**Report on Assessment ofCompliance with SEC Regulation AB**

**Servicing Criteria asPrimary Servicer**

 

Berkadia Commercial MortgageLLC (“Berkadia”) is responsible for assessing compliance, as of andfor the year ended December 31, 2016 (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.This assertion includes all commercial mortgage loans sold in publicsecuritizations from the period January 1, 2016 through December 31, 2016 forwhich Berkadia served as primary servicer (the “Platform”). 

 

Berkadia has concluded thatthe criteria are applicable as shown below (indicated by X) to the primaryservicing of the loans in the Platform:

 

| **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 transection 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 wasresponsible for this criteria in its role as Primary Servicer. 

(1)  Per servicing and pooling agreements, thecriteria does not apply to the role of Primary Servicer. 

(2)  Vendor(s), for which Berkadia is the ResponsibleParty, contributes to the servicing activities for this criteria.

 

 

The Servicing Criteria, aftergiving effect to the foregoing exclusions, are referred to as the“Applicable Servicing Criteria”. 

 

Berkadia utilizes vendors tosupport its servicing operations, including the use of a commercial tax servicewhich supports its assertions under 1122(d)(4)(xi) through (xiii) and the useof a lien filing firm to support its assertion under 1122(d)(4)(i). This vendoractivity contributes to the servicing activities to which Berkadia isasserting. In all cases, the vendors’ activities are limited, andBerkadia assumes responsibility for the 1122 assessment for these vendoractivities. These vendors do not fit the definition of servicer under Item1101(j), and Berkadia employs policies and procedures designed to provideassurance that the vendors’ activities comply with the ApplicableServicing Criteria to such vendors. 

 

For the Reporting Period, Berkadiahas assessed its compliance with the Applicable Servicing Criteria for thePlatform and has concluded that its servicing operation has complied, in allmaterial respects, with the Applicable Servicing Criteria. 

 

Grant Thornton LLP, anindependent registered public accounting firm, has issued an attestation reporton management’s assertion of compliance with the Applicable ServicingCriteria. 

 

 

Berkadia Commercial MortgageLLC

 

 

/s/ Mark E. McCool

Mark E. McCool

Executive Vice President

Berkadia Commercial MortgageLLC