Attached files
EX-33.1
(logo) Bank of America
Assessment Regarding Compliance with Applicable Servicing Criteria
1. Bank of America, National Association (the "Servicer") is responsible for
assessing compliance by it with the servicing criteria applicable to it
under paragraph (d) of Item 1122 of Regulation AB, as of December 31, 2011
and for the period from January 1, 2011 through December 31, 2011 (the
"Reporting Period"), as set forth in Appendix A hereto, in connection with
asset-backed securities transactions involving commercial mortgage loan
transactions that involved an offer or sale of asset-backed securities that
were required to be registered on or after January 1, 2006 with the
Securities and Exchange Commission pursuant to the Securities Act of 1933
(the "Platform");
2. The Servicer engaged certain vendors (the "Vendors") to perform certain
specific, limited or scripted activities during the Reporting Period,
related to portions of the servicing criteria as set forth in Appendix A
hereto (such portions of the servicing criteria include, and only include,
Item 1122(d)(2)(i) (only with respect to standard lockbox processing by
depositing checks into the appropriate account indicated by the Servicer)
and Item 1122(d)(4)(xi) (only with respect to verifying outstanding tax
payments and processing such tax payments pursuant to the Servicer's
direction)). The Servicer has elected to take responsibility for assessing
compliance with the portion of the servicing criteria performed by such
Vendors;
3. Except as set forth in paragraph 4 below, the Servicer 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 in Items 1122(d)(1)(iii), 1122(d)(2)(ii) (only with respect to
disbursements made to investors), 1122(d)(2)(iii) (other than with respect
to transactions for which the related transaction agreements specifically
required it to advance property protection expenses or payments of interest
and/or principal), 1122(d)(3)(i), 1122(d)(3)(ii), 1122(d)(3)(iii),
1122(d)(3)(iv), 1122(d)(4)(ii), 1122(d)(4)(vii), 1122(d)(4)(viii) (other
than for the period prior to a servicing transfer event (as defined in the
transaction agreements)) and 1122(d)(4)(xv) (other than with respect to
those items identified in Item 1114(a)(1)), of Regulation AB are
inapplicable to the Servicer based on the activities it performs with
respect to the Platform;
5. The Servicer has complied, in all material respects, with the applicable
servicing criteria for the Reporting Period with respect to the Platform;
6. The Servicer has not identified and is not aware of any material instance of
noncompliance by the Vendors with the applicable servicing criteria for the
Reporting Period with respect to the Platform;
7. The Servicer has not identified any material deficiency in its policies and
procedures to monitor the compliance by the Vendors with the applicable
servicing criteria for the Reporting Period with respect to the Platform;
and
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8. PricewaterhouseCoopers LLP, an independent registered public accounting
firm, has issued an attestation report on the Servicer's assessment of
compliance with the applicable servicing criteria as of December 31, 2011
and for the Reporting Period.
February 24, 2012
BANK OF AMERICA, NATIONAL ASSOCIATION
By: /s/ Janice M. Smith
Name: Janice M. Smith
Title: Managing Director
By: /s/ Jennifer Adams
Name: Jennifer Adams
Title: Director
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APPENDIX A
INAPPLICABLE
APPLICABLE SERVICING SERVICING
SERVICING CRITERIA CRITERIA CRITERIA
Reference Criteria Servicer Vendor
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 mortgage loans 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 mortgage loans are deposited X X
into the appropriate custodial bank (only with respect to
accounts and related bank clearing standard lockbox
accounts no more than two business days processing by
following receipt, or such other number depositing checks into
of days specified in the transaction the appropriate account
1122(d)(2)(i) agreements. indicated by the Servicer)
X
(only with respect
Disbursements made via wire transfer on to disbursements on
behalf of an obligor or to an investor behalf of an
1122(d)(2)(ii) are made only by authorized personnel. obligor)
X
(only with respect
to transactions
for which the
related transaction
agreements
specifically
Advances of funds or guarantees required it to
regarding collections, cash flows or advance property
distributions, and any interest or other protection expenses
fees charged for such advances, are made, or payments of
reviewed and approved as specified in interest and/or
1122(d)(2)(iii) the transaction agreements. principal)
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.
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INAPPLICABLE
APPLICABLE SERVICING SERVICING
SERVICING CRITERIA CRITERIA CRITERIA
Reference Criteria Servicer Vendor
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
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
trustee's records as to the total unpaid
principal balance and number of mortgage
1122(d)(3)(i) loans serviced by the Servicer.
Amounts due to investors are allocated X
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
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
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 mortgage loans X
is maintained as required by the
transaction agreements or related
1122(d)(4)(i) mortgage loan documents.
Mortgage loan and related documents X
are 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.
Payments on mortgage loans, including any X
payoffs, made in 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
1122(d)(4)(iv) with the related mortgage loan documents.
The Servicer's records regarding the X
mortgage loans 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 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
1122(d)(4)(vi) pool asset documents.
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INAPPLICABLE
APPLICABLE SERVICING SERVICING
SERVICING CRITERIA CRITERIA CRITERIA
Reference Criteria Servicer Vendor
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 mortgage (only for the period
loan is delinquent in accordance with prior to a servicing
the transaction agreements. Such records transfer event (as
are maintained on at least a monthly defined in the
basis, or such other period specified in transaction
the transaction agreements, and describe agreements))
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.,
1122(d)(4)(viii) illness or unemployment).
Adjustments to interest rates or rates X
of return for mortgage loans with variable
rates are computed based on the related
1122(d)(4)(ix) mortgage loan 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 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
1122(d)(4)(x) agreements.
Payments made on behalf of an obligor X X
(such as tax or insurance payments) are (only with respect to
made on or before the related penalty or verfiying outstanding
expiration dates, as indicated on the tax payments and
appropriate bills or notices for such processing such tax
payments, provided that such support has payments pursuant to
been received by the servicer at least 30 the Servicer's
calendar days prior to these dates, or direction)
such other number of days specified in
1122(d)(4)(xi) 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.
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 (only with respect
1114(a)(1) through (3) or Item 1115 of to those items
Regulation AB, is maintained as set identified in Item
1122(d)(4)(xv) forth in the transaction agreements. 1114(a)(1))
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