OVERVIEW -- We affirmed our overall STRONG ranking on BofA Merrill Lynch Global Markets Commercial Real Estate Servicing as a commercial loan primary and master servicer. The outlook is stable. -- We affirmed our overall ABOVE AVERAGE ranking on BofA Merrill Lynch Global Markets Commercial Real Estate Servicing as a commercial loan special servicer. The outlook is stable. -- We based our opinion on the company's well defined, efficient operations and procedures, highly effective leverage of loan servicing systems and strong audit, compliance and quality control environment. NEW YORK (Standard & Poor's) Dec. 17, 2012--Standard & Poor's Ratings Services today affirmed its STRONG ranking on BofA Merrill Lynch Global Markets Commercial Real Estate Servicing (CRES) as a commercial loan primary and master servicer. We also affirmed our ABOVE AVERAGE ranking as commercial loan special servicer. The outlook is stable for all three rankings. The financial position is Sufficient. BofA Merrill Lynch is one of the world's largest financial services companies with clients in more than 150 countries and provides services ranging from investment and corporate banking to investing and equity execution services. The bank is a major originator and servicer of commercial and multifamily mortgages, including large-loan, single-borrower, and CMBS transactions, which include fixed-rate conduit lending. As of June 30, 2012, CRES had total assets under management of approximately $110 billion and employed approximately 90 professionals. Its primary, master and special servicing operations are headquartered in Charlotte, N.C. The affirmed rankings reflect, in our opinion, the company's ongoing commitment to operational enhancements, proactive portfolio surveillance, experienced management team, and effective systems and technology. The company continues to improve processes and procedures in all areas of the organization, which, in our view, resulted in greater operating efficiencies. KEY RANKING FACTORS Strengths: -- Well defined, efficient operations and procedures; -- Highly effective leverage of loan servicing systems; and -- Strong audit, compliance, and quality control environment; Weakness: -- No formal vendor performance review process for appraiser, property managers and brokers. As of June 30, 2012, the company primary serviced a portfolio of approximately 9,497 loans and 13,084 collateral properties constituting a total unpaid principal balance of approximately $99.7 billion. The portfolio is geographically dispersed and contains all major collateral property types. CRES services loans for a diverse mix of investor types including CMBS, investment funds, life insurance company mortgages, financial institutions and Fannie Mae. Loan volume has decreased modestly over the past four and a half years mainly as due to lower CMBS issuance. As of the same date, CRES was the master servicer for more than18 third-party subservicers and the portfolio totaled $10.5 billion with 1,436 loans. New master servicing volume has decreased in recent years; however, CRES maintains the resources and procedures to accommodate new transactions. Also as of June 30, 2012, the company managed a special servicing portfolio of 416 properties totaling $4 billion as well as three real estate owned (REO) assets totaling $4.5 million. CRES is the named special servicer on 13 CMBS transactions with 64 loans totaling $13.7 billion. Overall the special servicing portfolio is predominately comprised of CMBS assets with a smaller portion of loans managed for banks and other third-party investors. The portfolio includes complex loan structures and most collateral property types located throughout the country. Since 2003, the group has resolved approximately $28 billion in problem loans. OUTLOOK Our outlook on all three servicer rankings is stable. CRES has a successful track record servicing commercial and multifamily mortgage loans. The company has demonstrated its commitment to invest in technology resources and continuous process improvement.