EX-33 (p)

                      MANAGEMENT'S ASSERTION ON COMPLIANCE
                           WITH REGULATION AB CRITERIA

                                February 26, 2007

     SunTrust Bank (the "Asserting Party") is responsible for assessing
compliance with the servicing criteria set forth in Title 17, Section
229.1122(d)(2)(i), 229.1122(d)(4)(i) and 229.1122(d)(4)(ii) of the Code of
Federal Regulations (the "CFR") (the  "Applicable  Servicing  Criteria"), for
securitization transactions serviced by SunTrust Mortgage, Inc. occurring after
December 31, 2005 (the "Platform"). The Asserting Party is not assessing
compliance with any other criteria set forth in Section 229.1122(d) of the CFR.

     The Asserting Party used the applicable criteria in paragraph (d) of Title
17, Section 229.1122 of the CFR to assess compliance with the Applicable
Servicing Criteria.

     The Asserting Party has concluded that is has complied, in all material
respects, with the Applicable Servicing Criteria as of and for the twelve month
period ending December 31, 2006 (the "Reporting Period").

     PricewaterhouseCoopers LLP, an independent registered public accounting
firm, has issued an attestation report on the assessment of compliance with the
Applicable Servicing Criteria for the Reporting Period as set forth in this
assertion.


SUNTRUST BANK
Solely with respect to Sections 229.1122(d)(4)(i) and 229.1122(d)(4)(ii)


By: /s/  Rosealma T. Burton    2/26/07
----------------------------
Name:   Rosealma T. Burton
Title:   First Vice President


SUNTRUST BANK
Solely with respect to Section 229.1122(d)(2)(i)

By: /s/ Tomas E. Suarez        2/26/07
-----------------------
Name:    Tomas E. Suarez
Title:   Vice President