exv99w4

Exhibit 99.4

Berkadia Commercial Mortgage LLC
Report on Compliance with Minimum
Master Servicing Standards
As of and for the Year Ended December 31, 2009

Management’s Assertion Concerning Compliance
With Minimum Master Servicing Standards

February 26, 2010

As of and for the year ended December 31, 2009, Berkadia Commercial Mortgage LLC (“Berkadia”) the operations of which were previously part of Capmark Finance Inc. (“Capmark Finance”), has complied in all material respects, with the minimum master servicing standards set forth in the Master Servicing Policy (attached in Exhibit I) which were derived from the Mortgage Bankers Association of America’s Uniform Single Attestation Program for Mortgage Bankers. For the purposes of our assertion, our compliance with the Master Servicing Policy as of and for the year ended December 31, 2009 comprehends compliance of Berkadia as of December 31, 2009 and for the period from December 11, 2009 through December 31, 2009, and Capmark Finance Inc. for the period from January 1, 2009 through December 10, 2009. Collectively for those periods, Berkadia and Capmark Finance are referred to herein as “the Company.” A listing of transactions associated with master servicing responsibility is listed in Exhibit II.

As of December 31, 2009, Berkadia was covered by insurance policies providing for $100 million of fidelity bond insurance and $100 million of errors and omission insurance.




Joseph A. Funk
Executive Vice President & Chief Financial Officer Berkadia Commercial Mortgage LLC



Richard Joe
Executive Vice President Berkadia Commercial Mortgage LLC

Exhibit I

Berkadia Commercial Mortgage, LLC
Minimum Master Servicing Policy

CUSTODIAL BANK ACCOUNTS

Reconciliations shall be prepared on a monthly basis for all custodial bank accounts and related bank clearing accounts. These reconciliations shall:

	•		Be mathematically accurate;

	•		Be prepared within thirty (30) calendar days after the cutoff date;

	•		Be reviewed and approved by someone other than the person who prepared the reconciliation; and

	•		Document explanations for reconciling items. These reconciling items shall be resolved within ninety (90) calendar days of identification.

	2.		Funds of the servicing entity shall be advanced as specified in the servicing agreement in cases where there is an overdraft in an investor’s or a mortgagor’s account.

	3.		All cash for each custodial account shall be maintained at a federally insured depository institution in trust for the applicable investor or in an investment account in accordance with the applicable servicing agreement requirements.

	4.		Tax and insurance escrow funds held in trust for a mortgagor shall be returned to the mortgagor within thirty (30) calendar days of payoff of the mortgage loan.

II.

MORTGAGE PAYMENTS

Mortgage payments which are properly identified with the Company’s account number and which agree to the total amount of the scheduled payment due shall be deposited into the clearing bank accounts and related custodial bank accounts within two business days of receipt. Any mortgage payments which do not meet these parameters will be researched and deposited into the appropriate bank accounts within five business days of receipt.

Exhibit I

Mortgage payments made in accordance with the mortgagor’s loan documents shall be posted to the applicable mortgagor records within two business days of receipt.

III.

DISBURSEMENTS

	1.		Disbursements made via wire transfer on behalf of a mortgagor or investor shall be made only by authorized personnel.

	2.		Amounts remitted to investors per the servicer’s investor reports shall agree with cancelled checks, or other form of payment, or custodial bank statements.

IV.

INVESTOR ACCOUNTING AND REPORTING

The servicing entity’s investor reports shall agree with, or reconcile to, investors records on a monthly basis as to the total unpaid principal balance and number of loans serviced by the servicing entity.

INSURANCE POLICIES

A fidelity bond and errors and omissions policy shall be in effect on the servicing entity in the amount of coverage represented to investors in management’s assertion.

VI.

MONITORING OF SUBSERVICER COMPLIANCE

	1.		Within 120 days of calendar year end or subservicer’s year end, the subservicer’s management assertions about compliance with minimum servicing standards, which were derived from the Mortgage Banker’s Association of America’s Uniform Single Attestation Program for Mortgage Bankers, and the Independent Auditors Report on management’s assertions shall be reviewed, and if material exceptions are found, appropriate corrective action will be taken.

	2.		An annual certification from each subservicer stating that the subservicer is in compliance with its subservicing agreement shall be obtained for the previous calendar year.

Exhibit II