Cwabs Inc Countrywide Home Loans Serv LP Asset Bk Ce Se 03 3 · 10-K · For 12/31/03 · EX-99.2

Filed On 3/29/04 3:52pm ET   ·   SEC File 333-105643-01   ·   Accession Number 905148-4-1876

Annual Report   ·   Form 10-K
Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: 10-K        Annual Report                                         12     32K 
 2: EX-31       Exh 31                                                 2      7K 
 3: EX-99.1     Exh 99.1                                               2      6K 
 4: EX-99.2     Exh 99.2                                               4     18K 

EX-99.2   ·   Exh 99.2

EX-99.2
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Exhibit 99.2
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EX-99.2
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Accountants and Management Consultants                   [Grant Thornton Logo]  

 REPORT OF INDEPENDENT ACCOUNTANTS ON MANAGEMENT'S
 -------------------------------------------------
ASSERTION ON COMPLIANCE WITH MINIMUM SERVICING STANDARDS
--------------------------------------------------------
 SET FORTH IN THE UNIFORM SINGLE ATTESTATION PROGRAM FOR
 -------------------------------------------------------
MORTGAGE BANKERS
----------------

Board of Directors                                                              
Countrywide Financial Corporation                                               

We have examined management's assertion about Countrywide Financial Corporation 
and Subsidiaries' (including its wholly-owned subsidiary, Countrywide Home      
Loans, Inc. ("CHL") and Countrywide Home Loans Servicing, L.P., a wholly-owned  
subsidiary of CHL) ("the Company") compliance with the minimum servicing        
standards identified in the Mortgage Bankers Association of America's Uniform   
Single Attestation Program for Mortgage Bankers (USAP) as of and for the year   
ended December 31, 2003 included in the accompanying management assertion.      
Management is responsible for the Company's compliance with those minimum       
servicing standards. Our responsibility is to express an opinion on management's
assertion about the entity's compliance based on our examination.               

Our examination was made in accordance with standards established by the        
American Institute of Certified Public Accountants and, accordingly, included   
examining, on a test basis, evidence about the Company's compliance with the    
minimum servicing standards and performing such other procedures as we          
considered necessary in the circumstances. We believe that our examination      
provides a reasonable basis for our opinion. Our examination does not provide a 
legal determination on the Company's compliance with the minimum servicing      
standards.                                                                      

In our opinion, management's assertion that Countrywide Financial Corporation   
and Subsidiaries (including its wholly-owned subsidiary, Countrywide Home Loans,
Inc., and Countrywide Home Loans Servicing, L.P., a wholly-owned subsidiary of  
CHL) complied with the aforementioned minimum servicing standards as of and for 
the year ended December 31, 2003 is fairly stated, in all material respects,    
except as disclosed in the attached Schedule of Findings.                       

/s/ GRANT THORNTON LLP                                                          
----------------------                                                          

Los Angeles, California                                                         
February 27, 2004                                                               

Suite 300                                                                       
1000 Wilshire Blvd.                                                             
Los Angeles, CA 90017 2464                                                      
T        213 627-1717                                                           
F        213 624-6793                                                           
W        www.grantthornton.com                                                  

Grant Thornton LLP                                                              
US Member of Grant Thornton International                                       

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EX-99.2
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 COUNTRYWIDE FINANCIAL CORPORATION
 SCHEDULE OF FINDINGS - USAP
 DECEMBER 31, 2003

Statement of Condition:                                                         
----------------------                                                          

During our testing of the Custodial Cash bank reconciliations, we noted that 1  
reconciliation out of 30 reconciliations was not prepared within 45 days of the 
cutoff date. Additionally, there were 2 reconciliations out of 30               
reconciliations that had items outstanding greater than 90 days that could have 
been cleared earlier. Each of these exceptions did not meet the minimum         
servicing standards set forth in the Mortgage Banker's Association's Uniform    
Single Attestation Program for Mortgage Bankers (the USAP).                     

Criteria:                                                                       
--------                                                                        

The Uniform Single Attestation Program for Mortgage Bankers, Section I.1.       
requires that reconciliations are mathematically accurate and are prepared      
within forty-five (45) calendar days after the cutoff date. Reconciling items   
shall also be resolved within ninety (90) calendar days of their original       
identification.                                                                 

Recommendation:                                                                 
--------------                                                                  

We recommend that the Company prepare Custodial Cash bank reconciliations and   
clear reconciling items within the minimum time periods specified by the USAP.  

Corrective Action Plan:                                                         
----------------------                                                          

Due to significant increases in volume of activity and staff turn-over, these   
accounts were being handled by inexperienced staff members. The Company has     
since increased the number and quality of staff in this area through additional 
hiring and training. As a result, the Company is not aware of any current USAP  
violations related to these accounts.                                           

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                                  [Countrywide Logo]
February 27, 2004                                                               
                                 4500 Park Granada
                                           Calabasas, California 91302
                              (818) 225-3000

Grant Thornton LLP                                                              
1000 Wilshire Boulevard                                                         
Suite 300                                                                       
Los Angeles, CA  90017                                                          

Gentlemen:                                                                      

As of and for the year ended December 31, 2003, Countrywide Financial           
Corporation and Subsidiaries (which includes its wholly-owned subsidiary,       
Countrywide Home Loans, Inc. ("CHL"), and Countrywide Home Loans Servicing,     
L.P., a wholly owned subsidiary of CHL) ("the Company") has complied in all     
material respects with the minimum servicing standards set forth in the Mortgage
Bankers Association of America's Uniform Single Attestation for Mortgage        
Bankers, except as disclosed in the attached Schedule of Findings to the report.
As of and for this same period, the Company had in effect a fidelity bond and   
errors and omissions policy in the amount of $215 million and $240 million,     
respectively.                                                                   

The Company investigated the matters noted in the Schedule of Findings and noted
that due to significant increases in volume of activity and staff turn-over,    
these accounts were being handled by inexperienced staff members. The Company   
has since increased the number and quality of staff in this area through        
additional hiring and training. As a result, they are not aware of any current  
USAP violations related to these accounts.                                      

Sincerely,                                                                      

/s/ Thomas K. McLaughlin                                                        
------------------------                                                        
Thomas K. McLaughlin                                                            
Senior Managing Director and                                                    
Chief Financial Officer                                                         

/s/ Kevin Meyers                                                                
----------------                                                                
Kevin Meyers                                                                    
Managing Director, Finance                                                      
Loan Administration                                                             

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Dates Referenced Herein   and   Documents Incorporated By Reference

				Referenced-On Page
This 10-K Filing		Date		First		Last			Other Filings
For The Period Ended		12/31/03		2		4
		2/27/04		2		4
Filed On / Filed As Of		3/29/04
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