EX-33.1 3 smt12001_33-1.txt EX-33.1 (logo) CENLAR FSB CENTRAL LOAN ADMINISTRATION & REPORTING PO Box 77400 * Ewing, NJ 08628 * 609-883-3900 Management Assessment The Board of Directors Cenlar FSB: Management of Cenlar FSB (the Company) is responsible for assessing compliance with the applicable servicing criteria set forth in Item 1122(d) of Regulation AB of the Securities and Exchange Commission relating to the servicing of residential mortgage loans (the Platform), except for servicing criteria 1122 (d)(1)(iii) Backup Servicer, as of and for the year ended December 31, 2012. This criteria is not applicable to the Company because the Company does not perform activities with respect to the Platform relating to this criteria. With respect to servicing criteria 1122 (d)(4)(xi) and 1122 (d)(2)(vi), management has engaged various vendors to perform the activities required by these servicing criteria. The Company's management has determined that none of these vendors is considered a "servicer" as defined in Item 1101(j) of Regulation AB, and the Company's management has elected to take responsibility for assessing compliance with the servicing criteria applicable to each vendor as permitted by Interpretation 17.06 of the SEC Division of Corporation Finance Manual of Publicly Available Telephone Interpretations ("Interpretation 17.06"). Management has policies and procedures in place designed to provide reasonable assurance that the vendors' activities comply in all material respects with the servicing criteria applicable to each vendor. The Company's management is solely responsible for determining that it meets the SEC requirements to apply Interpretation 17.06 for the vendors and related criteria. Appendix A identifies the individual asset-backed transactions and securities defined by management as constituting the Platform. The Company's management has assessed the Company's compliance with the applicable servicing criteria as of and for the year ended December 31, 2012. In making this assessment, management used the criteria set forth by the Securities and Exchange Commission in paragraph (d) of Item 1122 of Regulation AB. Based on such assessment, management believes that, as of and for the year ended December 31, 2012, the Company has complied, in all material respects with the servicing criteria, except for the servicing criteria 1122 (d)(1)(iii) Backup Servicer, set forth in Item 1122(d) of Regulation AB of the Securities and Exchange Commission relating to the servicing of the Platform. Overnight Mail: Cenlar FSB * 425 Phillips Boulevard * Ewing, NJ 08618 (page) Cenlar FSB March 7, 2013 Page 2 of2 KPMG LLP, an independent registered public accounting firm, has issued an attestation report with respect to management's assessment of compliance with the applicable servicing criteria as of and for the year ended December 31, 2012. /s/ Gregory S. Tornquist Gregory S. Tornquist President & Chief Executive Officer /s/ Stephen W. Gozdan /s/ Jeanne M. Bader Stephen W. Gozdan Jeanne M. Bader Chief Financial Officer Director of Loan Administration March 7, 2013 (page) Appendix A Securities Covered in Cenlar FSB's REG AB Attestation: Wells Fargo Bank, N.A.
Investor Security * Period Subserviced by Cenlar FSB A54 New York Mortgage Company NYMC 06-1 1/1 to 12/31/12 H96 UBS Real Estate Securities, Inc MASTR 06-OA1 1/1 to 12/31/12 D96 UBS Real Estate Securities, Inc MARM 06-OA2 1/1 to 12/31/12 H83 UBS Real Estate Securities, Inc MARM 07-1 1/1 to 12/31/12 J83 UBS Real Estate Securities, Inc MALT 07-1 1/1 to 12/31/12 T83 UBS Real Estate Securities, Inc MAST 07-1 1/1 to 12/31/12 U83 UBS Real Estate Securities, Inc MALT 07-HF1 1/1 to 12/31/12 A83 UBS Real Estate Securities, Inc SMT 2007-1 1/1 to 12/31/12 G52 Opteum Financial Services, LLC OMAC 06-1 1/1 to 12/31/12 H52 Opteum Financial Services, LLC OMAC 06-2 1/1 to 12/31/12 J52 Opteum Financial Services, LLC BAFC 2006-H 1/1 to 12/31/12 K52 Opteum Financial Services, LLC CMLTI 06-FX1 1/1 to 12/31/12 P52 Opteum Financial Services, LLC CMLTI 07-OPX1 1/1 to 12/31/12 G43 Thornburg Mortgage Home Loans TMST 2007-3 1/1 to 12/31/12 (RBS Financial) WF3 Lydian Bank/Wells Fargo GSR 2006 AR1 1/1 to 12/31/12 WF4 Lydian Bank/Wells Fargo GSR 2006 AR2 1/1 to 12/31/12 S06/T06 Morgan Stanley Private Bank, NA Sequoia Mortgage 1/1 to 12/31/12 Trust 2007-2 S06/T06 Morgan Stanley Private Bank, NA Sequoia Mortgage 1/1 to 12/31/12 Trust 2007-3 S06/T06 Morgan Stanley Private Bank, NA Sequoia Mortgage 1/1 to 12/31/12 Trust 2007-4 N06 Morgan Stanley Private Bank, NA MSM 2007-15AR 1/1 to 12/31/12 H06 Redwood Trust, Inc. SEMT 2012-1 1/1 to 12/31/12 K06 Redwood Trust, Inc. SEMT 2012-2 3/1 to 12/31/12 L06 Redwood Trust, Inc. SEMT 2012-3 6/1 to 12/31/12 Z06 Redwood Trust, Inc. SEMT 2012-4 9/1 to 12/31/12 Y06 Redwood Trust, Inc. SEMT 2012-5 10/1 to 12/31/12 RWO Redwood Trust, Inc. SEMT 2012-6 11/1 to 12/31/12
(page) (logo) CENLAR FSB CENTRAL LOAN ADMINISTRATION & REPORTING Certification Regarding Compliance with Applicable Servicing Criteria 1. Cen1ar FSB (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 and for the 12-month period ending December 31, 2012 (the Reporting Period) as set forth in Appendix A hereto. The transactions covered by this report include asset-backed securities transactions involving first lien residential mortgage loans [other than (a) transactions registered prior to compliance with Regulation AB [and (b) Freddie Mac, Fannie Mae and Ginnie Mae residential mortgage loan securitizations]] (the "Platform"); 2. The Servicer has engaged certain vendors (the "Vendors") to perform specific, limited or scripted activities as of and for the period ending December 31, 2012, and the Servicer elects to take responsibility for assessing compliance with the servicing criteria or portion of the servicing criteria applicable to such Vendors as set forth in Exhibit A hereto; 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 listed in the column titled "Inapplicable Servicing Criteria" on Exhibit A hereto are inapplicable to the Servicer based on the activities it performs, directly or through its Vendors, with respect to the Platform; 5. The Servicer has complied, in all material respects, with the applicable servicing criteria as of December 31, 2012 and for the Reporting Period with respect to the Platform taken as a whole; 6. The Servicer 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, 2012 and for the Reporting Period with respect to the Platform taken as a whole; 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 as of December 31, 2012 and for the Reporting Period with respect to the Platform taken as a whole; and 8. A registered public accounting firm (KPMG) has issued an attestation report on the Servicer's assessment of compliance with the applicable servicing criteria for the Reporting Period. Cenlar FSB By: /s/ Michael Blair Name: Michael Blair Title: Senior Vice President February 28, 2013 Date of Certification (page) EXHIBIT A
APPLICABLE INAPPLICABLE SERVICING CRITERIA SERVICING CRITERIA SERVICING CRITERIA Performed by Vendor(s) Performed for which Directly Servicer is by the Responsible Reference Criteria Servicer Party General Servicing Considerations 1122(d)(1)(i) Policies and procedures are instituted X to monitor any performance or other triggers and events of default in accordance with the transaction agreements. 1122(d)(1)(ii) 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 activities. 1122(d)(1)(iii) Any requirements in the transaction X^1 agreements to maintain a backup servicer for the mortgage loans are maintained. 1122(d)(1)(iv) 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 the transaction agreements. Cash Collection and Administration 1122(d)(2)(i) Payments on mortgage loans are deposited X 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. 1122(d)(2)(ii) Disbursements made via wire transfer on X behalf of an obligor or to investor are made only by authorized personnel. 1122(d)(2)(iii) 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 the transaction agreements. 1122(d)(2)(iv) 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 the transaction agreements. 1122(d)(2)(v) 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) of the Securities Exchange Act. 1122(d)(2)(vi) Unissued checks are safeguarded so as X^2 X^3 to prevent unauthorized access. 1 Cenlar does not (i) perform directly, (ii) take responsibility for the performance of by a Vendor, or (iii) retain a subservicer(s) or vendor(s) to perform. 2 Cenlar has procedures in place and monitors the tax Corelogic Tax Services, LLC (formerly First American) and Insurance Assurant Specialty Property (Assurant) vendor's performance and includes the functions in its attestation testing. 3 Both vendors provide processing services for the payment of taxes and insurance premiums. Cenlar monitors their performance and reconciles the checks issued.
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APPLICABLE INAPPLICABLE SERVICING CRITERIA SERVICING CRITERIA SERVICING CRITERIA Performed Performed by by Reference Criteria Servicer Vendor(s) 1122(d)(2)(vii) 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 agreements. Investor Remittances and Reporting 1122(d)(3)(i) Reports to investors, including those X^4 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 loans serviced by the Servicer. 1122(d)(3)(ii) Amounts due to investors are allocated X and remitted in accordance with timeframes, distribution priority and other terms set forth in the transaction agreements. 1122(d)(3)(iii) 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 agreements. 1122(d)(3)(iv) Amounts remitted to investors per the X investor reports agree with cancelled checks, or other form of payment, or custodial bank statements. Pool Asset Administration 1122(d)(4)(i) Collateral or security on mortgage loans X is maintained as required by the transaction agreements or related mortgage loan documents. 1122(d)(4)(ii) Mortgage loan and related documents X are safeguarded as required by the transaction agreements. 1122(d)(4)(iii) Any additions, removals or substitutions X to the asset pool are 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 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 with the related mortgage loan documents. 1122(d)(4)(v) The Servicer's records regarding the X mortgage loans agree with the Servicer's records with respect to an obligor's unpaid principal balance. 1122(d)(4)(vi) 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 pool asset documents. 4 1122(d)(3)(i)c Servicer is not required to file with the SEC. Servicer files reports in accordance with the transaction agreements.
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APPLICABLE INAPPLICABLE SERVICING CRITERIA SERVICING CRITERIA SERVICING CRITERIA Performed Performed by by Reference Criteria Servicer Vendor(s) 1122(d)(4)(vii) 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 agreements. 1122(d)(4)(viii) Records documenting collection efforts X are maintained during 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). 1122(d)(4)(ix) Adjustments to interest rates or rates X of return for mortgage loans with variable rates are computed based on the related mortgage loan documents. 1122(d)(4)(x) 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 agreements. 1122(d)(4)(xi) Payments made on behalf of an obligor X^5 X^6 (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. 1122(d)(4)(xii) 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 to the obligor's error or omission. 1122(d)(4)(xiii) 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 agreements. 1122(d)(4)(xiv) Delinquencies, charge-offs and X uncollectible accounts are recognized and recorded in accordance with the transaction agreements. 1122(d)(4)(xv) 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 forth in the transaction agreements. 5 Cenlar has procedures in place and monitors the tax (Corelogic Tax Services, LLC) and Insurance Vendor's (Assurant) performance and includes this in its attestation testing. 6 Both vendors provide processing services for the payment of taxes and insurance premiums. Cenlar monitors and is responsible for the timely payment of taxes and insurance premiums.
(page) Appendix A Securities Covered in Cenlar FSB's REG AB Attestation: Wells Fargo Bank, N.A.
Investor Issuer Security * Period Subserviced by Cenlar FSB A54 New York Mortgage Company NYMC 06-1 1/1 to 12/31/12 H96 UBS Real Estate Securities, Inc MASTR 06-OA1 1/1 to 12/31/12 D96 UBS Real Estate Securities, Inc MARM 06-OA2 1/1 to 12/31/12 H83 UBS Real Estate Securities, Inc MARM 07-1 1/1 to 12/31/12 J83 UBS Real Estate Securities, Inc MALT 07-1 1/1 to 12/31/12 T83 UBS Real Estate Securities, Inc MAST 07-1 1/1 to 12/31/12 U83 UBS Real Estate Securities, Inc MALT 07-HF1 1/1 to 12/31/12 A83 UBS Real Estate Securities, Inc SMT 2007-1 1/1 to 12/31/12 G52 Opteum Financial Services, LLC OMAC 06-1 1/1 to 12/31/12 H52 Opteum Financial Services, LLC OMAC 06-2 1/1 to 12/31/12 J52 Opteum Financial Services, LLC BAFC 2006-H 1/1 to 12/31/12 K52 Opteum Financial Services, LLC CMLTI 06-FX1 1/1 to 12/31/12 P52 Opteum Financial Services, LLC CMLTI 07-OPX1 1/1 to 12/31/12 G43 Thornburg Mortgage Home Loans TMST 2007-3 1/1 to 12/31/12 (RBS Financial) WF3 Lydian Bank/Wells Fargo GSR 2006 AR1 1/1 to 12/31/12 WF4 Lydian Bank/Wells Fargo GSR 2006 AR2 1/1 to 12/31/12 S06/T06 Morgan Stanley Private Bank, NA Sequoia Mortgage 1/1 to 12/31/12 Trust 2007-2 S06/T06 Morgan Stanley Private Bank, NA Sequoia Mortgage 1/1 to 12/31/12 Trust 2007-3 S06/T06 Morgan Stanley Private Bank, NA Sequoia Mortgage 1/1 to 12/31/12 Trust 2007-4 N06 Morgan Stanley Private Bank, NA MSM 2007-15AR 1/1 to 12/31/12 H06 Redwood Trust, Inc. SEMT 2012-1 1/1 to 12/31/12 K06 Redwood Trust, Inc. SEMT 2012-2 3/1 to 12/31/12 L06 Redwood Trust, Inc. SEMT 2012-3 6/1 to 12/31/12 Z06 Redwood Trust, Inc. SEMT 2012-4 9/1 to 12/31/12 Y06 Redwood Trust, Inc. SEMT 2012-5 10/1 to 12/31/12 RWO Redwood Trust, Inc. SEMT 2012-6 11/1 to 12/31/12