Trimont Real EstateAdvisors, LLC

 

Management’sCertification Regarding Compliancewith Applicable Servicing Criteria

 

 

TrimontReal Estate Advisors, LLC (the “Asserting Party”) is responsible for assessing complianceas of and for the year ended December 31, 2018 (the “Reporting Period”) withthe applicable servicing criteria set forth in Item 1122(d) of the Securitiesand Exchange Commission’s Regulation AB as set forth in Exhibit A hereto (the“Applicable Servicing Criteria”). The transactions covered by this report areonly those transactions processed by the Asserting Party in its capacity astrust, senior trust, or operating advisor for the asset backed securitiestransactions listed in Exhibit B hereto (the “Platform”).

 

TheAsserting Party has used the servicing criteria set forth in Item 1122(d) ofthe Securities and Exchange Commission’s Regulation AB to assess its compliancewith the Applicable Servicing Criteria for the Reporting Period and has concludedthat the Asserting Party has complied, in all material respects, with theApplicable Servicing Criteria as of and for the year ended December 31, 2018with respect to the Platform.

 

GrantThornton LLP, an independent registered public accounting firm, has issued anattestation report on the assessment of compliance with the ApplicableServicing Criteria as of and for the year ended December 31, 2018 as set forthin this assertion.

 

 

TrimontReal Estate Advisors, LLC 

February26, 2019

 

 

/s/Glen Peters

GlenPeters

ChiefFinancial Officer

 

 

| **Exhibit   A**

** **         |
|-------------------------------------|
| **Regulation   AB Criteria**        | **GSMS   2015-GC30** | **WFCM   2015-C27** | **WFCM   2015-C29** | **WFCM   2015-C31** | **WFCM   2015-LC20** | **WFCM   2015-NXS1** | **WFCM   2015-SG1** | **WFRBS   2014-C25** | **WFRBS   2014-C23** | **WFRBS   2014-C21** | **GSMS   2014-GC20** | **WFRBS   2014-C19** | **WFRBS   2013-C17** | **MSBAM   2013-C12** | **WFRBS   2013-C15** | **GSMS   2013-GC13** | **WFRBS   2013-C13** | **MSBAM   2013-C9**

** ** | **WFRBS   2013-C11** | **GSMS   2013-GC10** | **UBS   2012-C4** | **WFCM   2012-LC5** |
| ***Section***                       | ***Description*** | ***Criteria*** | ***Applicable   Criteria*** |
| General Servicing  Considerations   |
| 1122(d)(1)(i)                       | Policies and  Procedures | Policies and  procedures are instituted to monitor any performance or other triggers and  events of default in accordance with the transaction agreement. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(1)(ii)                      | Policies and  Procedures (vendors) | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(1)(iii)                     | Back-up Servicer | Any requirements in  the transaction agreements to maintain a back-up servicer for the pool assets  are maintained. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(1)(iv)                      | Fidelity Bond | 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  agreement. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(1)(v)                       | Accuracy of  Information | Aggregation of  information, as applicable, is mathematically accurate and the information  conveyed accurately reflects the information. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| Cash Collection  and Administration |
| 1122(d)(2)(i)                       | 2 Days to deposit  Payments into Custodial Accounts | Payments on pool assets  are deposited into the appropriate custodial bank accounts and related bank  clearing accounts no more than two business days of receipt, or such other  number of days specified in the transaction agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(2)(ii)                      | Wire Transfers | Disbursements  made via wire transfer on behalf of an obligor or to an investor are made  only by authorized personnel | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(2)(iii)                     | Advances | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(2)(iv)                      | Commingling | The related  accounts for the transaction, such as cash reserve accounts or accounts established  as a form of over collateralization, are separately maintained (e.g., with  respect to commingling of cash) as set forth in the transaction agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(2)(v)                       | Federally Insured  Institution | 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 §240.13k-1(b)(1) of this chapter.  I.3 Each custodial  account shall be maintained at a federally insured depository institution in  trust for the applicable investor. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(2)(vi)                      | Unissued Checks | Unissued checks  are safeguarded so as to prevent unauthorized access. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(2)(vii)                     | Reconciliations | 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:  (a) are mathematically accurate;  (b) are prepared within 30 calendar days after the bank statement cutoff  date, or such other number of days specified in the transaction agreements;  (c) are 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| Investor  Remittance and Reporting  |
| 1122(d)(3)(i)                       | Reports to the  Investor | 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. | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 |
| 1122(d)(3)(ii)                      | Investor  Remittance | Amounts due to investors  are allocated and remitted in accordance with timeframes, distribution  priority and other terms set forth in the transaction agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(3)(iii)                     | Investor’s  Records | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(3)(iv)                      | Remittance and  Bank Statements | Amounts remitted  to investors per the investor reports agree with cancelled checks, or other  form of payment, or custodial bank statements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| Pool Asset  Administration          |
| 1122(d)(4)(i)                       | Collateral/  Security on Pool Assets | Collateral or  security on pool assets is maintained as required by the transaction agreements  or related pool asset documents. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(ii)                      | Safeguard Pool  Assets | Pool assets and related  documents are safeguarded as required by the transaction agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(iii)                     | Changes to the  Pool Assets | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(iv)                      | Obligor’s Payment  Record | Payments on pool  assets, including any payoffs, made in accordance with the related pool asset  documents are posted to the applicable 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(v)                       | Pool Asset  Records Match UPB | The servicer’s  records regarding the pool assets agree with the servicer’s records with  respect to an obligor’s unpaid principal balance. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
|  1122(d)(4)(vi)                | Loan  Modifications | Changes with  respect to the terms or status of an obligor’s pool asset (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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(vii)                     | Loss Mitigation  Actions | 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 agreement. | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 |
| 1122(d)(4)(viii)                    | Collection  Efforts Documented | 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) | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(ix)                      | ARMs | Adjustments to  interest rates or rates of return for pool assets with variable rates are  computed based on the related pool asset documents. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(x)                       | Escrow Funds | Regarding any  funds held in trust for an obligor such funds are (a) 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)returned to the obligor within 30  calendar days of full repayment of the related pool asset, or such other  number of days specified in the transaction agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(xi)                      | Timely Payments | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(xii)                     | Late Payment  Penalties | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(xiii)                    | Obligor’s Records | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(xiv)                     | Delinquencies,  Charge-offs, and Other Uncollectible Accounts | Delinquencies, Charge-offs,  and uncollectible accounts are recognized and recorded in accordance with the  transaction agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(xv)                      | Any External  Enhancement | Any external  enhancement or other support, identified in Item 1114(a)(1) through (3) or  Item 1115 of this Regulation AB, is maintained as set forth in the  transaction agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |

 

 

| **Exhibit   A**

** **         |
|-------------------------------------|
| **Regulation   AB Criteria**        | **WFRBS   2012-C9** | **DBUBS   2011-LC3** | **WFRBS   2011-C5** | **WFCM   2016-NXS6** | **WFCM   2016-LC24** | **WFCM   2016-C37** | **245   Park Ave Trust 2017-245P** | **MSC   2017-H1** | **WFCM   2017-C39** | **WFCM   2017-RB1** | **WFCM   2017-C41** | **CFCRE   2011-C2** | **MSC   2011-C3** | **UBS   CCMT 2011-C1** | **JPMCC   2012 CIBX** | **UBS   2012-C1** | **WFRBS   2014-LC14** | **CGCMT   2014-GC23** | **CGCMT   2016-C3** | **CGCMT   2017-B1** | **GSMS   2012-GC6** | **WFRBS   2012-C7** |
| ***Section***                       | ***Description*** | ***Criteria*** | ***Applicable   Criteria*** |
| General Servicing  Considerations   |
| 1122(d)(1)(i)                       | Policies and  Procedures | Policies and  procedures are instituted to monitor any performance or other triggers and  events of default in accordance with the transaction agreement. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(1)(ii)                      | Policies and  Procedures (vendors) | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(1)(iii)                     | Back-up Servicer | Any requirements in  the transaction agreements to maintain a back-up servicer for the pool assets  are maintained. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(1)(iv)                      | Fidelity Bond | 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  agreement. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(1)(v)                       | Accuracy of  Information | Aggregation of  information, as applicable, is mathematically accurate and the information  conveyed accurately reflects the information. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| Cash Collection  and Administration |
| 1122(d)(2)(i)                       | 2 Days to deposit  Payments into Custodial Accounts | Payments on pool assets  are deposited into the appropriate custodial bank accounts and related bank  clearing accounts no more than two business days of receipt, or such other  number of days specified in the transaction agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(2)(ii)                      | Wire Transfers | Disbursements  made via wire transfer on behalf of an obligor or to an investor are made  only by authorized personnel | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(2)(iii)                     | Advances | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(2)(iv)                      | Commingling | The related  accounts for the transaction, such as cash reserve accounts or accounts established  as a form of over collateralization, are separately maintained (e.g., with  respect to commingling of cash) as set forth in the transaction agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(2)(v)                       | Federally Insured  Institution | 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 §240.13k-1(b)(1) of this chapter.  I.3 Each custodial  account shall be maintained at a federally insured depository institution in  trust for the applicable investor. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(2)(vi)                      | Unissued Checks | Unissued checks  are safeguarded so as to prevent unauthorized access. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(2)(vii)                     | Reconciliations | 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:  (a) are mathematically accurate;  (b) are prepared within 30 calendar days after the bank statement cutoff  date, or such other number of days specified in the transaction agreements;  (c) are 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| Investor  Remittance and Reporting  |
| 1122(d)(3)(i)                       | Reports to the  Investor | 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. | X1 | X4 | X3 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X3 | X4 | X3 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 |
| 1122(d)(3)(ii)                      | Investor  Remittance | Amounts due to investors  are allocated and remitted in accordance with timeframes, distribution  priority and other terms set forth in the transaction agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(3)(iii)                     | Investor’s  Records | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(3)(iv)                      | Remittance and  Bank Statements | Amounts remitted  to investors per the investor reports agree with cancelled checks, or other  form of payment, or custodial bank statements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| Pool Asset  Administration          |
| 1122(d)(4)(i)                       | Collateral/  Security on Pool Assets | Collateral or  security on pool assets is maintained as required by the transaction agreements  or related pool asset documents. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(ii)                      | Safeguard Pool  Assets | Pool assets and related  documents are safeguarded as required by the transaction agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(iii)                     | Changes to the  Pool Assets | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(iv)                      | Obligor’s Payment  Record | Payments on pool  assets, including any payoffs, made in accordance with the related pool asset  documents are posted to the applicable 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(v)                       | Pool Asset  Records Match UPB | The servicer’s  records regarding the pool assets agree with the servicer’s records with  respect to an obligor’s unpaid principal balance. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
|  1122(d)(4)(vi)                | Loan  Modifications | Changes with  respect to the terms or status of an obligor’s pool asset (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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(vii)                     | Loss Mitigation  Actions | 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 agreement. | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 |
| 1122(d)(4)(viii)                    | Collection  Efforts Documented | 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) | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(ix)                      | ARMs | Adjustments to  interest rates or rates of return for pool assets with variable rates are  computed based on the related pool asset documents. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(x)                       | Escrow Funds | Regarding any  funds held in trust for an obligor such funds are (a) 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)returned to the obligor within 30  calendar days of full repayment of the related pool asset, or such other  number of days specified in the transaction agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(xi)                      | Timely Payments | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(xii)                     | Late Payment  Penalties | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(xiii)                    | Obligor’s Records | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(xiv)                     | Delinquencies,  Charge-offs, and Other Uncollectible Accounts | Delinquencies, Charge-offs,  and uncollectible accounts are recognized and recorded in accordance with the  transaction agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(xv)                      | Any External  Enhancement | Any external  enhancement or other support, identified in Item 1114(a)(1) through (3) or  Item 1115 of this Regulation AB, is maintained as set forth in the  transaction agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |

 

 

**Key**

** **

| X1                                                                                                                                                                                                                   | With  respect to Item 1122(d)(3)(i), only parts A and B of this criteria are  applicable for the securitization.                                                                                           |
|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| X2                                                                                                                                                                                                                   | With  respect to Item 1122(d)(4)(vii), there were no loss mitigation or recovery  actions during the reporting period for the loan(s) that were serviced under  this securitization.                       |
| X3                                                                                                                                                                                                                   | With  respect to Item 1122(d)(3)(i), only parts A, B, and C are applicable. There  were no activities performed during the reporting period for the loan(s) that  were serviced under this securitization. |
| X4                                                                                                                                                                                                                   | With  respect to Item 1122(d)(3)(i), there were no activities performed during the  reporting period for the loan(s) that were serviced under this  securitization.                                        |
| With  respect to Applicable Servicing Criteria cells in Exhibit A that are denoted  with an “N/A”, per review of the respective servicing agreement, the criteria  was not in scope for the transaction. |

 

 

 

| **Exhibit   B**                     |
|-------------------------------------|
| **Name**                            | **Transaction** | **Period of   Service** |
| DBUBS 2011‐LC3                | Commercial Mortgage Pass‐Through  Certificates, DBUBS 2011‐LC3 pursuant to  the Pooling and Servicing Agreement dated August 1, 2011 | January 1, 2018 ‐

December  31, 2018 |
| WFRBS 2011‐C5                 | Commercial Mortgage Pass‐Through  Certificates, WFRBS 2011‐C5 pursuant to  the Pooling and Servicing Agreement dated November 1, 2011 | January 1, 2018 ‐

December  31, 2018 |
| MSC 2011‐C3                   | Commercial Mortgage Pass‐Through  Certificates, MSC 2011‐C3 pursuant to  the Pooling and Servicing Agreement dated October 1, 2011 | January 1, 2018 ‐

December  31, 2018 |
| CFCRE 2011‐C2                 | Commercial Mortgage Pass‐Through  Certificates, CFCRE 2011‐C2 pursuant to  the Pooling and Servicing Agreement dated December 11, 2011 | January 1, 2018 ‐

December  31, 2018 |
| UBS CCMT‐2011-C1              | Commercial Mortgage Pass‐Through  Certificates, UBS CCMT‐2011 pursuant to  the Pooling and Servicing Agreement dated December 1, 2011 | January 1, 2018 ‐

December  31, 2018 |
| GSMS 2012‐GC6                 | Commercial Mortgage Pass‐Through Certificates,  Series 2012‐GC6 pursuant to  the Pooling and Servicing Agreement dated February 1, 2012 | January 1, 2018 ‐

December  31, 2018 |
| UBS 2012‐C1                   | Commercial Mortgage Pass‐Through  Certificates, Series 2012‐C1  pursuant to the Pooling and Servicing Agreement dated May 1, 2012 | January 1, 2018 ‐

December  31, 2018 |
| JPMCC 2012 ‐ CIBX             | Commercial Mortgage Pass‐Through  Certificates, Series 2012‐CIBX  pursuant to the Pooling and Servicing Agreement dated June 1, 2012 | January 1, 2018 ‐

December  31, 2018 |
| WFRBS 2012‐C7                 | Commercial Mortgage Pass‐Through  Certificates, Series 2012‐C7  pursuant to the Pooling and Servicing Agreement dated June 1, 2012 | January 1, 2018 ‐

December  31, 2018 |
| WFCM 2012‐LC5                 | Commercial Mortgage Pass‐Through  Certificates, Series 2012‐LC5  pursuant to the Pooling and Servicing Agreement dated September 1, 2012 | January 1, 2018 ‐

December  31, 2018 |
| WFRBS 2012‐C9                 | Commercial Mortgage Pass‐Through  Certificates, Series 2012‐C9  pursuant to the Pooling and Servicing Agreement dated October 1, 2012 | January 1, 2018 ‐

December  31, 2018 |
| UBS 2012‐C4                   | Commercial Mortgage Pass‐Through  Certificates, Series 2012‐C4  pursuant to the Pooling and Servicing Agreement dated December 1, 2012 | January 1, 2018 ‐

December  31, 2018 |
| GSMS 2013‐GC10                | Commercial Mortgage Pass‐Through  Certificates, Series 2013‐GC10  pursuant to the Pooling and Servicing Agreement dated February 1, 2013 | January 1, 2018 ‐

December  31, 2018 |
| WFRBS 2013‐C11                | Commercial Mortgage Pass‐Through  Certificates, Series 2013‐C11  pursuant to the Pooling and Servicing Agreement dated February 1, 2013 | January 1, 2018 ‐

December  31, 2018 |
| MSBAM 2013‐C9                 | Commercial Mortgage Pass‐Through  Certificates, Series 2013‐C9  pursuant to the Pooling and Servicing Agreement dated May 1, 2013 | January 1, 2018 ‐

December  31, 2018 |
| WFRBS 2013‐C13                | Commercial Mortgage Pass‐Through  Certificates, Series 2013‐C13  pursuant to the Pooling and Servicing Agreement dated May 1, 2013 | January 1, 2018 ‐

December  31, 2018 |
| GSMS 2013‐GC13                | Commercial Mortgage Pass‐Through Certificates,  Series 2013‐GC13 pursuant to  the Pooling and Servicing Agreement dated July 1, 2013 | January 1, 2018 ‐

December  31, 2018 |
| WFRBS 2013‐C15                | Commercial Mortgage Pass‐Through  Certificates, Series 2013‐C15  pursuant to the Pooling and Servicing Agreement dated August 1, 2013 | January 1, 2018 ‐

December  31, 2018 |
| MSBAM  2013‐C12               | Commercial Mortgage Pass‐Through  Certificates, Series 2013‐C12  pursuant to the Pooling and Servicing Agreement dated October 1, 2013 | January 1, 2018 ‐

December  31, 2018 |
| WFRBS 2013‐C17                | Commercial Mortgage Pass‐Through  Certificates, Series 2013‐C17  pursuant to the Pooling and Servicing Agreement dated August 1, 2013 | January 1, 2018 ‐

December  31, 2018 |
| WFRBS 2014‐LC14               | Commercial Mortgage Pass‐Through  Certificates, Series 2014‐LC14  pursuant to the Pooling and Servicing Agreement dated February 1, 2014 | January 1, 2018 ‐

December  31, 2018 |
| WFRBS  2014‐C19               | Commercial Mortgage Pass‐Through  Certificates, Series 2014‐C19  pursuant to the Pooling and Servicing Agreement dated February 26, 2014 | January 1, 2018 ‐

December  31, 2018 |
| GSMS 2014‐GC20                | Commercial Mortgage Pass‐Through  Certificates, Series 2014‐GC20  pursuant to the Pooling and Servicing Agreement dated April 1, 2014 | January 1, 2018 ‐

December  31, 2018 |
| WFRBS 2014‐C21                | Commercial Mortgage Pass‐Through  Certificates, Series 2014‐C21  pursuant to the Pooling and Servicing Agreement dated August 1, 2014 | January 1, 2018 ‐

December  31, 2018 |
| CGCMT  2014‐GC23              | Commercial Mortgage Pass‐Through  Certificates, Series 2014‐GC23  pursuant to the Pooling and Servicing Agreement dated August 1, 2014 | January 1, 2018 ‐

December  31, 2018 |
| WFRBS 2014‐C23                | Commercial Mortgage Pass‐Through  Certificates, Series 2014‐C23  pursuant to the Pooling and Servicing Agreement dated September 1, 2014 | January 1, 2018 ‐

December  31, 2018 |
| WFRBS 2014‐C25                | Commercial Mortgage Pass‐Through  Certificates, Series 2014‐C25  pursuant to the Pooling and Servicing Agreement dated December 1, 2014 | January 1, 2018 ‐

December  31, 2018 |
| GSMS  2015‐GC30               | Commercial Mortgage Pass‐Through  Certificates, Series 2015‐GC30  pursuant to the Pooling and Servicing Agreement dated May 1, 2015 | January 1, 2018 ‐

December  31, 2018 |
| WFCM 2015‐C27                 | Commercial Mortgage Pass‐Through Certificates,  Series 2015‐C27 pursuant to  the Pooling and Servicing Agreement dated March 1, 2015 | January 1, 2018 ‐

December  31, 2018 |
| WFCM 2015‐C29                 | Commercial Mortgage Pass‐Through  Certificates, Series 2015‐C29  pursuant to the Pooling and Servicing Agreement dated June 1, 2015 | January 1, 2018 ‐

December  31, 2018 |
| WFCM  2015‐C31                | Commercial Mortgage Pass‐Through  Certificates, Series 2015‐C31  pursuant to the Pooling and Servicing Agreement dated November 1, 2015 | January 1, 2018 ‐

December  31, 2018 |
| WFCM 2015‐LC20                | Commercial Mortgage Pass‐Through  Certificates, Series 2015‐LC20  pursuant to the Pooling and Servicing Agreement dated March 1, 2015 | January 1, 2018 ‐

December  31, 2018 |
| WFCM 2015‐NXS1                | Commercial Mortgage Pass‐Through  Certificates, Series 2015‐NXS1  pursuant to the Pooling and Servicing Agreement dated April 1, 2015 | January 1, 2018 ‐

December  31, 2018 |
| WFCM 2015‐SG1                 | Commercial Mortgage Pass‐Through  Certificates, Series 2015‐SG1  pursuant to the Pooling and Servicing Agreement dated August 1, 2015 | January 1, 2018 ‐

December  31, 2018 |
| WFCM  2016‐C37                | Commercial  Mortgage Pass‐Through  Certificates, Series WFCM 2016‐C37  pursuant to the Pooling and Servicing Agreement dated December 1, 2016 | January 1, 2018 ‐

December  31, 2018 |
| CGCMT 2016‐C3                 | Commercial Mortgage Pass‐Through  Certificates, Series CGCMT 2016‐C3 pursuant to the Pooling and Servicing  Agreement dated November 1, 2016 | January 1, 2018 ‐

December  31, 2018 |
| WFCM 2016‐LC24                | Commercial  Mortgage Pass‐Through  Certificates, Series WFCM 2016‐LC24  pursuant to the Pooling and Servicing Agreement dated September 1, 2016 | January 1, 2018 ‐

December  31, 2018 |
| WFCM  2016‐NXS6               | Commercial Mortgage Pass‐Through  Certificates, Series WFCM 2016‐NXS6  pursuant to the Pooling and Servicing Agreement dated October 1, 2016 | January 1, 2018 ‐

December  31, 2018 |
| 245 Park Ave Trust 2017‐ 245P | Commercial Mortgage Pass‐Through  Certificates, Series 245 Park Ave Trust 2017‐245P pursuant to the Pooling and  Servicing Agreement dated May 30, 2017 | January 1, 2018 ‐

December  31, 2018 |
| CGCMT 2017‐B1                 | Commercial Mortgage Pass‐Through  Certificates, Series CGCMT 2017‐B1 pursuant to the Pooling and Servicing  Agreement dated August 29, 2017 | January 1, 2018 ‐

December  31, 2018 |
| MSC 2017‐H1                   | Commercial Mortgage Pass‐Through  Certificates, Series MSC 2017‐H1  pursuant to the Pooling and Servicing Agreement dated June 8, 2017 | January 1, 2018 ‐

December  31, 2018 |
| WFCM 2017‐C39                 | Commercial  Mortgage Pass‐Through  Certificates, Series WFCM 2017‐C39  pursuant to the Pooling and Servicing Agreement dated August 22, 2017 | January 1, 2018 ‐

December  31, 2018 |
| WFCM  2017‐RB1                | Commercial  Mortgage Pass‐Through  Certificates, Series WFCM 2017‐RB1  pursuant to the Pooling and Servicing Agreement dated March 1, 2017 | January 1, 2018 ‐

December  31, 2018 |
| WFCM 2017‐C41                 | Commercial  Mortgage Pass‐Through  Certificates, Series WFCM 2017‐RB1 pursuant to the Pooling and Servicing Agreement  dated November 1, 2017 | January 1, 2018 ‐

December  31, 2018 |