**Management's Certification On Compliance withApplicable Servicing Criteria**

 

 

Prudential Asset Resources,Inc., ("PAR") is responsible for assessing compliance by it with the servicingcriteria applicable to PAR under paragraph (d) of Item 1122 of Regulation AB(the "Servicing Criteria"), as of and for the year ended December 31,2019, as set forth in Exhibit A hereto in connection with all commercialmortgage loans serviced within the Platform, as set forth in Exhibit B duringthe applicable period;

 

1.     Except as set forth inparagraph 3 below, the Asserting Parties used the criteria set forth inparagraph (d) of Item 1122 of Regulation AB to assess the compliance with theServicing Criteria;

 

2.     The criteria described asnot applicable on Exhibit A hereto are inapplicable to the Asserting Partiesbased on the activities PAR performs with respect to commercial mortgagesecurities transactions involving mortgage loans, also PAR has identifiedspecific servicing criteria for which no transaction activity occurred;

 

3.     PAR has engaged certainvendors, which are not deemed to be servicers as defined in Item 1101(j) ofRegulation AB (the "Vendors"), to perform specific and limitedactivities or activities scripted by PAR as of and during the Reporting Period,and the PAR elects to take responsibility for assessing compliance with theServicing Criteria or portion of the Servicing Criteria applicable to suchVendors as set forth in Exhibit A hereto (such criteria, the "ApplicableServicing Criteria Performed by Vendor(s)"). 

 

PAR has policies and procedures in place designed toprovide reasonable assurance that the Vendor's activities comply, in allmaterial respects, for purposes of Regulation AB with the Applicable VendorServicing Criteria. PAR (i) has not identified and are not aware of anymaterial instance of noncompliance by the Vendors with the Applicable VendorServicing Criteria that would affect PAR's compliance and (ii) has notidentified any material deficiency in PAR's policies and procedures to monitorthe compliance by the Vendor with the Applicable Servicing Criteria Performedby Vendor(s) as of December 31, 2019 and for the Reporting Period.

 

4.     PAR has complied in allmaterial respects, with the Servicing Criteria as of and for the year endingDecember 31, 2019; and

 

5.     PricewaterhouseCoopers LLPhas issued an attestation report with respect to PAR's assessment of compliancewith the Servicing Criteria as of and for the year ended December 31, 2019.

 

February 21, 2020

 

 

Prudential Asset Resources,Inc.

 

 

/s/ Joni Brown-Haas

Joni Brown-Haas, President

 

/s/ Keith Kehlbeck

Keith Kehlbeck, Vice President

 

 

**EXHIBIT A**

** **

| **SERVICING CRITERIA**

**Reg AB Portfolio** | **APPLICABLE**

**SERVICING**

**CRITERIA**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | **INAPPLICABLE**

**SERVICING CRITERIA** |
|----------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------|
|  

 

Reference                    |  

 

Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | Performed 

by

Servicer                 | Performed

by

Vendor(s) |   |
| **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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | Y                                        |   |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | Y                                        |   |   |
| 1122(d)(1)(iii)                              | Any requirements in the  transaction agreements to maintain a back-up servicer for the mortgage loans  are maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |                                     |   | N/A |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                 | Y#1                                      |   |   |
| 1122(d)(1)(v)                                | Aggregation of information,  as applicable, is mathematically accurate and the information conveyed  accurately reflects the information.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | Y                                        |   |   |
| **Cash Collection and  Administration**      |
| 1122(d)(2)(i)                                | Payments on mortgage loans  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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | Y                                        |   |   |
| 1122(d)(2)(ii)                               | Disbursements made via wire  transfer on behalf of an obligor or to an investor are made only by  authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | Y                                        | Y#2 |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | Y                                        |   |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                             | Y                                        |   |   |
| 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- l(b)(1) of the Securities Exchange Act.                                                                                                                                                                                                                                                                                                                | Y                                        |   |   |
| 1122(d)(2)(vi)                               | Unissued checks are  safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | Y                                        | Y#2 |   |
| 1122(d)(2)(vii)                              | Reconciliations are prepared  on a monthly basis for all commercial mortgage 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. | Y                                        | Y#3 |   |
| **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 mortgage loans serviced by the  Servicer.                                             | Y #7 for 

(A&B)                     |   | N/A for (C&D) |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |                                     |   | N/A |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |                                     |   | N/A |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |                                     |   | N/A |
| **Pool Asset Administration**                |
| 1122(d)(4)(i)                                | Collateral or security on  mortgage loans is maintained as required by the transaction agreements or related  mortgage loan documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | Y                                        |   |   |
| 1122(d)(4)(ii)                               | Mortgage loan and related  documents are safeguarded as required by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | Y#4                                      |   |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | Y#5                                      |   |   |
| 1122(d)(4)(iv)                               | Payments on mortgage loans,  including any payoffs, made in accordance with the related mortgage loan  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 mortgage loan documents.                                                                                                                                                                                                                                                                                     | Y                                        |   |   |
| 1122(d)(4)(v)                                | The Servicer’s records  regarding the mortgage loans agree with the Servicer’s records with respect  to an obligor’s unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     | Y                                        |   |   |
| 1122(d)(4)(vi)                               | Changes with respect to the terms  or status of an obligor’s mortgage loans (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.                                                                                                                                                                                                                                                                                                                                                                                                                                                  | Y                                        |   |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                           | Y#6                                      |   |   |
| 112)(d)(4)(viii)                             | Records documenting  collection efforts are maintained during the period a mortgage loan 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 mortgage loans including, for example, phone calls, letters and  payment rescheduling plans in cases where delinquency is deemed temporary  (e.g., illness or unemployment)                                                                                                                                                                                           | Y                                        |   |   |
| 1122(d)(4)(ix)                               | Adjustments to interest  rates or rates of return for mortgage loans with variable rates are computed  based on the related mortgage loan documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | Y                                        |   |   |
| 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 mortgage loan 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 mortgage loan documents and state laws; and (C) such funds are  returned to the obligor within 30 calendar days of full repayment of the  related mortgage loans, or such other number of days specified in the  transaction agreements.                                                                                                               | Y                                        |   |   |
| 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.                                                                                                                                                                                                                                                                                                                 | Y                                        | Y#2 |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | Y                                        | Y#2 |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | Y                                        |   |   |
| 1122(d)(4)(xiv)                              | Delinquencies, charge-offs  and uncollectible accounts are recognized and recorded in accordance with the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | Y                                        |   |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                     |   | N/A |

 

 

**Y**=Yes

 

**Y#l** = Fidelity bond and errors and omissions policies inforce for Prudential. In addition, fidelity bond and errors and omissionspolicies are in force for the following vendors: Silverskills Private Limited (SPL)(approx.$1MM), National Tax Search, LLC (NTS) ($2MM), Covius Real EstateServices, LLC ($3MM), and Armada ($5MM).

 

**Y#2** = The only third-party vendor to whom this applies isNTS. PAR transferred to the vendor the process of paying property taxes to thelocal government taxing authorities. Payment is made only after review,authorization and transfer of funds is completed by PAR. Policies andprocedures are in place to monitor this vendor.

 

**Y#3** = SPL performs monthly P&I, Tax & Insurance,Reserve, and Suspense account compilations including review and approval of allself-reconciling bank accounts. PAR has procedures in place to review workperformed by SPL.

 

**Y#4** = As outlined in the PSAs, the primary responsibilityfor safeguarding all original documents (except Letters of Credit, which areheld by PAR) is with the named Document Custodian. The named Trustee hasoversight responsibility for the custodian, not the Servicer. However, to theextent that loans are secured by Letters of Credit or loans are modified orsome other credit action occurs which generates a new or revised loan document,then Servicer complies with this criteria.

 

**Y#5** = PAR's role related to additions, removals orsubstitutions to the asset pool only occurs after a decision is made to somodify the asset pool. The responsibility and any decisions related toadditions, removals or substitutions to the asset pool is with the Trustee,Issuer and related mortgage loan seller. PAR as Servicer has not experiencedany of these types of actions in its CMBS asset pools.

 

**Y#6** = There are currently no transactions during the yearthat applied to this servicing criteria within the Reg AB where PAR was namedthe special servicer.

 

**Y#7** = PAR does not report to investors, but reports only tothe master servicer and/or trustee.

 

**N/A**= Not applicable, as the criteria is not theresponsibility of the primary/master servicer or no event has occurred whichtriggered an action by the primary/master servicer.

 

 

**Exhibit B**

 

**List of Commercial Mortgage-BackedSecurity Transactions - RegAB Portfolio**

 

 

1.        DLJCommercial Mortgage Corp., Commercial Mortgage Pass-Through Certificates,Series 2000-CKP1

 

2.        MorganStanley Capital I Inc., Commercial Mortgage Pass-Through Certificates, Series2003-IQ5 ("MSCI 2003-IQ5")

 

3.        MorganStanley Capital I Inc., Commercial Mortgage Pass-Through Certificates, Series2003-IQ6 ("MSCI 2003-IQ6")

 

4.        BearStearns Commercial Mortgage Securities Inc., Commercial Mortgage Pass-ThroughCertificates, Series 2003-PWR2 ("BSCMS 2003-PWR2")

 

5.        BearStearns Commercial Mortgage Securities Inc., Commercial Mortgage Pass-ThroughCertificates, Series 2004-PWR3 ("BSCMS 2004-PWR3")

 

6.        BearSteams Commercial Mortgage Securities II Inc., Commercial Mortgage Pass-ThroughCertificates, Series 2004-PWR6 ("BSCMS 2004-PWR6")

 

7.        BearStearns Commercial Mortgage Securities Inc., Commercial Mortgage Pass-ThroughCertificates, Series 2005-PWR7 ("BSCMS 2005-PWR7")

 

8.        Bear StearnsCommercial Mortgage Securities Inc., Commercial Mortgage Pass-ThroughCertificates, Series 2005-PWR8 ("BSCMS 2005-PWR8")

 

9.        BearStearns Commercial Mortgage Securities Inc., Commercial Mortgage Pass-ThroughCertificates, Series 2005-PWR9 ("BSCMS 2005-PWR9")

 

10.     Bear Steams CommercialMortgage Securities II Inc., Commercial Mortgage Pass-Through Certificates,Series 2005-PWR10 ("BSCMS 2005-PWRl0")

 

11.     Merrill Lynch Mortgage Trust2006-C2, Commercial Mortgage Pass-Through Certificates, Series 2006-C2("MLMT 2006-C2")

 

12.     Bear Steams CommercialMortgage Securities II Inc., Commercial Mortgage Pass-Through Certificates,2006-PWR11 ("BSCMS 2006-PWR11")

 

13.     Bear Stearns CommercialMortgage Securities Inc., Commercial Mortgage Pass-Through Certificates,2006-PWR13 ("BSCMS 2006-PWR13")

 

14.     Bear Stearns CommercialMortgage Securities Inc., Commercial Mortgage Pass-Through Certificates,2006-PWR14 ("BSCMS 2006-PWR14")

 

15.     Morgan Stanley Capital IInc., Commercial Mortgage Pass-Through Certificates, Series 2007-IQ14("MSCI 2007-IQ14")

 

16.     Bear Stearns CommercialMortgage Securities Inc., Commercial Mortgage Pass-Through Certificates,2007-PWR16 ("BSCMS 2007-PWR16")

 

17.     Morgan Stanley Capital IInc., Commercial Mortgage Pass-Through Certificates, 2007-IQ15 ("MSCI2007-IQ15")

 

18.     Bear Stearns CommercialMortgage Securities Inc., Commercial Mortgage Pass-Through Certificates,2007-PWR17 ("BSCMS 2007-PWR17")

 

19.     WFRBS Commercial MortgageTrust 2012-C6, Commercial Mortgage Pass-Through Certificates, Series 2012-C6

 

20.     WFRBS Commercial MortgageTrust 2012-C7, Commercial Mortgage Pass-Through Certificates, Series 2012-C7

 

21.     WFRBS Commercial MortgageTrust 2012-C8, Commercial Mortgage Pass-Through Certificates, Series 2012-C8

 

22.     RBS Commercial FundingInc., Commercial Mortgage Pass-Through Certificates, Series 2012-C9

 

23.     WFRBS Commercial Mortgage Trust2012-C10, Commercial Mortgage Pass-Through Certificates, Series 2012-C10

 

24.     RBS Commercial FundingInc., Commercial Mortgage Pass-Through Certificates, Series 2013-C11

 

25.     WFRBS Commercial MortgageTrust 2013-C12, Commercial Mortgage Pass- Through Certificates, Series 2013-C12

 

26.     WFRBS Commercial MortgageTrust 2013-C13, Commercial Mortgage Pass-Through Certificates, Series 2013-C13

 

27.     WFRBS Commercial MortgageTrust 2013-C14, Commercial Mortgage Pass-Through Certificates, Series 2013-C14

 

28.     RBS Commercial FundingInc., Commercial Mortgage Pass-Through Certificates, Series 2013-C15

 

29.     WFRBS Commercial MortgageTrust 2013-C16, Commercial Mortgage Pass-Through Certificates, Series 2013-C16

 

30.     WFRBS Commercial MortgageTrust 2013-C17, Commercial Mortgage Pass-Through Certificates, Series 2013-C17

 

31.     WFRBS Commercial MortgageTrust 2013-C18, Commercial Mortgage Pass-Through Certificates, Series 2013-C18

 

32.     COMM 2013-CCRE13 MortgageTrust Commercial Mortgage Pass-Through Certificates

 

33.     COMM 2014-CCRE14 MortgageTrust Commercial Mortgage Pass-Through Certificates

 

34.     RBS Commercial FundingInc., Commercial Mortgage Pass-Through Certificates, Series 2014-C19 

 

35.     WFRBS Commercial MortgageTrust 2014-C20, Commercial Mortgage Pass-Through Certificates, Series 2014-C20

 

36.     RBS Commercial FundingInc., Commercial Mortgage Pass-Through Certificates, Series 2014-C21

 

37.     WFRBS Commercial Mortgage Trust2014-C22, Commercial Mortgage Pass-Through Certificates, Series 2014-C22

 

38.     RBS Commercial FundingInc., Commercial Mortgage Pass-Through Certificates, Series 2014-C23

 

39.     WFRBS Commercial MortgageTrust 2014-C24, Commercial Mortgage Pass-Through Certificates, Series 2014-C24

 

40.     Wells Fargo CommercialMortgage Trust 2014-LC18, Commercial Mortgage Pass-Through Certificates, Series2014-LC18

 

41.     RBS Commercial FundingInc., Commercial Mortgage Pass-Through Certificates, Series 2014-C25

 

42.     Wells Fargo CommercialMortgage Trust 2015-C26, Commercial Mortgage Pass-Through Certificates, Series2015-C26

 

43.     Wells Fargo CommercialMortgage Trust 2015-C27, Commercial Mortgage Pass-Through, Certificates, Series2015-C27

 

44.     Wells Fargo CommercialMortgage Trust 2015-C28, Commercial Mortgage Pass-Through Certificates, Series2015-C28

 

45.     Wells Fargo CommercialMortgage Trust 2015-SG1, Commercial Mortgage Pass-Through Certificates, Series2015-SG1

 

46.     Wells Fargo CommercialMortgage Trust 2015-C31, Commercial Mortgage Pass-Through Certificates, Series2015-C31

 

47.     CFCRE 2016-C3 MortgageTrust, Commercial Mortgage Pass-Through Certificates, Series 2016-C3

 

48.     SG Commercial MortgageSecurities Trust 2016-C5, Commercial Mortgage Pass-Through Certificates Series2016-C5