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**REPORTOF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM**

 

RialtoCapital Advisors, LLC.

 

Wehave examined management of Rialto Capital Advisors, LLC’s assertion, includedin the accompanying Management’s Assertion on Compliance with ApplicableRegulation AB Servicing Criteria, that Rialto Capital Advisors, LLC, (the “Company”)complied with the servicing criteria set forth in Item 1122(d) of theSecurities and Exchange Commission’s Regulation AB for the commercial mortgageloan platform (the “Platform”), excluding criteria in Items 1122 (d)(l)(iii),(d)(2)(ii), (d)(2)(iii), (d)(3)(i.C), (d)(3)(i.D), (d)(3)(ii), (d)(3)(iii),(d)(3)(iv), (d)(4)(v), (d)(4)(ix), (d)(4)(x), (d)(4)(xi), (d)(4)(xii),(d)(4)(xiii), (d)(4)(xiv), and (d)(4)(xv) (the “servicing criteria”), as of andfor the year ended December 31, 2019, which management has determined are notapplicable to the activities performed by the Company with respect to thePlatform. Exhibit 1 to management’s assertion identifies the individualasset-backed transactions defined by management as constituting the Platform. Managementis responsible for the Company’s compliance with the servicing criteria and itsassertion. Our responsibility is to express an opinion on management’sassertion about the Company’s compliance with the servicing criteria based onour examination.

 

Ourexamination was conducted in accordance with the standards of the PublicCompany Accounting Oversight Board (United States) and in accordance withattestation standards established by the American Institute of Certified PublicAccountants. Those standards require that we plan and perform the examinationto obtain reasonable assurance about whether management’s assertion aboutcompliance with the servicing criteria is fairly stated, in all materialrespects, and, accordingly, included examining, on a test basis, evidence aboutthe Company’s compliance with the servicing criteria, including tests on asample basis of the servicing activities related to the Platform, determiningwhether the Company performed those selected activities in compliance with the servicingcriteria during the specified period, and performing such other procedures aswe considered necessary in the circumstances. Our procedures were limited toselected servicing activities performed by the Company during the periodcovered by this report and, accordingly, such samples may not have includedservicing activities related to each asset-backed transaction included in thePlatform. Further, an examination is not designed to detect noncompliancearising from errors that may have occurred prior to the period specified abovethat may have affected the balances or amounts calculated or reported by theCompany during the period covered by this report. We believe that the evidencewe obtained in our examination is sufficient and appropriate to provide areasonable basis for our opinion.

 

Asdescribed in management’s assertion, for servicing criteria Item1122(d)(l)(ii), the Company has engaged a vendor to perform certain activitiesrequired by this servicing criteria. The Company has determined that thisvendor is not considered a “servicer” as defined in Item 1101(j) of RegulationAB, and the Company has elected to take responsibility for assessing compliancewith the servicing criteria applicable to this vendor as permitted by the SEC’s*Compliance and Disclosure Interpretation 200.06, Vendors Engaged byServicers (“C&DI 200.06”)*. As permitted by C&DI 200.06, the Companyhas asserted that it has policies and procedures in place designed to providereasonable assurance that the vendor’s activities comply in all materialrespects with the servicing criteria applicable to this vendor. The Company issolely responsible for determining that it meets the SEC requirements to applyC&DI 200.06 for the vendor and related criteria as described in its assertion,and we performed no procedures with respect to the Company’s determination ofits eligibility to apply C&DI 200.06.

 

Ourexamination does not provide a legal determination on the Company’s compliancewith the servicing criteria.

 

Inour opinion, management’s assertion that the Company complied with theaforementioned servicing criteria as of and for the year ended December 31,2019, for the commercial mortgage loan platform, is fairly stated, in allmaterial respects.

 

 

/s/Deloitte & Touche LLP

 

February28, 2020