Exhibit 33.1

Management Assessment

Management of the Cenlar FSB (Cenlar or the Bank) is responsible for assessing compliance with the applicable servicing criteria set forth in Item 1122(d) of Regulation AB of the Securities and Exchange Commission relating to the servicing of residential mortgage loans (the Platform), except for servicing criteria 1122 (d)(1)(iii), 1122(d)(3)(i)(b)-(c), 1122(d)(4)(i), 1122(d)(4)(ii) and 1122(d)(4)(xi), as of and for the year ended December 31, 2019. These criteria are not applicable to the Bank because the Bank does not perform activities with respect to the Platform relating to these criteria. Appendix A identifies the individual asset-backed transactions and securities defined by management as constituting the Platform. With respect to servicing criterion 1122(d)(2)(i), management has engaged various vendors to perform the activities required by these servicing criteria, has determined that these vendors are not considered a “servicer'' as defined in Item 1101(j) of Regulation AB, and the Bank has elected to take responsibility for assessing compliance with the applicable servicing criteria applicable to each vendor as permitted by Regulation AB Compliance and Disclosure Interpretations of the Division of Corporation Finance, Section 200.06, “Vendors Engaged by Servicers” (C&DI 200.06). As permitted by C&DI 200.06, the Bank asserts that it has policies and procedures in place, designed and operating effectively, to provide reasonable assurance that the vendors’ activities comply in all material respects with servicing criteria applicable to each vendor. The Bank is solely responsible for determining that it meets the SEC requirements to apply C&DI 200.06 for the vendors and related criteria as described in our assertion.

The Bank's management has assessed the Bank's compliance with the applicable servicing criteria as of and for the year ended December 31, 2019. In making this assessment, management used the criteria set forth by the Securities and Exchange Commission in paragraph (d) of Item 1122 of Regulation AB.

Based on such assessment, management has concluded that, as of and for the year ended December 31, 2019, the Bank has complied in all material respects with the servicing criteria, except as set forth in the column titled “Inapplicable Servicing Criteria on Appendix B, set forth in Item 1122(d) of Regulation AB of the Securities and Exchange Commission relating to the servicing of the Platform.

Ernst & Young LLP, an independent registered public accounting firm, has issued an attestation report with respect to management's assessment of compliance with the applicable servicing criteria as of and for the year ended December 31, 2019.

 

/s/ Gregory S. Tornquist

Gregory S. Tornquist

Chairman of the Board and Chief Executive Officer

 

|                                                                                                        |                                                                                          |
|--------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------|
| /s/ Stephen W. Gozdan

Stephen W. Gozdan

Executive Vice President and Chief Financial Officer

  | /s/ Robert Lux

Robert Lux

Executive Vice President and Chief Operating Officer

  |

March 5, 2020

Overnight Mail:  Cenlar FSB | 425 Phillips Boulevard | Ewing, NJ 08618

----

Appendix A

Securities Covered in Cenlar FSB’s REG AB Attestation

|          |                                                   |                |                                    |
|----------|---------------------------------------------------|----------------|------------------------------------|
| Investor | Servicer                                          | Security       | * Period Subserviced by Cenlar FSB |
| RD0      | Redwood Residential Acquisition Corp              | SEMT 2014-4    | 1/1 to 12/31/19                    |
| RD1      | Redwood Residential Acquisition Corp              | SEMT 2015-1    | 1/1 to 12/31/19                    |
| RD2      | Redwood Residential Acquisition Corp              | SEMT 2015-2    | 1/1 to 12/31/19                    |
| RD5      | Redwood Residential Acquisition Corp              | SEMT 2015-3    | 1/1 to 12/31/19                    |
| RS8      | Redwood Residential Acquisition Corp              | SEMT 2015-4    | 1/1 to 12/31/19                    |
| RT4      | Redwood Residential Acquisition Corp              | SEMT 2014-2    | 1/1 to 12/31/19                    |
| RT5      | Redwood Residential Acquisition Corp              | SEMT 2014-3    | 1/1 to 12/31/19                    |
| RV1      | Redwood Residential Acquisition Corp/UBS Bank USA | SEMT 2016-1    | 1/1 to 12/31/19                    |
| RV2      | Redwood Residential Acquisition Corp/UBS Bank USA | SEMT 2016-2    | 1/1 to 12/31/19                    |
| RV3      | Redwood Residential Acquisition Corp/UBS Bank USA | SEMT 2016-3    | 1/1 to 12/31/19                    |
| RV4      | Redwood Residential Acquisition Corp              | SEMT 2017-1    | 1/1 to 12/31/19                    |
| RV5      | Redwood Residential Acquisition Corp              | SEMT 2017-2    | 1/1 to 12/31/19                    |
| RW8      | Redwood Residential Acquisition Corp              | SEMT 2013-8    | 1/1 to 12/31/19                    |
| RX0      | Redwood Residential Acquisition Corp              | SEMT 2013-9    | 1/1 to 12/31/19                    |
| RX1      | Redwood Residential Acquisition Corp              | SEMT 2013-10   | 1/1 to 12/31/19                    |
| RX2      | Redwood Residential Acquisition Corp              | SEMT 2013-11   | 1/1 to 12/31/19                    |
| RX3      | Redwood Residential Acquisition Corp              | SEMT 2013-12   | 1/1 to 12/31/19                    |
| RX8      | Redwood Residential Acquisition Corp              | SEMT 2014-1    | 1/1 to 12/31/19                    |
| SF7      | SOFI Lending Corp                                 | SFPMT 2016-1   | 1/1 to 12/31/19                    |
| UB1      | UBS Bank USA                                      | SEMT 2015-4    | 1/1 to 12/31/19                    |
| UB2      | Redwood Residential Acquisition Corp/UBS Bank USA | SEMT 2016-1    | 1/1 to 12/31/19                    |
| UB4      | Redwood Residential Acquisition Corp/UBS Bank USA | SEMT 2016-2    | 1/1 to 12/31/19                    |
| UB5      | Redwood Residential Acquisition Corp/UBS Bank USA | SEMT 2016-3    | 1/1 to 12/31/19                    |
| A54      | New York Mortgage Company                         | NYMC 2006-1    | 1/1 to 12/31/19                    |
| AG9      | AIG Home Loans                                    | PSMC 2018-1    | 1/1 to 12/31/19                    |
| AG2      | AIG Home Loans                                    | PSMC 2018-2    | 1/1 to 12/31/19                    |
| AG3      | AIG Home Loans                                    | PSMC 2018-3    | 1/1 to 12/31/19                    |
| AG4      | AIG Home Loans                                    | PSMC 2018-4    | 1/1 to 12/31/19                    |
| AG7      | AIG Home Loans                                    | CSMC 2017-HL1  | 1/1 to 12/31/19                    |
| AG8      | AIG Home Loans                                    | CSMC 2017-HL2  | 1/1 to 12/31/19                    |
| C69      | LoanDepot.com LLC                                 | MMCA 2018-MTG1 | 1/1 to 12/31/19                    |

----

Appendix A

Securities Covered in Cenlar FSB’s REG AB Attestation

|     |                                                                                         |                 |                 |
|-----|-----------------------------------------------------------------------------------------|-----------------|-----------------|
| LD2 | LoanDepot.com LLC                                                                       | MMCA 2018-MTG2  | 1/1 to 12/31/19 |
| FK3 | FirstKey Mortgage, LLC                                                                  | FKMT 2014-1     | 1/1 to 12/31/19 |
| FY5 | FirstKey Mortgage, LLC                                                                  | FKMT 2015-1     | 1/1 to 12/31/19 |
| H06 | Redwood Residential Acquisition Corp                                                    | SEMT 2012-1     | 1/1 to 5/31/19  |
| K06 | Redwood Residential Acquisition Corp                                                    | SEMT 2012-2     | 1/1 to 12/31/19 |
| L06 | Redwood Residential Acquisition Corp                                                    | SEMT 2012-3     | 1/1 to 12/31/19 |
| RW0 | Redwood Residential Acquisition Corp                                                    | SEMT 2012-6     | 1/1 to 12/31/19 |
| RW1 | Redwood Residential Acquisition Corp                                                    | SEMT 2013-1     | 1/1 to 12/31/19 |
| RW2 | Redwood Residential Acquisition Corp                                                    | SEMT 2013-2     | 1/1 to 12/31/19 |
| RW3 | Redwood Residential Acquisition Corp                                                    | SEMT 2013-3     | 1/1 to 12/31/19 |
| RW4 | Redwood Residential Acquisition Corp                                                    | SEMT 2013-4     | 1/1 to 12/31/19 |
| RW5 | Redwood Residential Acquisition Corp                                                    | SEMT 2013-5     | 1/1 to 12/31/19 |
| RW6 | Redwood Residential Acquisition Corp                                                    | SEMT 2013-6     | 1/1 to 12/31/19 |
| RW7 | Redwood Residential Acquisition Corp                                                    | SEMT 2013-7     | 1/1 to 12/31/19 |
| Y06 | Redwood Residential Acquisition Corp                                                    | SEMT 2012-5     | 1/1 to 12/31/19 |
| Z06 | Redwood Residential Acquisition Corp                                                    | SEMT 2012-4     | 1/1 to 12/31/19 |
| G52 | Wells Fargo (previous client Orchid Island TRS, LLC fka Opteum Financial Services, LLC) | OMAC 06-1       | 1/1 to 12/31/19 |
| H52 | Wells Fargo (previous client Orchid Island TRS, LLC fka Opteum Financial Services, LLC) | OMAC 2006-2     | 1/1 to 12/31/19 |
| J52 | Wells Fargo (previous client Orchid Island TRS, LLC fka Opteum Financial Services, LLC) | BAFC 2006-H     | 1/1 to 12/31/19 |
| K52 | Wells Fargo (previous client Orchid Island TRS, LLC fka Opteum Financial Services, LLC) | CMLTI 2006-FX1  | 1/1 to 12/31/19 |
| P52 | Wells Fargo (previous client Orchid Island TRS, LLC fka Opteum Financial Services, LLC) | CMLTI 2007-OPX1 | 1/1 to 12/31/19 |
| TB5 | Matrix Financial Services Corporation-Two

Harbors                                      | ABMT 2016-2     | 1/1 to 12/31/19 |
| TB6 | Matrix Financial Services Corporation-Two

Harbors                                      | ABMT 2016-1     | 1/1 to 12/31/19 |
| TB7 | Matrix Financial Services Corporation-Two

Harbors                                      | ABMT 2015-7     | 1/1 to 12/31/19 |
| TH3 | Matrix Financial Services Corporation-Two

Harbors                                      | ABMT 2014-3     | 1/1 to 12/31/19 |

 

 

----

Appendix A

Securities Covered in Cenlar FSB’s REG AB Attestation

|     |                                                    |               |                 |
|-----|----------------------------------------------------|---------------|-----------------|
| TH4 | Matrix Financial Services Corporation-Two

Harbors | ABMT 2014-2   | 1/1 to 12/31/19 |
| TH5 | Matrix Financial Services Corporation-Two

Harbors | ABMT 2014-1   | 1/1 to 12/31/19 |
| TH6 | Matrix Financial Services Corporation-Two

Harbors | ABMT 2013-1   | 1/1 to 12/31/19 |
| TR3 | Matrix Financial Services Corporation-Two

Harbors | ABMT 2016-3   | 1/1 to 12/31/19 |
| TW1 | Matrix Financial Services Corporation-Two

Harbors | ABMT 2015-1   | 1/1 to 12/31/19 |
| TW2 | Matrix Financial Services Corporation-Two

Harbors | ABMT 2015-2   | 1/1 to 12/31/19 |
| TW3 | Matrix Financial Services Corporation-Two

Harbors | ABMT 2015-3   | 1/1 to 12/31/19 |
| TW4 | Matrix Financial Services Corporation-Two

Harbors | ABMT 2015-4   | 1/1 to 12/31/19 |
| TW5 | Matrix Financial Services Corporation-Two

Harbors | ABMT 2015-5   | 1/1 to 12/31/19 |
| TW6 | Matrix Financial Services Corporation-Two

Harbors | ABMT 2015-6   | 1/1 to 12/31/19 |
| WF3 | Lydian Bank/Wells Fargo                            | GSR 2006 AR1  | 1/1 to 12/31/19 |
| WF4 | Lydian Bank/Wells Fargo                            | GSR 2006 AR2  | 1/1 to 12/31/19 |
| BU0 | UBS Bank USA                                       | SEMT 2018-CH4 | 1/1 to 12/31/19 |
| BU2 | UBS Bank USA                                       | SEMT 2018-8   | 1/1 to 12/31/19 |
| U55 | Amegy                                              | 2001-RS2      | 1/1 to 12/31/19 |
| M80 | CITIMORTGAGE                                       | 2001-SB1      | 1/1 to 12/31/19 |
| U55 | Amegy                                              | 2002-WH32     | 1/1 to 12/31/19 |
| U55 | Amegy                                              | 2003-WH18     | 1/1 to 12/31/19 |
| U55 | Amegy                                              | 2005-WH3      | 1/1 to 12/31/19 |
| 131 | Cenlar FSB                                         | ARMT 2004-4   | 1/1 to 12/31/19 |
| 080 | Cenlar FSB                                         | CSFB 2003-25  | 1/1 to 12/31/19 |
| 078 | Cenlar FSB                                         | CSFB 2003-27  | 1/1 to 12/31/19 |
| 079 | Cenlar FSB                                         | CSFB 2004-4   | 1/1 to 12/31/19 |
| 128 | Cenlar FSB                                         | CSFB 2004-7   | 1/1 to 12/31/19 |
| E60 | Lydian Bank/Wells Fargo                            | CSFB 2004-AR3 | 1/1 to 12/31/19 |
| WF1 | Lydian Bank/Wells Fargo                            | CSFB 2004-AR4 | 1/1 to 12/31/19 |
| 076 | Cenlar FSB                                         | CSFB 2004-AR5 | 1/1 to 12/31/19 |
| 129 | Cenlar FSB                                         | CSFB 2004-AR8 | 1/1 to 12/31/19 |
| 120 | Cenlar FSB                                         | CSFB 2005-1   | 1/1 to 12/31/19 |

 

 

----

Appendix A

Securities Covered in Cenlar FSB’s REG AB Attestation

|             |                                                                                          |                 |                 |
|-------------|------------------------------------------------------------------------------------------|-----------------|-----------------|
| J60         | Lydian Bank/Wells Fargo                                                                  | GSR 2005-AR3    | 1/1 to 12/31/19 |
| WF2         | Lydian Bank/Wells Fargo                                                                  | GSR 2005-AR5    | 1/1 to 12/31/19 |
| H60         | HarborView/Wells                                                                         | HBV 2003-2      | 1/1 to 12/31/19 |
| G60         | HarborView/Wells                                                                         | HBV 2007-4      | 1/1 to 12/31/19 |
| H30         | Wells Fargo (previous client Orchid Island TRS, LLC fka Opteum Financial Services,

LLC) | HMAC 2004-6     | 1/1 to 12/31/19 |
| GP2         | Pingora Loan Servicing, LLC                                                              | JPMMT 2014-5    | 1/1 to 12/31/19 |
| GP0         | Pingora Loan Servicing, LLC                                                              | JPMMT 2014-IVR3 | 1/1 to 12/31/19 |
| PN7         | Pingora Loan Servicing, LLC                                                              | JPMMT 2014-IVR3 | 1/1 to 12/31/19 |
| GP1         | Pingora Loan Servicing, LLC                                                              | JPMMT 2014-OAK4 | 1/1 to 12/31/19 |
| PN9         | Pingora Loan Servicing, LLC                                                              | JPMMT 2014-OAK4 | 1/1 to 12/31/19 |
| GP9         | Pingora Loan Servicing, LLC                                                              | JPMMT 2015-3    | 1/1 to 12/31/19 |
| PM2         | Pingora Loan Servicing, LLC                                                              | JPMMT 2015-4    | 1/1 to 12/31/19 |
| PV9         | Pingora Loan Servicing, LLC                                                              | JPMMT 2015-5    | 1/1 to 12/31/19 |
| Y59         | LoanDepot.com LLC                                                                        | JPMMT 2017-6    | 1/1 to 12/31/19 |
| C59         | LoanDepot.com LLC                                                                        | JPMMT 2018-1    | 1/1 to 12/31/19 |
| D69         | LoanDepot.com LLC                                                                        | JPMMT 2018-4    | 1/1 to 12/31/19 |
| LD5         | LoanDepot.com LLC                                                                        | JPMMT 2018-5    | 1/1 to 12/31/19 |
| LD6         | LoanDepot.com LLC                                                                        | JPMMT 2018-6    | 1/1 to 12/31/19 |
| LD7         | LoanDepot.com LLC                                                                        | JPMMT 2018-8    | 1/1 to 12/31/19 |
| LD4         | LoanDepot.com LLC                                                                        | JPMMT 2018-LTV1 | 1/1 to 12/31/19 |
| 142 (Cat 1) | Cenlar FSB                                                                               | MALT 2003-2     | 1/1 to 12/31/19 |
| WF7         | Lydian Bank/Wells Fargo                                                                  | MALT 2004-5     | 1/1 to 12/31/19 |
| WF8         | Lydian Bank/Wells Fargo                                                                  | MALT 2004-6     | 1/1 to 12/31/19 |
| WF9         | Lydian Bank/Wells Fargo                                                                  | MALT 2004-9     | 1/1 to 12/31/19 |
| 142 (Cat 3) | Cenlar FSB                                                                               | MARM 2003-2     | 1/1 to 12/31/19 |
| U60         | Lydian Bank/Wells Fargo                                                                  | MARM 2003-2     | 1/1 to 12/31/19 |
| WF5         | Lydian Bank/Wells Fargo                                                                  | MARM 2004-1     | 1/1 to 12/31/19 |
| 088         | Cenlar FSB                                                                               | MARM 2004-4     | 1/1 to 12/31/19 |
| WF6         | Lydian Bank/Wells Fargo                                                                  | MARM 2004-5     | 1/1 to 12/31/19 |
| 030         | Cenlar FSB                                                                               | MASTR 2003-3    | 1/1 to 12/31/19 |
| 135         | Cenlar FSB                                                                               | MASTR 2004-10   | 1/1 to 12/31/19 |
| D94         | New York Mortgage                                                                        | NYMT 2005-1     | 1/1 to 12/31/19 |
| G94         | New York Mortgage                                                                        | NYMT 2005-2     | 1/1 to 12/31/19 |
| A94         | New York Mortgage                                                                        | NYMT 2005-3     | 1/1 to 12/31/19 |
| B52         | Wells Fargo (previous client Orchid Island TRS, LLC fka Opteum Financial Services,

LLC) | OMAC 2005-1     | 1/1 to 12/31/19 |

 

 

----

Appendix A

Securities Covered in Cenlar FSB’s REG AB Attestation

|     |                                                                                          |                              |                     |
|-----|------------------------------------------------------------------------------------------|------------------------------|---------------------|
| D52 | Wells Fargo (previous client Orchid Island TRS, LLC fka Opteum Financial Services,

LLC) | OMAC 2005-3                  | 1/1 to 12/31/19     |
| E52 | Wells Fargo (previous client Orchid Island TRS, LLC fka Opteum Financial Services,

LLC) | OMAC 2005-4                  | 1/1 to 12/31/19     |
| F52 | Wells Fargo (previous client Orchid Island TRS, LLC fka Opteum Financial Services,

LLC) | OPTMAC05-5                   | 1/1 to 12/31/19     |
| LS2 | Liberty Savings Bank                                                                     | PRIME 2003-CL1               | 1/1 to 12/31/19     |
| LS1 | Liberty Savings Bank                                                                     | PRIME 2004-CL2               | 1/1 to 12/31/19     |
| S11 | Bethpage Federal Credit Union                                                            | SEMT 2013-2                  | 1/1 to 12/31/19     |
| R56 | Goldman Sachs                                                                            | WMC 1989-1                   | 1/1 to 5/31/19      |
| Q56 | Goldman Sachs                                                                            | WMC 1989-1R                  | 1/1 to 1/31/19      |
| M73 | CRESCENT MORTGAGE COMPANY                                                                |                         | 1/1 to 12/31/19     |
| LB7 | Liberty Savings                                                                          | REMIC 1997-6                 | 1/1 to 12/31/19     |
| T11 | Bethpage Federal Credit Union                                                            | SEMT 2013-10                 | 1/1 to 12/31/19     |
| R11 | Bethpage Federal Credit Union                                                            | SEMT 2013-11                 | 1/1 to 12/31/19     |
| BP1 | Bethpage Federal Credit Union                                                            | SEMT 2014-1                  | 1/1 to 12/31/19     |
| BP2 | Bethpage Federal Credit Union                                                            | SEMT 2015-2                  | 1/1 to 12/31/19     |
| R95 | Baxter Credit Union                                                                      | SEMT 2015-2                  | 1/1 to 12/31/19     |
| Q95 | Baxter Credit Union                                                                      | SEMT 2015-3                  | 1/1 to 12/31/19     |
| P95 | Baxter Credit Union                                                                      | SEMT 2016-3                  | 1/1 to 12/31/19     |
| AD9 | AmeriHome                                                                                | JPMMT 2018-8                 | 1/1 to 12/31/19     |
| TD8 | AmeriHome                                                                                | JPMMT 2018-6                 | 1/1 to 12/31/19     |
| A79 | LoanDepot.com LLC                                                                        | GSMBS 2019-PJ1               | 3/1 to 12/31/19     |
| AG5 | AIG Home Loans                                                                           | PSMC 2019-1                  | 6/1 to 12/31/19     |
| AG6 | AIG Home Loans                                                                           | PSMC 2019-2                  | 10/1 to 12/31/19    |
| HB9 | Homebridge                                                                               | AOMT 2019-1                  | 1/1/19 to 12/31/19  |
| HM6 | Homebridge                                                                               | AOMT 2019-2                  | 3/1/19 to 12/31/19  |
| J06 | Redwood Trust                                                                            | SEMT 2019-2                  | 5/1/19 to 12/31/19  |
| MH1 | Amerihome                                                                                | JPMMT 2019-8                 | 10/1/19 to 12/31/19 |
| RA3 | Amerihome                                                                                | JPMMT 2019-INV2              | 9/1/19 to 10/31/19  |
| RA5 | Amerihome                                                                                | CIM TRUST 2019-INV3          | 9/1/19 to 12/31/19  |
| RA6 | Amerihome                                                                                | ATHENE ASSET MANAGEMENT-ACRA | 8/1/19 to 12/31/19  |

 

 

----

Appendix A

Securities Covered in Cenlar FSB’s REG AB Attestation

|     |                                               |                                     |                      |
|-----|-----------------------------------------------|-------------------------------------|----------------------|
| RA7 | Amerihome                                     | ATHENE ASSET MANAGEMENT- DIAMOND    | 8/1/19 to 12/31/19   |
| RA8 | Amerihome                                     | BOFA CIM TRUST 2019-INV2            | 4/1/19 to 12/31/19   |
| RA9 | Amerihome                                     | JPMMT 2019-INV1                     | 5/1/19 to 12/31/19   |
| RH7 | Amerihome                                     | JPMMT 2019-3                        | 4/1/19 to 12/31/19   |
| RH8 | Amerihome                                     | JPMMT 2019-2                        | 3/1/19 to 12/31/19   |
| RH9 | Amerihome                                     | JPMMT 2019-1                        | 1/1/19 to 12/31/19   |
| SH0 | Morgan Stanley Mortgage Capital Holdings

LLC | SEMT 2018-2                         | 5/1/19 to 12/31/19   |
| SH1 | Morgan Stanley Mortgage Capital Holdings

LLC | SEMT 2018-CH1                       | 5/1/19 to 12/31/19   |
| SH2 | Morgan Stanley Mortgage Capital Holdings

LLC | SEMT 2014-2                         | 5/1/19 to 12/31/19   |
| SM2 | Morgan Stanley Mortgage Capital Holdings

LLC | CATHAY BANK                         | 5/1/19 to 12/31/19   |
| SM3 | Morgan Stanley Mortgage Capital Holdings

LLC | MSMCH, NA                           | 5/1/19 to 12/31/19   |
| SM4 | Morgan Stanley Mortgage Capital Holdings

LLC | SEMT 2015-2                         | 5/1/19 to 12/31/19   |
| TE9 | Amerihome                                     | BANK OF AMERICA WL

Holding - Jumbo | 4/1/19 to 12/31/19   |
| TM0 | AIG Home Loans                                | PSMC 2019-3                         | 10/1/19 to 12/31/19  |
| UF1 | United Shore                                  | JP MORGAN CHASE                     | 9/1/19 to 12/31/19   |
| UF2 | United Shore                                  | JPMMT 2019-INV2                     | 9/1/19 to 12/31/19   |
| UF3 | United Shore                                  | JPMMT 2019-7                        | 9/1/19 to 12/31/19   |
| UF4 | United Shore                                  | JPMMT 2019-8                        | 10/1/19 to 12/31/19  |
| UF6 | United Shore                                  | JPMMT-LTV3                          | 10/1/19 to 12/31/19  |
| UF7 | United Shore                                  | JPMMT 2019-9                        | 11/30/19 to 12/31/19 |
| TL1 | LoanDepot.com LLC                             | JPMMT 2019-9                        | 11/30/19 to 12/31/19 |
| MH3 | Amerihome                                     | BAML 2019-CRA                       | 12/1/19 to 12/31/19  |
| TL0 | LoanDepot.com LLC                             | Mid-First EBO                       | 1/1/19 to 12/19      |
| TD9 | Amerihome                                     | JPM holding Inv                     | 10/1/19 to 12/31/19  |
| LD3 | LoanDepot.com LLC                             | Bank United EBO                     | 8/1/19 to 12/31/19   |
| UF8 | United Shore                                  | JPMMT 2019-INV3                     | 12/1/19 to 12/31/19  |
| PX4 | CitiMortgage                                  | First County - whole Loans          | 12/1/19 to 12/31/19  |
| PX8 | CitiMortgage                                  | Webster Bank - whole loans          | 11/1/19 to 12/31/19  |
| PX3 | CitiMortgage                                  | Peoples Bank - whole loans          | 12/1/19 to 12/31/19  |

 

 

----

Appendix A

Securities Covered in Cenlar FSB’s REG AB Attestation

|     |              |                                                  |                      |
|-----|--------------|--------------------------------------------------|----------------------|
| N80 | CitiMortgage | SASCO 2002 AL1                                   | 1/1 to 12/31/19      |
| PX6 | CitiMortgage | CARVER FEDERAL SAVINGS BANK - whole loans        | 6/1/19 to 12/31/19   |
| PX7 | CitiMortgage | First National Bank of Long Island - whole loans | 10/31/19 to 12/31/19 |
| CQ2 | CitiMortgage | 1993-WL-7                                        | 1/1 to 12/31/19      |
| DS2 | CitiMortgage | WAMU 5/30/2001. Pool #

012275                   | 1/1 to 12/31/19      |
| DS9 | CitiMortgage | CHASE                                            | 1/1 to 12/31/19      |
| GX7 | CitiMortgage | CHASE 12/20/2001                                 | 1/1 to 12/31/19      |

 

 

----

Appendix B

|                                    |                                                                                                                                                                                                                                                                   |                                 |                                                                               |                                                                                     |                                                                                             |
|------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------|-------------------------------------------------------------------------------|-------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------|
| SERVICING CRITERIA                 |
| Reference                          | Criteria                                                                                                                                                                                                                                                          | Applicable: Performed by Cenlar | Applicable: Performed by Vendor (s) for which Cenlar is the responsible party | Inapplicable: Performed by Vendor (s) For which Cenlar is NOT the responsible party | Inapplicable: NOT performed by Cenlar or by subservicer(s) or vendor (s) retained by Cenlar |
| 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.                                                                                                          | X                               |                                                                          |                                                                                |                                                                                        |
| 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.                                                        | X                               |                                                                          |                                                                                |                                                                                        |
| 1122(d)(1)(iii)                    | Any requirements in the transaction agreements to maintain a back-up servicer for the pool assets are maintained.                                                                                                                                                 |                            |                                                                          |                                                                                | X                                                                                           |
| 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. | X                               |                                                                          |                                                                                |                                                                                        |
| 1122(d)(1)(v)                      | Aggregation of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information.                                                                                                                           | X                               |                                                                          |                                                                                |                                                                                        |
| Cash Collection and Administration |
| 1122(d)(2)(i)                      | Payments on pool assets 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.                     | X                               | X1                                                                            |                                                                                |                                                                                        |
| 1122(d)(2)(ii)                     | Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.                                                                                                                                             | X                               |                                                                          |                                                                                |                                                                                        |
| 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.                                         | X                               |                                                                          |                                                                                |                                                                                        |
| 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.             | X2                              |                                                                          |                                                                                |                                                                                        |

 

1 Cenlar uses a third-party provider (Excela Technologies/TransCentra, Inc) for processing checks received through its lockbox and Ventanex, a web-based service provider used for borrowers to make payments. Cenlar has elected to take responsibility for assessing compliance with the servicing criterion as permitted by Regulation AB Compliance and Disclosure Interpretations of the Division of Corporation Finance 200.06, “Vendors Engaged by Servicers”

2 Cenlar is required to comply with these criteria in the event that these criteria would occur. There were no instances of occurrence in our Applicable Reporting Period.

 

 

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| SERVICING CRITERIA                 |
| Reference                          | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | Applicable: Performed by Cenlar | Applicable: Performed by Vendor (s) for which Cenlar is the responsible party | Inapplicable: Performed by Vendor (s) For which Cenlar is NOT the responsible party | Inapplicable: NOT performed by Cenlar or by subservicer(s) or vendor (s) retained by Cenlar |
| 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-1(b)(1) of the Securities Exchange Act.                                                                                                                                                                                                                                                                                                          | X                               |                                                                          |                                                                                |                                                                                        |
| 1122(d)(2)(vi)                     | Unissued checks are safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | X                               |                                                                          |                                                                                |                                                                                        |
| 1122(d)(2)(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 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. | X                               |                                                                          |                                                                                |                                                                                        |
| 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 pool assets serviced by the Servicer.                                  | X3                              |                                                                          |                                                                                |                                                                                        |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | X                               |                                                                          |                                                                                |                                                                                        |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | X                               |                                                                          |                                                                                |                                                                                        |
| 1122(d)(3)(iv)                     | Amounts remitted to investors per the investor reports agree with cancelled checks, or other form of                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | X                               |                                                                          |                                                                                |                                                                                        |

 

3 Cenlar’s responsibility in criterion 1122(d)(3)(i)(A) is for providing information to the master servicer in timeframes set forth in the transaction documents. Cenlar is not responsible for criteria 1122(d)(3)(i)(B) and 1122(d)(3)(i)(C). Cenlar is responsible for agreeing the unpaid principal balance to the records of the master servicer as listed in criteria 1122(d)(3)(i)(D).

 

 

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|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                 |                                                                               |                                                                                     |                                                                                             |
| SERVICING CRITERIA        |
| Reference                 | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | Applicable: Performed by Cenlar | Applicable: Performed by Vendor (s) for which Cenlar is the responsible party | Inapplicable: Performed by Vendor (s) For which Cenlar is NOT the responsible party | Inapplicable: NOT performed by Cenlar or by subservicer(s) or vendor (s) retained by Cenlar |
|                      | payment, or custodial bank statements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |                            |                                                                          |                                                                                |                                                                                        |
| Pool Asset Administration |
| 1122(d)(4)(i)             | Collateral or security on pool assets is maintained as required by the transaction agreements or related mortgage loan documents.                                                                                                                                                                                                                                                                                                                                                                                    |                            |                                                                          |                                                                                | X                                                                                           |
| 1122(d)(4)(ii)            | Pool asset and related documents are safeguarded as required by the transaction agreements                                                                                                                                                                                                                                                                                                                                                                                                                           |                            |                                                                          |                                                                                | X                                                                                           |
| 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.                                                                                                                                                                                                                                                                                                                                          | X2                              |                                                                          |                                                                                |                                                                                        |
| 1122(d)(4)(iv)            | Payments on pool assets, including any payoffs, made in accordance with the related pool asset 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 pool asset documents.                                                                                                   | X                               |                                                                          |                                                                                |                                                                                        |
| 1122(d)(4)(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                               |                                                                          |                                                                                |                                                                                        |
| 1122(d)(4)(vi)            | Changes with respect to the terms or status of an obligor's pool assets (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                               |                                                                          |                                                                                |                                                                                        |
| 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.                                                                                                                                                                                                               | X                               |                                                                          |                                                                                |                                                                                        |
| 1122(d)(4)(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                               |                                                                          |                                                                                |                                                                                        |
| 1122(d)(4)(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                               |                                                                          |                                                                                |                                                                                        |

 

2 Cenlar is required to comply with these criteria in the event that these criteria would occur. There were no instances of occurrence in our Applicable Reporting Period.

 

 

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|                    |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             |                                 |                                                                               |                                                                                     |                                                                                             |
| SERVICING CRITERIA |
| Reference          | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | Applicable: Performed by Cenlar | Applicable: Performed by Vendor (s) for which Cenlar is the responsible party | Inapplicable: Performed by Vendor (s) For which Cenlar is NOT the responsible party | Inapplicable: NOT performed by Cenlar or by subservicer(s) or vendor (s) retained by Cenlar |
| 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 pool asset 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 pool asset documents and state laws; and (C) such funds are returned to the obligor within 30 calendar days of full repayment of the related pool assets, or such other number of days specified in the transaction agreements. | X                               |                                                                          |                                                                                |                                                                                        |
| 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.                                                                                                                                                                                             |                            |                                                                          | X4                                                                                  |                                                                                        |
| 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.                                                                                                                                                                                                                                                                                                                                             | X                               |                                                                          |                                                                                |                                                                                        |
| 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.                                                                                                                                                                                                                                                                                                                                                                             | X                               |                                                                          |                                                                                |                                                                                        |
| 1122(d)(4)(xiv)    | Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                            | X                               |                                                                          |                                                                                |                                                                                        |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                               | X2                              |                                                                          |                                                                                |                                                                                        |

 

2 Cenlar is required to comply with these criteria in the event that these criteria would occur. There were no instances of occurrence in our Applicable Reporting Period.

4 Cenlar obtains an assertion and accompanying 1122 attestation report from CoreLogic Tax Services, LLC and Assurant Specialty Property (Assurant) for performing such activities.