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**Report of Independent Registered Public Accounting Firm**

 

 

To the Board of Directors andManagement of 

Prudential Asset Resources,Inc.:

 

We have examined management's assertion,included in the accompanying Certification Regarding Compliance with ApplicableServicing Criteria, that Prudential Asset Resources, Inc. (the"Company") complied with the servicing criteria set forth in Item1122(d) of the Securities and Exchange Commission's Regulation AB for theCommercial Mortgage-Backed Security Transactions - Reg AB Portfolio (the"Platform"), as of December 31, 2019 and for the year then ended,excluding 1122(d)(1)(iii), 1122(d)(3)(i)(C) & (D), 1122(d)(3)(ii),1122(d)(3)(iii), 1122(d)(3)(iv), and 1122(d)(4)(xv), which the Company hasdetermined are not applicable to the servicing activities performed by it withrespect to the Platform. As described in management's assertion, for servicingcriteria 1122(d)(2)(ii), 1122(d)(2)(vi), 1122(d)(2)(vii), 1122(d)(4)(xi) and1122(d)(4)(xii), the Company has engaged various vendors to perform theactivities required by these servicing criteria. The Company has determinedthat these vendors are not considered "servicers" as defined in Item1101(j) of Regulation AB, and the Company has elected to take responsibilityfor assessing compliance with the servicing criteria applicable to each vendoras permitted by Compliance and Disclosure Interpretation 200.06 of the SECDivision of Corporation Finance's interpretations of the rules adopted underRegulation AB and the Securities Act and the Exchange Act ("Interpretation200.06"). As permitted by Interpretation 200.06, the Company has assertedthat it has policies and procedures in place designed to provide reasonableassurance that the vendors' activities comply in all material respects with theservicing criteria applicable to each vendor. The Company is solely responsiblefor determining that it meets the SEC requirements to apply Interpretation200.06 for the vendors and related criteria as described in its assertion, andwe performed no procedures with respect to the Company's determination of itseligibility to use Interpretation 200.06. Exhibit B to management's assertionidentifies the individual asset-backed transactions and securities defined bymanagement as constituting the Platform. Prudential Asset Resources, Inc.'smanagement is responsible for its assertion and for the Company's compliancewith the applicable servicing criteria. Our responsibility is to express anopinion on management's assertion about the Company's compliance with theapplicable servicing criteria based on our examination.

 

Our examination was conductedin accordance with the standards of the Public Company Accounting OversightBoard (United States) and in accordance with attestation standards establishedby the American Institute of Certified Public Accountants. Those standardsrequire that we plan and perform the examination to obtain reasonable assuranceabout whether management's assertion about compliance with the applicableservicing criteria is fairly stated, in all material respects, and accordingly,included examining, on a test basis, evidence about the Company's compliancewith the applicable servicing criteria and performing such other procedures aswe considered necessary in the circumstances. Our examination included testingof selected asset-backed transactions and securities that comprise thePlatform, testing of selected servicing activities related to the Platform, anddetermining whether the Company processed those selected transactions andperformed those selected activities in compliance with the applicable servicingcriteria. Our procedures were limited to the selected transactions and servicingactivities performed by the Company during the period covered by this report.Our procedures were not designed to detect noncompliance arising from errorsthat may have occurred prior to or subsequent to our tests that may haveaffected the balances or amounts calculated or reported by the Company duringthe period covered by this report. We believe that our examination provides,and that the evidence we obtained is sufficient and appropriate to provide, areasonable basis for our opinion. Our examination does not provide a legaldetermination on the Company's compliance with the servicing criteria.

 

In our opinion, management'sassertion that Prudential Asset Resources, Inc. complied with theaforementioned applicable servicing criteria as of and for the year endedDecember 31, 2019 for the Commercial Mortgage-Backed Security Transactions -Reg AB Portfolio is fairly stated, in all material respects.

 

 

/s/ PricewaterhouseCoopers LLP

 

 

Dallas, Texas 

February 21, 2020