**Certification Regarding Compliance with ApplicableServicing Criteria**

** **

**To PricewaterhouseCoopers LLP**

 

1.       Prudential Asset Resources, Inc., (“PAR”)are responsible for assessing compliance by it with the servicing criteriaapplicable to PAR under paragraph (d) of Item 1122 of Regulation AB (the“Servicing Criteria”), as of and for the year ended December 31, 2018, as setforth in Exhibit A hereto in connection with all commercial mortgageloans serviced within the Platform during the applicable period;

 

2.       Except as set forth in paragraph 3 below,the Asserting Parties used the criteria set forth in paragraph (d) of Item 1122of Regulation AB to assess the compliance with the Servicing Criteria;

 

3.       The criteria described as not applicableon Exhibit A hereto are inapplicable to the Asserting Parties based onthe activities of PAR perform with respect to commercial mortgage securitiestransactions involving mortgage loans, also PAR has identified specificservicing criteria for which no transaction activity occurred;

 

4.       PAR has engaged certain vendors, which arenot deemed to be servicers as defined in Item 1101(j) of Regulation AB (the“Vendors”), to perform specific and limited activities or activities scripted bythe PAR as of and during the Reporting Period, and the PAR elects to takeresponsibility for assessing compliance with the Servicing Criteria or portionof the Servicing Criteria applicable to such Vendors as set forth in Exhibit Ahereto (such criteria, the “Applicable Servicing Criteria Performed byVendor(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, 2018 and for the Reporting Period.

 

5.       PAR has complied, in all materialrespects, with the Servicing Criteria as of and for the year ending December31, 2018; and

 

6.       PricewaterhouseCoopers LLP has issued anattestation report with respect to PAR's assessment of compliance with theServicing Criteria as of and for the year ended December 31, 2018, whichattestation report is included in Exhibit B attached hereto. ThisCertification is being provided to PricewaterhouseCoopers LLP in fulfillment ofits requirement for issuance of the final report.

 

February 22, 2019

 

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 institutedto 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 aremaintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |                                                        |   | 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 thetransaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                               |  

 

Y#1                                         |   |   |
|  

 

1122(d)(1)(v)                                                                           | Aggregation of information, as applicable, is****mathematically  accurate and the information conveyed accurately reflects theinformation.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |  

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 aforeign financial institution that meets  the requirements of Rule 13k-l(b)(l) of the Securities ExchangeAct.                                                                                                                                                                                                                                                                                                                      |  

 

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 daysspecified 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, suchreports (A) are prepared in accordance with timeframes and other terms  set forth in the transactionagreements;  (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 thetotal 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 transactionagreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |                                                        |   |  

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 loandocuments.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | 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 transactionagreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |  

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 businessdays after receipt, or such other  number of daysspecified 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 respecttoan obligor's unpaid  principalbalance.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |  

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 andapproved by authorized  personnel in accordance with the transaction agreements and related poolasset 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 bythe transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                           |  

 

 

Y#6                                 |   |   |
|  

 

 

 

 

 

1122(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 caseswhere delinquency is  deemed temporary (e.g., illness orunemployment).                                                                                                                                                                                          |  

 

 

 

 

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 thetransaction 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 relatedpenaltyorexpirationdates,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 dayspriortothesedates,orsuchother 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 madeonbehalfofanobligorarepaid from the  Servicer's funds and not chargedtotheobligor,unlessthelate paymentwasduetotheobligor'serror or  omission.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |  

 

Y                                           |  

 

Y#2 |   |
|  

 

 

 

1122(d)(4)(xiii)                                                        | Disbursementsmadeonbehalfofan  obligor are posted within two businessdaystotheobligor'srecords maintained by the Servicer, orsuch othernumberofdaysspecifiedinthe transactionagreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |  

 

Y                                           |   |   |
|  

 

1122(d)(4)(xiv)                                                                         | Delinquencies, charge-offs and uncollectibleaccountsarerecognized and  recorded in accordance with the transactionagreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |  

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#1**= Fidelitybond and errors and omissions policies in force for Prudential. In addition,fidelity bond and errors and omissions policies are in force for the followingvendors: Silverskills Private Limited (SPL) (approx.. $1MM), National TaxSearch, LLC (NTS) ($2MM) and Covius Real Estate Services, LLC ($3MM).

 

**Y#2**= The onlythird-party vendor to whom this applies is (NTS). PAR transferred to the vendorthe process of paying property taxes to the local government taxingauthorities. Payment is made only after review, authorization and transfer offunds is completed by PAR. Policies and procedures are in place to monitor thisvendor.

 

**Y#3**= (SPL)performs monthly P&I, Tax & Insurance, Reserve, and Suspense accountcompilations including review and approval of all self reconciling bankaccounts. PAR has procedures in place to review work performed by SPL.

 

**Y#4**= Asoutlined in the PSAs, the primary responsibility for safeguarding all originaldocuments (except Letters of Credit, which are held by PAR) is with the namedDocument Custodian. The named Trustee has oversight responsibility for thecustodian, not the Servicer. However, to the extent that loans are secured byLetters of Credit or loans are modified or some other credit action occurswhich generates a new or revised loan document, then Servicer complies withthiscriteria.

 

**Y#5**= PAR'srole related to additions, removals or substitutions to the asset pool onlyoccurs after a decision is made to so modify the asset pool. The responsibilityand any decisions related to additions, removalsor substitutions to the asset pool is with the Trustee, Issuerand related mortgage loan seller. PAR as Servicer has not experienced any ofthese types of actions in its CMBS asset pools.

 

**Y#6**= There are currently no transactionsduring the year that applied to this servicing criteria within the Reg AB wherePAR was named the 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 the responsibilityof the primary/master servicer or no event has occurred which triggered anaction by the primary/master servicer.

 

 

**EXHIBIT C**

** **

**Listof Commercial Mortgage-Backed Security Transactions - RegAB Portfolio**

** **

** **

1.       Morgan Stanley Capital I Inc., CommercialMortgage Pass-Through Certificates, Series2006-IQ12 (“MSCI 2006-IQ12”)

 

2.        Merrill Lynch Mortgage Trust 2006-C2,Commercial Mortgage Pass-Through Certificates, Series 2006-C2 (“MLMT2006-C2”)

 

3.       Bear Stearns CommercialMortgage Securities II Inc., Commercial Mortgage Pass-Through Certificates,2006-PWR11 (“BSCMS 2006-PWR11”)

 

4.       Bear Stearns CommercialMortgage Securities Inc., Commercial Mortgage Pass-Through Certificates,2006-PWR12 (“BSCMS2006-PWR12”)

 

5.       Bear Stearns CommercialMortgage Securities Inc., Commercial Mortgage Pass-Through Certificates,2006-PWR13 (“BSCMS2006-PWR13”)

 

6.       Bear Stearns Commercial MortgageSecurities Inc., Commercial Mortgage Pass-Through Certificates, 2006-PWR14 (“BSCMS2006-PWR14”)

 

7.       Bear Stearns CommercialMortgage Securities Inc., Commercial Mortgage Pass-Through Certificates,2007-PWR15 (“BSCMS2007-PWR15”)

 

8.       MorganStanleyCapitalIInc.,CommercialMortgagePass-ThroughCertificates,Series2007-IQ14 (“MSCI2007-IQ14”)

 

9.       Bear Stearns CommercialMortgage Securities Inc., Commercial Mortgage Pass-Through Certificates,2007-PWR16 (“BSCMS2007-PWR16”)

 

10.     Morgan Stanley Capital I Inc., CommercialMortgage Pass-Through Certificates, 2007-IQ15 (“MSCI2007-IQ15”)

 

11.     Bear Stearns Commercial MortgageSecurities Inc., Commercial Mortgage Pass-Through Certificates,2007-PWR17(“BSCMS2007-PWR17”)

 

12.     Bear Steams Commercial Mortgage Securities Inc., CommercialMortgage Pass-Through Certificates,2007-PWR18(“BSCMS2007-PWR18”)

 

13.    WFRBSCommercialMortgageTrust2012-C6,CommercialMortgagePass-ThroughCertificates, Series2012-C6

 

14.     WFRBSCommercialMortgageTrust2012-C7,CommercialMortgagePass-ThroughCertificates, Series2012-C7

 

15.    WFRBSCommercialMortgageTrust2012-C8,CommercialMortgagePass-ThroughCertificates, Series2012-C8

 

16.    RBS Commercial Funding Inc., CommercialMortgage Pass-Through Certificates, Series2012-C9

 

17.    WFRBS Commercial Mortgage Trust 2012-C10,Commercial Mortgage Pass-Through Certificates,Series2012-C10

 

18.    RBS Commercial Funding Inc., Commercial MortgagePass-Through Certificates, Series 2013-C11

 

19.    WFRBS Commercial Mortgage Trust 2013-C12,Commercial Mortgage Pass-Through Certificates, Series 2013-C12

 

20.    WFRBS Commercial Mortgage Trust 2013-C13,Commercial Mortgage Pass-Through Certificates, Series 2013-C13

 

21.    WFRBS Commercial Mortgage Trust 2013-C14,Commercial Mortgage Pass-Through Certificates, Series 2013-C14

 

22.     RBS Commercial Funding Inc., Commercial Mortgage Pass-ThroughCertificates, Series 2013- C15

 

23.    WFRBS Commercial Mortgage Trust 2013-C16,Commercial Mortgage Pass-Through Certificates, Series 2013-C16

 

24.    WFRBS Commercial Mortgage Trust 2013-C17,Commercial Mortgage Pass-Through Certificates, Series 2013-C17

 

25.    WFRBS Commercial Mortgage Trust 2013-C18,Commercial Mortgage Pass-Through Certificates, Series 2013-C18

 

26.    COMM2013-CCRE13MortgageTrustCommercialMortgagePass-ThroughCertificates

 

27.    COMM20I4-CCRE14MortgageTrustCommercialMortgagePass-ThroughCertificates

 

28.    RBS Commercial Funding Inc., CommercialMortgage Pass-Through Certificates, Series 2014-C19

 

29.     WFRBS Commercial Mortgage Trust 2014-C20, Commercial Mortgage Pass-ThroughCertificates,Series2014-C20

 

30.     RBS Commercial Funding Inc.,Commercial Mortgage Pass-Through Certificates, Series 2014-C21

 

31.     WFRBS Commercial Mortgage Trust 2014-C22, Commercial MortgagePass-Through Certificates, Series2014-C22

 

32.    RBSCommercialFundingInc.,CommercialMortgagePass-ThroughCertificates,Series2014-C23

 

33.    WFRBS Commercial Mortgage Trust 2014-C24,Commercial Mortgage Pass-Through Certificates,Series2014-C24

 

34.    Wells Fargo Commercial Mortgage Trust 2014-LC18,Commercial Mortgage Pass-Through Certificates, Series 2014-LC18

 

35.     RBS Commercial Funding Inc.,Commercial Mortgage Pass-Through Certificates, Series 2014- C25

 

36.     Wells Fargo Commercial Mortgage Trust 2015-C26,Commercial Mortgage Pass-Through Certificates, Series 2015-C26

 

37.     Wells Fargo Commercial Mortgage Trust2015-C27, Commercial Mortgage Pass-Through Certificates, Series2015-C27

 

38.     Wells Fargo Commercial Mortgage Trust2015-C28, Commercial Mortgage Pass-Through Certificates, Series2015-C28

 

39.    Wells Fargo Commercial Mortgage Trust2015-SG1, Commercial Mortgage Pass-Through Certificates, Series 2015-SG1

 

40.     Wells Fargo Commercial Mortgage Trust 2015-C31, Commercial MortgagePass-Through Certificates, Series2015-C31

 

41.     CFCRE 2016-C3 Mortgage Trust, Commercial MortgagePass-Through Certificates, Series 2016- C3

 

42.     SG Commercial Mortgage SecuritiesTrust 2016-C5, Commercial Mortgage Pass-Through Certificates Series2016-C5