Report of Independent Registered Public Accounting Firm

The Board of Directors and Shareholder KeyBank National Association

We have examined management’s assertion, included in the accompanying
Management’s Assertion on Compliance with Regulation AB Servicing Criteria, that KeyBank National Association, as successor by merger
to KeyCorp Real Estate Capital Markets, Inc., (the Company) complied with the servicing criteria set forth in Item 1122 (d) of the Securities
and Exchange Commission’s Regulation AB for commercial real estate mortgage loans platform, except for the instance of material
noncompliance described therein, as of and for the year ended December 31, 2022, except for Item 1122 (d)(3)(i)(b), 1122 (d)(3)(i)(c),
1122 (d)(3)(i)(d), 1122 (d)(3)(ii), 1122 (d)(3)(iii) and 1122 (d)(3)(iv), which the Company has determined are not applicable to the activities
performed by them with respect to the servicing platform covered by this report as noted in Appendix B of management’s assertion.
See Appendix A of management’s assertion for the asset backed transactions covered by this platform. Management is responsible for
the Company’s compliance with those servicing criteria. Our responsibility is to express an opinion on management’s assertion
about the Company’s compliance with the servicing criteria based on our examination.

Our examination was conducted in accordance with attestation standards
established by the American Institute of Certified Public Accountants and the Public Company Accounting Oversight Board (United States)
and, accordingly, included examining, on a test basis, evidence about the Company’s compliance with the applicable servicing criteria
and performing such other procedures as we considered necessary in the circumstances. Our examination included testing of less than all
of the individual asset backed transactions and securities that comprise the Platform, testing of less than all of the servicing activities
related to the Platform and determining whether the Company processed those selected transactions and performed those selected activities
in compliance with the servicing criteria and as permitted by Regulation AB Compliance and Disclosure Interpretations of the Division
of Corporation Finance, Section 200.06, “Vendors Engaged by Servicers” (C&DI 200.06). Furthermore, our procedures were
limited to the selected transactions and servicing activities performed by the Company during the period covered by this report. Our procedures
were not designed to determine whether errors may have occurred either prior to or subsequent to our tests that may have affected the
balances or amounts calculated or reported by the Company during the period covered by this report for the selected transactions or any
other transactions. Although the Company is responsible for assessing compliance with Item 1122 (d)(1)(iii) of Regulation AB, there were
no servicing activities performed by the Company during the year ended December 31, 2022 that required these servicing criteria to be
complied with. We believe that the evidence we obtained is sufficient and appropriate to provide a reasonable basis for our opinion.

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A member firm of Ernst & Young Global Limited











Our examination disclosed the following material
noncompliance with servicing criteria 1122(d)(4)(ix) applicable to the Company during the year ended December 31, 2022. With respect to
servicing criteria 1122(d)(4)(ix), the servicer did not consistently process adjustments to interest rates in accordance with pool asset
documents.

We are required to be independent of Key Bank National
Association and to meet our other ethical responsibilities, in accordance with the relevant ethical requirements related to our examination
engagement.

Our examination does not provide a legal determination
on the Company’s compliance with the servicing criteria.

As described in management’s assertion, for servicing
criteria 1122 (d)(4)(xi), the Company has engaged a vendor to perform the activities required by this servicing criteria. The Company
has determined that this vendor is not considered a “servicer” as defined in Item 1101(j) of Regulation AB, and the Company
has elected to take responsibility for assessing compliance with the applicable servicing criteria applicable to the vendor as permitted
by C&DI 200.06. As permitted by C&DI 200.06, the Company has asserted that it has policies and procedures in place designed to
provide reasonable assurance that the vendors’ activities comply in all material respects with servicing criteria applicable to
the vendor. The Company is solely responsible for determining that it meets the SEC requirements to apply C&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 eligibility to
apply C&DI 200.06.

In our opinion, except for the material noncompliance
described in the third paragraph, the Company complied with the aforementioned servicing criteria, including servicing criteria 1122 (d)(4)(xi)
for which compliance is determined based on C&DI 200.06 as described above, as of and for the year ended December 31, 2022.





February 22, 2023



A member firm of Ernst & Young Global Limited