Management's Assertion on Compliance
with Applicable
Regulation AB Servicing Criteria

| | 1. | Rialto Capital Advisors, LLC (the "Asserting Party") is responsible for assessing compliance
with the servicing criteria applicable to it under paragraph (d) of Item 1122 of Regulation AB, as of and for the 12-month period ending
December 31, 2022 (the "Reporting Period"), as set forth in Appendix A hereto. The transactions covered by this report, include
commercial mortgage-asset-backed securities transactions, as listed on Exhibit I hereto, for which the Asserting Party served as special
servicer, and that were registered with the Securities and Exchange Commission pursuant to the Securities Act of 1933 (the "Platform");
| | -- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

| | 2. | The Asserting Party has engaged certain vendors, which are not servicers as defined in Item 1101(j)
of Regulation AB (the "Vendors"), to perform specific, limited or scripted activities, and the Asserting Party elects to take
responsibility for assessing compliance with the servicing criteria or portion of the servicing criteria applicable to such Vendors' activities
as set forth in Appendix A hereto;
| | -- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

| | 3. | Except as set forth in paragraph 4 below, the Asserting Party used the criteria set forth in paragraph
(d) of Item 1122 of Regulation AB to assess the compliance with the applicable servicing criteria;
| | -- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

| | 4. | The criteria listed in the column titled "Inapplicable Servicing Criteria" on Appendix A hereto
are inapplicable to the Asserting Party based on the activities it performs, directly or through its Vendors, with respect to the Platform;
| | -- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

| | 5. | The Asserting Party has complied, in all material respects, with the applicable servicing criteria as
of December 31, 2022 and for the Reporting Period with respect to the Platform taken as a whole;
| | -- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

| | 6. | The Asserting Party has not identified and is not aware of any material instance of noncompliance by
the Vendors with the applicable servicing criteria as of December 31, 2022 and for the Reporting Period with respect to the Platform taken
as a whole;
| | -- | -----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

| | 7. | The Asserting Party has not identified any material deficiency in its policies and procedures to monitor the compliance by the Vendors
with the applicable servicing criteria as of December 31, 2022 and for the Reporting Period with respect to the Platform taken as a whole;
and
| | -- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

| | 8. | Deloitte & Touche LLP, an independent registered public accounting firm, has issued an attestation report on the Asserting Party's
assessment of compliance with the applicable servicing criteria for the Reporting Period.
| | -- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

February 23, 2023










Exhibit 1

|Pooling and Servicing Agreements | Applicable Certification Period     
|-------------------------------- | ------------------------------------
|CLNY 2019-IKPR                   | January 1, 2022 to June 3, 2022     
|WFRBS 2012-C6                    | January 1, 2022 to June 6, 2022     
|WFRBS 2012-C8                    | January 1, 2022 to December 31, 2022
|WFCM 2012-LC5                    | January 1, 2022 to December 31, 2022
|UBS-Barclays 2012-C3             | January 1, 2022 to December 31, 2022
|UBS-Barclays 2012-C4             | January 1, 2022 to December 31, 2022
|GSMS 2012-GCJ9                   | January 1, 2022 to December 31, 2022
|JPMCC 2012-LC9                   | January 1, 2022 to December 31, 2022
|COMM 2013-LC6                    | January 1, 2022 to December 31, 2022
|WFRBS 2013-CI2                   | January 1, 2022 to December 31, 2022
|UBS-Barclays 2013-C6             | January 1, 2022 to December 31, 2022
|GSMS 2013-GCJ12                  | January 1, 2022 to December 31, 2022
|WFRBS 2013-C14                   | January 1, 2022 to December 31, 2022
|WFRBS 2011-C5                    | January 1, 2022 to December 31, 2022
|WFCM 2013-LC12                   | January 1, 2022 to December 31, 2022
|WFRBS 2011-C2                    | January 1, 2022 to December 31, 2022
|WFRBS 2011-C3                    | January 1, 2022 to December 31, 2022
|WFRBS 2011-C4                    | January 1, 2022 to December 31, 2022
|UBS-Citigroup 2011-C1            | January 1, 2022 to December 31, 2022
|UBSCM 2012-C1                    | January 1, 2022 to December 31, 2022
|GSMS 2011-GC3                    | January 1, 2022 to December 31, 2022
|COMM 2013-LC13                   | January 1, 2022 to December 31, 2022
|WFRBS 2013-C16                   | January 1, 2022 to December 31, 2022
|GSMS 2013-GCJ16                  | January 1, 2022 to December 31, 2022
|WFRBS 2013-CI7                   | January 1, 2022 to December 31, 2022
|GSMS 2012-GC6                    | January 1, 2022 to December 31, 2022
|MSBAM 2013-C13                   | January 1, 2022 to December 31, 2022
|COMM 2014-CCRE14                 | January 1, 2022 to December 31, 2022
|MSBAM 2014-C14                   | January 1, 2022 to December 31, 2022
|WFRBS 2014-LC14                  | January 1, 2022 to December 31, 2022
|COMM 2014 -LC15                  | January 1, 2022 to December 31, 2022
|WFRBS 2014-C20                   | January 1, 2022 to December 31, 2022

2




|COMM 2014-CCRE18 | January 1, 2022 to December 31, 2022
|---------------- | ------------------------------------
|CGCMT 2014-GC23  | January 1, 2022 to December 31, 2022
|MSBAM 2014-C17   | January 1, 2022 to December 31, 2022
|COMM 2014-UBS5   | January 1, 2022 to December 31, 2022
|MSBAM 2014-C18   | January 1, 2022 to December 31, 2022
|COMM 2012-CCRE4  | January 1, 2022 to December 31, 2022
|WFRBS 2014-C24   | January 1, 2022 to December 31, 2022
|JPMBB 2014-C25   | January 1, 2022 to December 31, 2022
|WFCM 2014-LCI8   | January 1, 2022 to December 31, 2022
|COMM 2015-DC1    | January 1, 2022 to December 31, 2022
|GSMS 2015-GC28   | January 1, 2022 to December 31, 2022
|WFCM 2015-C27    | January 1, 2022 to December 31, 2022
|WFCM 2015-LC20   | January 1, 2022 to December 31, 2022
|WFCM 2015-NXSI   | January 1, 2022 to December 31, 2022
|CSAIL 2015-C2    | January 1, 2022 to December 31, 2022
|WFCM 2015-NXS2   | January 1, 2022 to December 31, 2022
|COMM 2015-PC1    | January 1, 2022 to December 31, 2022
|CSAIL 2015-C3    | January 1, 2022 to December 3I, 2022
|WFCM 2015-SG1    | January 1, 2022 to December 31, 2022
|WFCM 2015-LC22   | January 1, 2022 to December 31, 2022
|COMM 2015-CCRE27 | January 1, 2022 to December 31, 2022
|WFCM 2015-NXS4   | January 1, 2022 to December 31, 2022
|MSCI 2015-UBS8   | January 1, 2022 to December 31, 2022
|CSAIL 2016-C5    | January 1, 2022 to December 31, 2022
|WFCM 2016-C32    | January 1, 2022 to December 31, 2022
|WFCM 2016-NXSS   | January 1, 2022 to December 31, 2022
|CGCMT 2015-GC27  | January 1, 2022 to December 31, 2022
|WFCM 2016-C33    | January 1, 2022 to December 31, 2022
|MSBAM 2015-C20   | January 1, 2022 to December 31, 2022
|CFCRE 2016-C4    | January 1, 2022 to December 31, 2022
|BACM 2016-UBS10  | January 1, 2022 to December 31, 2022
|SGCMS 2016-C5    | January 1, 2022 to December 31, 2022
|WFCM 2016-BNKI   | January 1, 2022 to December 31, 2022
|CD 2016-CD 1     | January 1, 2022 to December 31, 2022
|GSMS 2016-GS3    | January 1, 2022 to December 31, 2022
|MSBAM 2016-C31   | January 1, 2022 to December 31, 2022

3




|CGCMT 2016-C3   | January 1, 2022 to December 31, 2022
|--------------- | ------------------------------------
|CFCRE 2016-C6   | January 1, 2022 to December 31, 2022
|CSAIL 2016-C7   | January 1, 2022 to December 31, 2022
|MSCI 2016-UBS12 | January 1, 2022 to December 31, 2022
|BBCMS 2017-C1   | January 1, 2022 to December 31, 2022
|GSMS 2017-GS5   | January 1, 2022 to December 31, 2022
|CGCMT 2017-P7   | January 1, 2022 to December 31, 2022
|BANK 2017-BNK4  | January 1, 2022 to December 31, 2022
|CD 2017-CD4     | January 1, 2022 to December 31, 2022
|CFCRE 2017-C8   | January 1, 2022 to December 31, 2022
|JPMCC 2017-JP6  | January 1, 2022 to December 31, 2022
|CD 2017-CD5     | January 1, 2022 to December 31, 2022
|GSMS 2017-GS7   | January 1, 2022 to December 31, 2022
|BANK 2017-BNK7  | January 1, 2022 to December 31, 2022
|CSAIL 2017-CX9  | January 1, 2022 to December 31, 2022
|UBSCM 2017-C4   | January 1, 2022 to December 31, 2022
|UBSCM 2017-C6   | January 1, 2022 to December 31, 2022
|BANK 2017-BNK9  | January 1, 2022 to December 31, 2022
|GSMS 2018-GS9   | January 1, 2022 to December 31, 2022
|UBSCM 2018-C9   | January 1, 2022 to December 31, 2022
|MSBAM 2012-C5   | January 1, 2022 to December 31, 2022
|WFCM 2018-C44   | January 1, 2022 to December 31, 2022
|UBSCM 2018-C10  | January 1, 2022 to December 31, 2022
|WFCM 2015-C30   | January 1, 2022 to December 31, 2022
|JPMBB 2014-C23  | January 1, 2022 to December 31, 2022
|MSBAM 2014-C19  | January 1, 2022 to December 31, 2022
|COMM 2015-LC21  | January 1, 2022 to December 31, 2022
|MSBAM 2016-C29  | January 1, 2022 to December 31, 2022
|JPMBB 2015-C31  | January 1, 2022 to December 31, 2022
|GSMS 2018-GS10  | January 1, 2022 to December 31, 2022
|CD 2018-CD7     | January 1, 2022 to December 31, 2022
|GSMS 2018-3PCK  | January 1, 2022 to December 31, 2022
|BANK 2018-BNK14 | January 1, 2022 to December 31, 2022
|DBGS 2018-C1    | January 1, 2022 to December 31, 2022
|CSAIL 2018-C14  | January 1, 2022 to December 31, 2022
|UBSCM 2018-C14  | January 1, 2022 to December 31, 2022

4




|ILPT 2019-SURF   | January 1, 2022 to December 31, 2022
|---------------- | ------------------------------------
|MSCI 2019-L2     | January 1, 2022 to December 31, 2022
|WFCM 2019-C50    | January 1, 2022 to December 31, 2022
|BANK 2019-BNK18  | January 1, 2022 to December 31, 2022
|WFCM 2015-P2     | January 1, 2022 to December 31, 2022
|BMARK 2019-B11   | January 1, 2022 to December 31, 2022
|CGCMT 2019-GC41  | January 1, 2022 to December 31, 2022
|BBCMS 2019-C4    | January 1, 2022 to December 31, 2022
|COMM 2014-CCRE15 | January 1, 2022 to December 31, 2022
|UBSCM 2019-C17   | January 1, 2022 to December 31, 2022
|BANK 2019-BNK21  | January 1, 2022 to December 31, 2022
|CGCMT 2019-GC43  | January 1, 2022 to December 31, 2022
|CSAIL 2019-C18   | January 1, 2022 to December 31, 2022
|COMM 2019-0C44   | January 1, 2022 to December 31, 2022
|UBSCM 2019-C18   | January 1, 2022 to December 31, 2022
|WFCM 2020-C55    | January 1, 2022 to December 31, 2022
|UBSBB 2012-C2    | January 1, 2022 to December 31, 2022
|BBCMS 2020-C7    | January 1, 2022 to December 31, 2022
|CSMC 2020-NET    | January 1, 2022 to December 31, 2022
|BMARK 2020-B19   | January 1, 2022 to December 31, 2022
|BMARK 2020-B22   | January 1, 2022 to December 31, 2022
|CSMC 2020-FACT   | January 1, 2022 to December 31, 2022
|BANK 2020-BNK29  | January 1, 2022 to December 31, 2022
|WFCM 2020-C58    | January 1, 2022 to December 31, 2022
|FSRIA 2019-FL1   | January 1, 2022 to December 31, 2022
|BANK 20 21-BNK32 | January 1, 2022 to December 31, 2022
|BSST 2021-1818   | January 1, 2022 to December 31, 2022
|BMARK 2021-B25   | January 1, 2022 to December 31, 2022
|FSRIA 2021-FL2   | January 1, 2022 to December 31, 2022
|MSC 2007-T27     | January 1, 2022 to December 31, 2022
|BANK 2021-BNK33  | January 1, 2022 to December 31, 2022
|BBCMS 2021-C10   | January 1, 2022 to December 31, 2022
|CSMC 2021-ADV    | January 1, 2022 to December 31, 2022
|BANK 2021-BNK36  | January 1, 2022 to December 31, 2022
|FSRIA 2021-FL3   | January 1, 2022 to December 31, 2022
|BACM 2017-BNK3   | January 1, 2022 to December 31, 2022

5




|BMARK 2021-B31                                                                                                 | January 1, 2022 to December 31, 2022   
|-------------------------------------------------------------------------------------------------------------- | ---------------------------------------
|BSST 2022-1700                                                                                                 | February 22, 2022 to December 31, 2022 
|SPGN 2022-TFLM                                                                                                 | February 25, 2022 to December 31, 2022 
|FSRIA 2022-FL4                                                                                                 | March 31, 2022 to December 31, 2022    
|BBCMS 2022-C15                                                                                                 | April 13, 2022 to December 31, 2022    
|BANK 2022-BN41                                                                                                 | May 5, 2022 to December 31, 2022       
|Rial 2022-FL8                                                                                                  | May 20, 2022 to December 31, 2022      
|CGCMT 2022-GC48
    (RCA is special servicer as to the Yorkshire &
    Lexington Towers loan combination only) | June 1, 2022 to December 31, 2022      
|BAMLL 2022-DKLX                                                                                                | June 6, 2022 to December 31, 2022      
|FSRIA 2022-FL5                                                                                                 | June 16, 2022 to December 31, 2022     
|BMO 2022-C2                                                                                                    | July 12, 2022 to December 31, 2022     
|FSRIA 2022-FL6                                                                                                 | August 25, 2022 to December 31, 2022   
|CSMC 2022-NWPT                                                                                                 | September 21, 2022 to December 31, 2022
|BMARK 2022-B37                                                                                                 | November 3, 2022 to December 31, 2022  
|BBCMS 2022-C18                                                                                                 | December 14, 2022 to December 31, 2022 

6




APPENDIX A



|SERVICING
    CRITERIA |                                                                                                                                                                                                                                                                    
|---------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
|Reference              | 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.                                                                                                         
|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.                                                            
|1122(d)(1)(iii)        | Any requirements in the transaction agreements to maintain a back-up services for the pool assets are maintained.                                                                                                                                                  
|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.
|1122(d)(1)(v)          | Aggregation of information, as applicable, is 
mathematically accurate and the information conveyed 
accurately reflects the information.                                                                                                                          

7






|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.                                                                                                                                                                                                                                                                                                                                                                                                                                                  
|1122(d)(2)(ii)                         | Disbursements made via wire transfer on behalf of an 
obligor
    or to an investor are made only by authorized
    personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                          
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                                      
|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.                                                                                                                                                                                                                                                                                                                          
|1122(d)(2)(vi)                         | Unissued checks are safeguarded so as to prevent 
unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         
|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.

8






|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.
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                               
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    

9






|                 | 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.                                                                                                                                                                                                                                                                                                                                                                                   
|1122(d)(4)(ii)   | Pool asset and related documents are safeguarded as 
required by the transaction agreements                                                                                                                                                                                                                                                                                                                                                                                                                           
|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.                                                                                                                                                                                                                                                                                                                                         
|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.                                                                                                    
|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.                                                                                                                                                                                                                                                                                                                                                                           
|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.                                                                                                                                                                                                                                                           
|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.                                                                                                                                                                                                            
|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).
|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.                                                                                                                                                                                                                                                                                                                                                                        
|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                                                                                               

10






|                 | 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.                                                                                                                                                                                                                                 |  |  
|---------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |  | -
|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.                                                                                                                                                                                                                                                                     |  | X
|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



XI- Rialto Capital Advisors, LLC performs
the activities pertaining to this criterion, except for specific, limited activities performed by (a) its third-party property managers
relating to REO Property, if any; and (b) RERC, LLC, a SitusAMC Company, pursuant to a Staffing Agreement, in which RERC provides RCA
with real estate consultant and valuation professionals to perform support functions in connection with property appraisals. Rialto has
elected to take responsibility for assessing compliance with these servicing criteria with respect to the activities of its third-party
property managers and RERC, LLC.

X2-Primary responsibility for processing
borrower payments rests with the Master Servicer, however, Rialto Capital Advisors, LLC may from time to time receive payments on an
exception basis which are forwarded to the Master Servicer in accordance with such criteria. The criteria is marked applicable as Rialto
Capital Advisors, LLC had instances or activity relating to this criteria for the calendar year of January 1, 2022 to December 31, 2022.

X3- Although Rialto Capital Advisors,
LLC is responsible for performing the activities under this criteria, it is noted no such activities occurred during the calendar year
of January 1, 2022 to December 31, 2022,

X4-Only items (A) and (B) of the Servicing
Criteria are applicable to Rialto Capital Advisors, LLC as special servicer. Items (C) and (D) are inapplicable as the responsibility
for filing reports with the Commission and agreeing totals to the Servicer records rests with the Trustee and/or Certificate Administrator,
as applicable.



11