TEXT-S&P affirms CitiMortgage residential mortgage servicer ranking

OVERVIEW

-- We affirmed our ABOVE AVERAGE ranking on CitiMortgage Inc. as a
residential mortgage master servicer.
-- The company is proactive in adjusting its practices to meet market
conditions including monitoring its servicers' participation and compliance
with recent regulatory requirements.
-- The outlook for the ranking is stable.

NEW YORK (Standard & Poor's) Sept. 17, 2012--Standard & Poor's Ratings
Services today affirmed its ABOVE AVERAGE ranking on CitiMortgage Inc. (CMI),
a wholly owned indirect subsidiary of Citigroup Inc., as a U.S.
residential mortgage loan master servicer. The outlook on the ranking is stable.

The ranking affirmation reflects our view that CMI has an extremely
experienced staff, has experienced minimal turnover, and employs effective
internal controls within its master servicing operation. CMI continues to
maintain high servicing standards with regard to adhering to the pooling and
servicing agreements and other documents that govern the securitizations it
services.

KEY RANKING FACTORS

Strengths:
-- A seasoned and very knowledgeable management group.
-- CMI provides oversight of its servicers that are subject to consent
orders they agreed to with their regulators.
-- CMI is proactive in monitoring costs that are being passed to
securitization trusts, such as trustee expenses related to the recording of
mortgages in the Mortgage Electronic Registration System (MERS) and internal
expenses.

Weakness:
-- While CMI has enhanced its technology since our last review, other
servicers we review have more advanced tools to analyze and compile the
loan-level data they receive from their servicers.

Key changes since Standard & Poor's published its last report on CMI in June
2011.
-- Enhanced oversight of servicers, including CMI's primary servicing
operation, that are subject to compliance with consent orders they signed with
the Office of the Comptroller of the Currency (OCC).
-- CMI has enhanced its reporting; enhancements including developing
exception reports for foreclosures not in compliance.
-- CMI has expanded the frequency and thoroughness of its outside audits
of servicers.
-- CMI has enhanced its Web interface to provide investors the ability to
analyze loan performance.

As a master servicer, CMI monitors the administration of residential mortgage
loans serviced by primary loan servicers and safeguards the interests of
investors in residential mortgage-backed securities (RMBS). CMI's portfolio
continues to decrease as the securitizations it manages pay down. CMI has
established the requisite technology and infrastructure to, in our view,
efficiently compile and consolidate loan-level data directly from its
servicers and monitor the servicers' compliance with applicable regulations
and prudent loan servicing standards, as well as adherence to specific
investor requirements.

The company continues to enhance its oversight through servicer scorecards and
on-site reviews.

OUTLOOK

The outlook is stable. Standard & Poor's expects CMI to continue to serve as a
quality residential loan master servicer. As securitizations pay down,
however, CMI will be challenged to manage the size of its staff and
infrastructure.

RELATED CRITERIA AND RESEARCH

-- Revised Criteria For Including RMBS, CMBS, And ABS Servicers On
Standard & Poor's Select Servicer List, April 16, 2009
-- Servicer Evaluation Ranking Criteria: U.S., Sept. 21, 2004
-- Select Servicer List