the transaction agreements in certain
instances.
Remediation Activities
SunTrust Mortgage, Inc has undertaken an initiative to identify external and
internal factors impacting timelines to develop a process that is streamlined.
The enhanced process implementation will improve the compliance, consistency,
and effectiveness of foreclosure processing and improve timeline performance.
