**Management’s Assertion on Compliance with Applicable**

**Regulation AB Servicing Criteria**

 

 

1.        Rialto Capital Advisors, LLC (“Rialto”), the Special Servicer in the agreementslisted on Exhibit 1 (the “Pooling and Servicing Agreements”), and is responsiblefor assessing compliance with the servicing criteria applicable to it underparagraph (d) of Item 1122 of Regulation AB, for the period from January 1,2018, up to and including December 31, 2018, or applicable shorter period therewithin, (the “Reporting Period”), as set forth in Appendix A hereto.  Thetransactions covered by this report include the transactions listed on Exhibit1 that are commercial mortgage-asset backed securities transactions for whichRialto acted as Special Servicer on or after January 1, 2018, or for theApplicable Certification Period as listed on Exhibit 1 (the"Platform").

 

2.        Rialto has engaged certain vendors (the “Vendors”) to perform specific,limited, or scripted activities, and Rialto elects to take responsibility forassessing compliance with the servicing criteria, or portion of the servicingcriteria, applicable to such Vendors’ activities as set forth in Appendix Ahereto. Rialto has determined its Vendors are not “servicers” as defined inItem 1101 (j) of Regulation AB and asserts that it has policies and proceduresin place to provide reasonable assurance that the Vendors’ activities comply,in all material respects, with the servicing criteria applicable to eachvendor;

 

3.        Except as set forth in paragraph 4 below, Rialto used the criteria set forth inparagraph (d) of Item 1122 of Regulation AB to assess the compliance with theapplicable servicing criteria;

 

4.        The criteria listed in the column titled “Inapplicable Servicing Criteria” onAppendix A hereto are inapplicable to Rialto based on the activities itperforms, directly or through its Vendors, with respect to the Platform;

 

5.        Rialto has complied, in all material respects, with the applicable servicingcriteria as of December 31, 2018, and for the Reporting Period with respect tothe Platform taken as a whole.

 

6.        Rialto has not identified and is not aware of any material instance ofnoncompliance by the Vendors with the applicable servicing criteria as of December31, 2018, and for the Reporting Period with respect to the Platform taken as awhole;

 

7.        Rialto has not identified any material deficiency in its policies andprocedures to monitor the compliance by the Vendors with the applicable servicingcriteria as of December 31, 2018, and for the Reporting Period with respect tothe Platform taken as a whole; and

 

8.        NDNB Assurance LLP, an independent public accounting firm, has issued anattestation report on Rialto’s assessment of compliance with the applicableservicing criteria for the Reporting Period.

 

 

Date: March 1, 2019

 

Name: Adam Singer

 

Title: Managing Director

 

 

Signature: /s/ Adam Singer

 

 

**Exhibit 1**

 

 

| **Pooling and Servicing Agreements**                                                                                                                                                                                                                | **Applicable Certification Period**      |
|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------|
| WFRBS 2012-C8                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| WFCM 2012-LC5                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| UBS-Barclays 2012-C3                                                                                                                                                                                                                                | January 1, 2018 to December  31, 2018    |
| UBS-Barclays 2012-C4                                                                                                                                                                                                                                | January 1, 2018 to December  31, 2018    |
| GSMS 2012-GCJ9                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| JPMCC 2012-LC9                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| COMM 2013-LC6                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| WFRBS 2013-C12                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| UBS-Barclays 2013-C6                                                                                                                                                                                                                                | January 1, 2018 to December  31, 2018    |
| GSMS 2013-GCJ12                                                                                                                                                                                                                                     | January 1, 2018 to December  31, 2018    |
| WFRBS 2013-C14                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| WFRBS 2011-C5                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| WFCM 2013-LC12                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| WFRBS 2011-C2                                                                                                                                                                                                                                       | January 1, 2018 to December 31,  2018    |
| WFRBS 2011-C3                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| WFRBS 2011-C4                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| UBS-Citigroup 2011-C1                                                                                                                                                                                                                               | January 1, 2018 to December  31, 2018    |
| UBS 2012-C1                                                                                                                                                                                                                                         | January 1, 2018 to December  31, 2018    |
| WFRBS 2012-C6                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| GSMS 2011-GC3                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| COMM 2013-LC13                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| WFRBS 2013-C16                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| GSMS 2013-GCJ16                                                                                                                                                                                                                                     | January 1, 2018 to December  31, 2018    |
| WFRBS 2013-C17                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| GSMS 2012-GC6                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| MSBAM 2013-C13                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| COMM 2014-CCRE14                                                                                                                                                                                                                                    | January 1, 2018 to December  31, 2018    |
| MSBAM 2014-C14                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| WFRBS 2014-LC14                                                                                                                                                                                                                                     | January 1, 2018 to December  31, 2018    |
| COMM 2014-LC15                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| WFRBS 2014-C20                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| COMM 2014-CCRE18                                                                                                                                                                                                                                    | January 1, 2018 to December  31, 2018    |
| CGCMT 2014-GC23                                                                                                                                                                                                                                     | January 1, 2018 to December 31,  2018    |
| MSBAM 2014-C17                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| COMM 2014-UBS5                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| MSBAM 2014-C18                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| COMM 2012-CCRE4                                                                                                                                                                                                                                     | January 1, 2018 to December  31, 2018    |
| COMM 2012-LC4                                                                                                                                                                                                                                       | January 1, 2018 to May 31,  2018         |
| WFRBS 2014-C24                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| JPMBB 2014-C25                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| LCCM 2014-909                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| WFCM 2014-LC18                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| COMM 2015-DC1                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| GSMS 2015-GC28                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| WFCM 2015-C27                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| WFCM 2015-LC20                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| WFCM 2015-NXS1                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| CSAIL 2015-C2                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| WFCM 2015-NXS2                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| COMM 2015-PC1                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| CSAIL 2015-C3                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| WFCM 2015-SG1                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| WFCM 2015-LC22                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| COMM 2015-CCRE27                                                                                                                                                                                                                                    | January 1, 2018 to December  31, 2018    |
| WFCM 2015-NXS4                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| MSCI 2015-UBS8                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| CSAIL 2016-C5                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| WFCM 2016-C32                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| WFCM 2016-NXS5                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| CGCMT 2015-GC27 (Special  Servicer solely for the Boca Hamptons Plaza Portfolio Loan prior to July 5,  2018 and named Special Servicer under the applicable Pooling and Servicing  Agreement from and after July 5, 2018 through December 31, 2018) | January 1, 2018 to December  31, 2018    |
| WFCM 2016-C33                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| MSBAM 2016-C29                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| CFCRE 2016-C4                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| GSMS 2016-GS2 (Special  Servicer solely for the Veritas Multifamily Pool 2 only)                                                                                                                                                                    | January 1, 2018 to December  31, 2018    |
| BACM 2016-UBS10                                                                                                                                                                                                                                     | January 1, 2018 to December  31, 2018    |
| SGCMS 2016-C5                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| WFCM 2016-BNK1                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| CD 2016-CD1                                                                                                                                                                                                                                         | January 1, 2018 to December  31, 2018    |
| GSMS 2016-GS3                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| MSBAM 2016-C31                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| CGCMT 2016-C3                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| CFCRE 2016-C6                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| CSAIL 2016-C7                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| MSCI 2016-UBS12                                                                                                                                                                                                                                     | January 1, 2018 to December  31, 2018    |
| BBCMS 2017-C1                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| GSMS 2017-GS5                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| CGCMT 2017-P7                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| BANK 2017-BNK4                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| CD 2017-CD4                                                                                                                                                                                                                                         | January 1, 2018 to December  31, 2018    |
| CFCRE 2017-C8                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| JPMCC 2017-JP6                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| CD 2017-CD5                                                                                                                                                                                                                                         | January 1, 2018 to December  31, 2018    |
| GSMS 2017-GS7                                                                                                                                                                                                                                       | January 1, 2018 to December  31, 2018    |
| BANK 2017-BNK7                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| CSAIL 2017-CX9                                                                                                                                                                                                                                      | January 1, 2018 to December 31,  2018    |
| UBS 2017-C4                                                                                                                                                                                                                                         | January 1, 2018 to December  31, 2018    |
| UBS 2017-C6                                                                                                                                                                                                                                         | January 1, 2018 to December  31, 2018    |
| BANK 2017-BNK9                                                                                                                                                                                                                                      | January 1, 2018 to December  31, 2018    |
| GSMS 2018-GS9                                                                                                                                                                                                                                       | March 29, 2018 to December  31, 2018     |
| UBS 2018-C9                                                                                                                                                                                                                                         | March 29, 2018 to December  31, 2018     |
| MSCI 2012-C5                                                                                                                                                                                                                                        | April 13, 2018 to December  31, 2018     |
| WFCM 2018-C44                                                                                                                                                                                                                                       | May 17, 2018 to December 31,  2018       |
| UBS 2018-C10                                                                                                                                                                                                                                        | May 31, 2018 to December 31,  2018       |
| WFCM 2015-C30                                                                                                                                                                                                                                       | July 5, 2018 to December 31,  2018       |
| JPMBB 2014-C23                                                                                                                                                                                                                                      | July 5, 2018 to December 31,  2018       |
| MSBAM 2014-C19                                                                                                                                                                                                                                      | July 5, 2018 to December 31,  2018       |
| COMM 2015-LC21                                                                                                                                                                                                                                      | July 5, 2018 to December 31,  2018       |
| MSBAM 2015-C20                                                                                                                                                                                                                                      | July 5, 2018 to December 31,  2018       |
| JPMBB 2015-C31                                                                                                                                                                                                                                      | July 5, 2018 to December 31,  2018       |
| GSMS 2018-GS10                                                                                                                                                                                                                                      | July 30, 2018 to December  31, 2018      |
| CD 2018-CD7                                                                                                                                                                                                                                         | August 24, 2018 to December  31, 2018    |
| GSMS 2018-3PCK                                                                                                                                                                                                                                      | September 27, 2018 to  December 31, 2018 |
| BANK 2018-BNK14                                                                                                                                                                                                                                     | September 27, 2018 to  December 31, 2018 |
| DBGS 2018-C1                                                                                                                                                                                                                                        | October 30, 2018 to December  31, 2018   |
| CSAIL 2018-C14                                                                                                                                                                                                                                      | November 29, 2018 to December  31, 2018  |
| UBS 2018-C14                                                                                                                                                                                                                                        | December 12, 2018 to  December 31, 2018  |

 

 

APPENDIX A

 

| **SERVICING CRITERIA** |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
|------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| **Reference**          | **Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | **Performed by Servicer** | **Inapplicable    Servicing Criteria** |
| ** **             | **General Servicing  Considerations**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | ** ** | ** ** |
| 1122(d)(1)(i)          | Policies and procedures are  instituted to monitor any performance or other triggers and events of default  in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | **X** |   |
| 1122(d)(1)(ii)         | If any material servicing  activities are outsourced to third parties, policies and procedures are  instituted to monitor the third party’s performance and compliance with such  servicing activities.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | ** **

**X** |   |
| 1122(d)(1)(iii)        | Any requirements in the  transaction agreements to maintain a back-up servicer for the [pool assets]  are maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |   | **X** |
| 1122(d)(1)(iv)         | A fidelity bond and errors  and 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.                                                                                                                                                                                                                                                                                                                                                                                                                                          | ** **

**X** |   |
| 1122(d)(i)(v)          | Aggregation of information,  as applicable, is mathematically accurate and the information conveyed  accurately reflects the information.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     | ** **

**X** |   |
| ** **             | **Cash Collection and  Administration**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |   |   |
| 1122(d)(2)(i)          | Payments on [pool assets]  are deposited 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                            | **X1** |   |
| 1122(d)(2)(ii)         | Disbursements made via wire  transfer on behalf of an obligor or to an investor are made only by  authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | **X** |   |
| 1122(d)(2)(iii)        | Advances of funds or  guarantees 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | **X** |   |
| 1122(d)(2)(iv)         | The related accounts for the  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.                                                                                                                                                                                                                                                                                                                                                                                                                                                      | **X** |   |
| 1122(d)(2)(v)          | Each custodial account is  maintained at 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.                                                                                                                                                                                                                                                                                                              | **X** |   |
| 1122(d)(2)(vi)         | Unissued checks are  safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | **X** |   |
| 1122(d)(2)(vii)        | Reconciliations are prepared  on a 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. | ** **

** **

** **

** **

** **

**X** |   |
| ** **             | **Investor Remittances and  Reporting**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |   |   |
| 1122(d)(3)(i)          | Reports to investors,  including those 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 investors’ or the trustee’s records as to the  total unpaid principal balance and number of [pool assets] serviced by the  Servicer.                                | **X2** |   |
| 1122(d)(3)(ii)         | Amounts due to investors are  allocated and remitted in accordance with timeframes, distribution priority  and other terms set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |   | **X** |
| 1122(d)(3)(iii)        | Disbursements made to an investor  are posted within two business days to the Servicer’s investor records, or  such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |   | **X** |
| 1122(d)(3)(iv)         | Amounts remitted to  investors per the investor reports agree with cancelled checks, or other form  of payment, or custodial bank statements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |   | **X** |
| ** **             | **Pool Asset Administration**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |   |   |
| 1122(d)(4)(i)          | Collateral or security on  [pool assets] is maintained as required by the transaction agreements or  related mortgage loan documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | **X** |   |
| 1122(d)(4)(ii)         | [pool asset] and related  documents are safeguarded as required by the transaction agreements                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | **X** |   |
| 1122(d)(4)(iii)        | Any additions, removals or  substitutions to the asset pool are made, reviewed and approved in accordance  with any conditions or requirements in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | **X** |   |
| 1122(d)(4)(iv)         | Payments on [pool assets],  including any payoffs, made in accordance with the related [pool asset] 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 [pool asset] documents.                                                                                                                                                                                                                                                                                 |   | **X3** |
| 1122(d)(4)(v)          | The Servicer’s records  regarding the [pool assets] agree with the Servicer’s records with respect to  an obligor’s unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |   | **X** |
| 1122(d)(4)(vi)         | Changes with respect to the terms  or status of an obligor's [pool assets] (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.                                                                                                                                                                                                                                                                                                                                                                                                                                                  | **X** |   |
| 1122(d)(4)(vii)        | Loss mitigation or recovery  actions (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.                                                                                                                                                                                                                                                                                                                                                                                                    | ** **

** **

**X** |   |
| 1122(d)(4)(viii)       | Records documenting  collection efforts are maintained during the period a [pool asset] 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 [pool assets] including, for example, phone calls, letters and  payment rescheduling plans in cases where delinquency is deemed temporary  (e.g., illness or unemployment).                                                                                                                                                                               | ** **

** **

** **

** **

**X** |   |
| 1122(d)(4)(ix)         | Adjustments to interest  rates or rates of return for [pool assets] with variable rates are computed  based on the related [pool asset] documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |   | **X** |
| 1122(d)(4)(x)          | Regarding any funds held in  trust for an obligor (such as escrow accounts): (A) such funds are analyzed,  in accordance with the obligor’s [pool asset] 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 [pool asset] documents and state laws; and (C) such funds are  returned to the obligor within 30 calendar days of full repayment of the  related [pool assets], or such other number of days specified in the  transaction agreements.                                                                                                     |   | **X** |
| 1122(d)(4)(xi)         | Payments made on behalf of  an obligor (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.                                                                                                                                                                                                                                                                                                          |   | **X** |
| 1122(d)(4)(xii)        | Any late payment penalties  in 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                            |   | **X** |
| 1122(d)(4)(xiii)       | Disbursements made on behalf  of an 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |   | **X** |
| 1122(d)(4)(xiv)        | Delinquencies, charge-offs  and uncollectible accounts are recognized and recorded in accordance with the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |   | **X4** |
| 1122(d)(4)(xv)         | Any external enhancement or  other support, identified in Item 1114(a)(1) through (3) or Item 1115 of  Regulation AB, is maintained as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |   | **X** |

 

 

1)      Rialto Capital Advisors, LLC performs theactivities pertaining to these criteria, except for specific, limitedactivities performed by its third party property managers relating to REOProperty, if any.  Rialto has elected to take responsibility for assessingcompliance with these servicing criteria with respect to the activities of itsthird party property managers. 

 

2)      Only items (A) and (B) of the ServicingCriteria are applicable to Rialto Capital Advisors, LLC as specialservicer.  Items (C) and (D) are inapplicable as the responsibility forfiling reports with the Commission and agreeing totals to the Servicer recordsrests with the Trustee and/or Certificate Administrator, as applicable. 

 

3)      Primary responsibility for processingborrower payments rests with the Master Servicer, however, Rialto CapitalAdvisors, LLC may from time to time receive payments on an exception basiswhich are forwarded to the Master Servicer in accordance with such criterion.

 

4)      Rialto Capital Advisors, LLC provides theapplicable Master Servicer relating to each deal with the final recoverydetermination and data utilized to complete IRS Form 1099C on loans withcharge-offs, however, the ultimate responsibility for adjusting the loanrecord,  reporting to the IRS, and delivering 1099C Forms to the borrowerrests with the Master Servicer.