**Report onAssessment of Compliance with SEC Regulation AB**

**Servicing Criteriaas Primary Servicer**

** **

BerkadiaCommercial Mortgage LLC (“Berkadia”) is responsible for assessing compliance,as of and for the year ended December 31, 2018 (the “Reporting Period”), withthe Servicing Criteria set forth in Item 1122(d) of Regulation AB of the U.S.Securities and Exchange Commission for asset-backed securities transactions. Thisassertion includes all commercial mortgage loans sold in public securitizationsfrom the period January 1, 2006 through December 31, 2018 for which Berkadiaserved as primary servicer (the “Platform”).

 

Berkadiahas concluded that the criteria are applicable as shown below (indicated by  “X”) to the primary servicing of the loans in the Platform:

 

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**Regulation AB  Criteria 1122(d)**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | **Applicability  of Criteria as the Primary**

**Servicer** |
|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------|
| (1)      General servicing considerations.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |                                                        |
| (i)       Policies and procedures are instituted to monitor any performance or other  triggers and events of     

           default in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     | X                                                           |
| (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                                                   |
| (iii)     Any requirements in the transaction agreements to maintain a back-up servicer  for the pool assets are    

           maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | (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                                                   |
| (v)      Aggregation of information, as applicable, is mathematically accurate and the  information conveyed   

           accurately reflects the information.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | X                                                           |
| (2)      Cash collection and administration.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |                                                        |
| (i)       Payments on pool assets are deposited into the 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |  

X                                                   |
| (ii)      Disbursements made via wire transfer on behalf of an obligor or to an  investor are made only by   

           authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | X                                                           |
| (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                                                   |
| (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                                                   |
| (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 § 240.13k-1(b)(1) of this chapter.                                                                                                                                                                                                                                                                             |  

X                                                   |
| (vi)     Unissued checks are safeguarded so as to prevent  unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     | X                                                           |
| (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:                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                                        |
| (A)     Are mathematically accurate;                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | X                                                           |
|  (B)       Are prepared within 30 calendar days after the  bank statement cutoff date, or such other number of days      

            specified in the transaction agreements;                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | X                                                           |
| (C)       Are reviewed and approved by someone other than the person who prepared  the reconciliation; and                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | X                                                           |
| (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                                                   |
| (3)        Investor remittances and reporting.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |                                                        |
| (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;                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | X                                                           |
| (B)       Provide information calculated in accordance  with the terms specified in the transaction agreements;                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | X                                                           |
| (C)       Are filed with the Commission as required by  its rules and regulations; and                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | (1)                                                         |
| (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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | X                                                           |
| (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                                                           |
| (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                                                           |
| (iv)       Amounts remitted to investors per the investor  reports agree with cancelled checks, or other form of  

             payment, or custodial bank statements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | X                                                           |
| (4)        Pool asset administration.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                                        |
| (i)         Collateral or security on pool assets  is maintained as required by the transaction agreements or related  

             pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | X(2)                                                        |
| (ii)       Pool  assets and related documents are safeguarded as required by the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | (1)                                                         |
| (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                                                   |
| (iv)       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.                                                                                                                                                                            |  

X                                                   |
| (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                                                           |
| (vi)      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.                                                                                                                                                                                                                                                                                                                                                                                                                                            |  

X                                                   |
| (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.                                                                                                                                                                                                                                                                                                                                                                                                       |  

(1)                                                 |
|    (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                                                   |
| (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                                                           |
| (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;                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | X                                                           |
| (B)        Interest on such funds is paid, or credited, to obligors in accordance with  applicable pool asset     

             documents and state laws; and                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | X                                                           |
| (C)        Such funds are 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | X                                                           |
| (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(2)                                        |
| (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(2)                                                |
| (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(2)                                                |
| (xiv)      Delinquencies, charge-offs and uncollectible accounts are recognized and  recorded in accordance with  

              the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | X                                                           |
| (xv)       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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             |  

(1)                                                 |

 

X   Servicer was responsible for this criteria in its role asPrimary Servicer.

(1) Per servicing and pooling agreements, the criteria does not apply to the roleof Primary Servicer.

(2) Vendor(s), for which Berkadia is the Responsible Party, contribute(s) tothe servicing activities for this criteria.

 

TheServicing  Criteria , after  giving  effect  to  the foregoing  exclusions,  are  referred  to  as the "Applicable Servicing Criteria."

 

Berkadiautilizes vendors to support its servicing operations, including the use of acommercial tax service which supports its assertions under 1122(d)(4)(xi)through 1122(d)(4)(xiii) and the use of a lien filing firm to support itsassertion under 1122(d)(4)(i). These vendors' activities contribute to theservicing activities to which Berkadia is asserting. In all cases, the vendors'activities are limited, and Berkadia assumes responsibility for the 1122assessment for these vendors' activities. These vendors do not fit thedefinition of servicer under Item 1101(j), and Berkadia employs policies andprocedures designed to provide assurance that the vendors' activities complywith the Applicable Servicing Criteria to such vendors.

 

Forthe Reporting Period, Berkadia has assessed its compliance with the Applicable ServicingCriteria for the Platform and has concluded that its servicing operation hascomplied, in all material respects, with the Applicable Servicing Criteria.

 

GrantThornton LLP, an independent registered public accounting firm, has issued anattestation report on management's assertion of compliance with the ApplicableServicing Criteria.

 

 

BerkadiaCommercial Mortgage LLC

 

 

February15, 2019

 

 

/s/Mark E . McCool

MarkE . McCool 

ExecutiveVice President

BerkadiaCommercial Mortgage LLC