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.
LaSalle Bank National Association
Name: Barbara L. Marik
Title: Senior Vice President
Appendix A
Reg AB
Reference
Servicing Criteria
Servicing Criteria
Applicable to
LaSalle Bank
National
Association (as
trustee, paying
agent, or
custodian)
Servicing Criteria
Inapplicable to
LaSalle Bank
National
Association ( as
trustee, paying
agent, or
custodian)
General Servicing Considerations
1122(d)(1)(i)
Policies and procedures are instituted to monitor any performance or other
triggers and events of default in accordance with the transaction
agreements.
X
1122(d)(1)(ii)
If any material servicing activities are outsourced to third parties, policies
and procedures are instituted to monitor the third party's performance and
compliance with such servicing activities.
X
1
1122(d)(1)(iii)
Any requirements in the transaction agreements to maintain a back-up
servicer for the Pool Assets are maintained.
X
1122(d)(1)(iv)
A fidelity bond and errors and 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.
X
Cash Collection and Administration
1122(d)(2)(i)
Payments on pool assets are deposited 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.
X
1122(d)(2)(ii)
Disbursements made via wire transfer on behalf of an obligor or to an
investor are made only by authorized personnel.
X
1122(d)(2)(iii)
Advances of funds or guarantees 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.
X
2
1122(d)(2)(iv)
The related accounts for the transaction, such as cash reserve accounts or
accounts established as a form of over collateralization, are separately
maintained (e.g., with respect to commingling of cash) as set forth in the
transaction agreements.
X
1122(d)(2)(v)
Each custodial account is maintained at 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.
X
1122(d)(2)(vi) Unissued checks are safeguarded so as to prevent unauthorized access.
X
1
No material servicing activities were outsourced to third parties during the Reporting Period
2
No advances were made during the Reporting Period.
1122(d)(2)(vii)
Reconciliations are prepared on a 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.
X
Investor Remittances and Reporting
1122(d)(3)(i)
Reports to investors, including those 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
investors' or the
indenture trustee's records as to the total unpaid principal
balance and number of Pool Assets serviced by the related Servicer.
X
1122(d)(3)(ii)
Amounts due to investors are allocated and remitted in accordance with
timeframes, distribution priority and other terms set forth in the
transaction agreements.
X
1122(d)(3)(iii)
Disbursements made to an investor are posted within two business days to
the related Servicer's investor records, or such other number of days
specified in the transaction agreements.
X
1122(d)(3)(iv)
Amounts remitted to investors per the investor reports agree with
cancelled checks, or other form of payment, or custodial bank statements.
X
Pool Asset Administration
1122(d)(4)(i)
Collateral or security on pool assets is maintained as required by the
transaction agreements or related pool asset documents.
X
1122(d)(4)(ii)
Pool assets and related documents are safeguarded as required by the
transaction agreements
X
1122(d)(4)(iii)
Any additions, removals or substitutions to the asset pool are made,
reviewed and approved in accordance with any conditions or requirements
in the transaction agreements.
X
1122(d)(4)(iv)
Payments on pool assets, including any 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.
X
1122(d)(4)(v)
The related Servicer's records regarding the pool assets agree with the
related Servicer's records with respect to an obligor's unpaid principal
balance.
X
1122(d)(4)(vi)
Changes with respect to the terms or 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 asset documents.
X
1122(d)(4)(vii)
Loss mitigation or recovery actions (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.
X
1122(d)(4)(viii)
Records documenting collection efforts 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).
X
1122(d)(4)(ix)
Adjustments to interest rates or rates of return for pool assets with
variable rates are computed based on the related pool asset documents.
X
1122(d)(4)(x)
Regarding any funds held in trust for 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.
X
1122(d)(4)(xi)
Payments made on behalf of an obligor (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.
X
1122(d)(4)(xii)
Any late payment penalties in connection 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.
X
1122(d)(4)(xiii)
Disbursements made on behalf of an 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.
X
1122(d)(4)(xiv)
Delinquencies, charge-offs and uncollectible accounts are recognized and
recorded in accordance with the transaction agreements.
X
1122(d)(4)(xv)
Any external enhancement or other support, identified in Item 1114(a)(1)
through (3) or Item 1115 of Regulation AB, is maintained as set forth in
the transaction agreements.
X
Appendix B
Material Instances of Noncompliance by LaSalle
1122(d)(3)(i)(A) and (B) --During the Reporting Period, certain monthly investor or re mittance
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.
