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February 28, 2019





Management’s
Assertion on Compliance with Regulation AB Criteria



| | Re:     Assessment of Compliance for services provided pursuant to the Pooling and Servicing Agreements
entered into by CWCapital Asset Management LLC beginning January 1, 2006 for the 12 month period ended December 31, 2018.
| | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



CWCapital Asset Management LLC (“CWCAM”)
is responsible for assessing compliance with applicable servicing criteria set forth in Item 1122 (d) of Regulation AB of the
Securities and Exchange Commission for the securitizations issued beginning January 1, 2006, as listed on Appendix A (“Applicable
Servicing Criteria”).

CWCAM has assessed its compliance with the applicable
servicing criteria as of December 31, 2018 and for the period from January 1, 2018 to December 31, 2018 (the “Reporting
Period”). 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, excluding the criteria set forth in Item 1122 (d)(1)(iii), (d)(3)(i)(b), (d)(3)(i)(c),
(d)(3)(i)(d), (d)(3)(ii), (d)(3)(iii), (d)(3)(iv), (d)(4)(v), (d)(4)(ix), (d)(4)(x), (d)(4)(xi), (d)(4)(xii), (d)(4)(xiii), (d)(4)(xiv),
and (d)(4)(xv) of Regulation AB, which CWCAM has concluded are not applicable to the activities it performs (collectively, the
“Not Applicable Criteria”). With respect to applicable servicing criteria (d)(1)(ii), (d)(2)(vi), (d)(4)(i), (d)(4)(iii),
and (d)(4)(iv), CWCAM has determined that there were no occurrences of events that would require CWCAM to perform such activities.
The securitizations covered by this report include all securitizations wherein CWCAM is named as the Special Servicer for securitizations
issued beginning January 1, 2006, as listed in Appendix B (the “Platform”).

Based on such assessment, management
believes, as of December 31, 2018 and for the Reporting Period, the following:

1) CWCAM has
determined that the Not Applicable Criteria are in fact not applicable to the activities it performs with respect to the Platform.



2) CWCAM has
complied in all material respects with the servicing criteria set forth in Item 1122 (d), with the exception of the Not Applicable
Criteria and any material instance of noncompliance described in Schedule A hereto.



Schedule B hereto includes Management’s
Discussion of the Material Instance of Noncompliance noted in Schedule A.



CohnReznick LLP, an independent
registered public accounting firm, has issued an attestation report on CWCAM’s compliance with the Applicable Servicing Criteria
as of December 31, 2018 and for the Reporting Period.



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CWCapital Asset Management LLC











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Schedule A



Material Instance of Noncompliance



CWCAM’s assessment of compliance with the
Applicable Servicing Criteria set forth by the Securities and Exchange Commission in paragraph (d) of Item 1122 of Regulation AB
as of December 31, 2018 and for the Reporting Period, disclosed a material instance of noncompliance occurred with respect to the
servicing criterion set forth in 1122(d)(2)(vii), as follows:



| | · | With respect to compliance 1122(d)(2)(vii), CWCAM’s
policies and procedures were not properly followed with respect to timely completion of bank reconciliations.
| | - | -----------------------------------------------------------------------------------------------------------------------------------------------------------------



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Schedule B



Management’s Discussion on Material Instance
of Noncompliance



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 (A) are mathematically accurate; (B) are prepared within 30 calendar days after the bank statement
cutoff date, or such other number of days specified in the transaction agreements; (C) are reviewed and approved by someone other
than the person who prepared the reconciling items; 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.



Noncompliance

The instance of material noncompliance, for the
Reporting Period included a failure to complete the required bank reconciliations within 30 calendar days after the bank statement
cutoff date. In five of the twelve months related to the Reporting Period, the required reconciliations were not completed within
the 30 calendar days requirement as follows:

February 2018: bank reconciliations were
prepared on June 22, 2018

March 2018: bank reconciliations were prepared
on May 1, 2018

September 2018: bank reconciliations were
prepared on November 6, 2018

November 2018: bank reconciliations were
prepared on February 19, 2019

December 2018: bank reconciliations were
prepared on February 6, 2019



Remediation

In response to the lack of adherence to company
policy and procedures, the Compliance Committee reviewed the reasons for noncompliance and added two additional procedures to supplement
its existing procedures:

1) the accounting department has added
the completion of bank account reconciliations within 30 calendar days to its monthly closing checklist, which is reviewed and
signed off by a CWCAM officer; and

2) the Chief Financial Officer has set
up a monthly electronic reminder requiring that the completed bank reconciliations be forwarded to the CFO for an additional layer
of review.

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Appendix A



|                | Relevant Servicing Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |               
|--------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --------------
|Reference       | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | CWCAM         
|                | 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | Applicable    
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | Applicable    
|1122(d)(1)(iii) | Any requirements in the transaction agreements to maintain a back-up servicer for the mortgage loans are maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | Not Applicable
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                              | Applicable    
|1122(d)(1)(v)   | Aggregation of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | Applicable    
|                | 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                               | Applicable    
|1122(d)(2)(ii)  | Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | Applicable    
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | Applicable    
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                                          | Applicable    
|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.                                                                                                                                                                                                                                                                                                                               | Applicable    
|1122(d)(2)(vi)  | Unissued checks are safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | Applicable    
|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 (A) are mathematically accurate; (B) are prepared within 30 calendar days after the bank statement cutoff date, or such other number of days specified in the transaction agreements; (C) are 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. | Applicable    





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|                | Relevant Servicing Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |                                                                                                                                                
|--------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | -----------------------------------------------------------------------------------------------------------------------------------------------
|Reference       | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | CWCAM                                                                                                                                          
|                | Investor
    Remittances and Reporting                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                                                                                                                                
|1122(d)(3)(i)   | Reports to investors, including those to be filed with the Commission, are maintained in accordance with the transaction agreements and applicable Commission requirements.  Specifically, such reports (A) are prepared in accordance with timeframes and other terms set forth in the transaction agreements; (B) provide information calculated in accordance with the terms specified in the transaction agreements; (C) are filed with the Commission as required by its rules and regulations; and (D) agree with investors’ or the trustee’s records as to the total unpaid principal balance and number of mortgage loans serviced by the Servicer. | (A)       Applicable
        (B)       Not
        Applicable
        (C)       Not
        Applicable
        (D)       Not
        Applicable
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | Not Applicable                                                                                                                                 
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | Not Applicable                                                                                                                                 
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | Not Applicable                                                                                                                                 
|                | Pool Asset Administration                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |                                                                                                                                                
|1122(d)(4)(i)   | Collateral or security on mortgage loans is maintained as required by the transaction agreements or related mortgage loan documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | Applicable                                                                                                                                     
|1122(d)(4)(ii)  | Mortgage loan and related documents are safeguarded as required by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | Applicable                                                                                                                                     
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | Applicable                                                                                                                                     
|1122(d)(4)(iv)  | Payments on mortgage loans, including any payoffs, made in accordance with the related mortgage loan documents are posted to the Servicer’s obligor records maintained no more than two business days after receipt, or such other number of days specified in the transaction agreements, and allocated to principal, interest or other items (e.g., escrow) in accordance with the related mortgage loan documents.                                                                                                                                                                                                                                       | Applicable                                                                                                                                     
|1122(d)(4)(v)   | The Servicer’s records regarding the mortgage loans agree with the Servicer’s records with respect to an obligor’s unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | Not Applicable                                                                                                                                 
|1122(d)(4)(vi)  | Changes with respect to the terms or status of an obligor’s mortgage loans (e.g., loan modifications or re-agings) are made, reviewed and approved by authorized personnel in accordance with the transaction agreements and related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                  | Applicable                                                                                                                                     
|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.                                                                                                                                                                                                                                                                                                                                                      | Applicable                                                                                                                                     



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|                 | Relevant Servicing Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |               
|---------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --------------
|Reference        | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | CWCAM         
|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 cases where delinquency is deemed temporary (e.g., illness or unemployment).                                                                           | Applicable    
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                              | Not Applicable
|1122(d)(4)(x)    | Regarding any funds held in trust for an obligor (such as escrow accounts):  (A) such funds are analyzed, in accordance with the obligor’s mortgage loan documents, on at least an annual basis, or such other period specified in the transaction agreements; (B) interest on such funds is paid, or credited, to obligors in accordance with applicable mortgage loan documents and state laws; and (C) such funds are returned to the obligor within 30 calendar days of full repayment of the related mortgage loans, or such other number of days specified in the transaction agreements. | Not Applicable
|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.                                                                                                                                                                                                 | Not Applicable
|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.                                                                                                                                                                                                                                                                                                                                                             | Not Applicable
|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.                                                                                                                                                                                                                                                                                                                                                                                       | Not Applicable
|1122(d)(4)(xiv)  | Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                | Not Applicable
|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.                                                                                                                                                                                                                                                                                                                                                                                                                   | Not Applicable





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Appendix B





|AVENTURA
    2018-AVM | GSMS
    2012-GCJ7     | UBS
    2012-C2    
|--------------------- | ---------------------- | -------------------
|BACM
    2006-6       | GSMS
    2014-GC22     | UBS
    2017-C1    
|BACM
    2007-1       | GSMSC
    2014-GC26    | WBCMT
    2006-C23 
|BACM
    2007-2       | GSMS
    2015-GC32     | WBCMT
    2006-C25 
|BACM
    2007-3       | HITT
    2017-HYT2 MZB | WBCMT
    2006-C26 
|BACM
    2007-4       | JPMBB
    2014-C23     | WBCMT
    2006-C28 
|BACM
    2007-5       | JPMC
    2006-CIBC17   | WBCMT
    2007-C30 
|BACM
    2008-1       | JPMC
    2006-LDP9     | WBCMT
    2007-C32 
|BANK
    2017-BNK5    | JPMC
    2007-CIBC18   | WBCMT
    2007-C34 
|BHMS
    2018-ATLS    | JPMC
    2008-C2       | WFCM
    2015-C30  
|BMARK2018-B2          | JPMC
    2018-LAQ      | WFCM
    2016-C35  
|BENCHMARK
    2018-B4 | JPMCC
    2013-LC11    | WFCM
    2016-LC25 
|BENCHMARK
    2018-B8 | JPMCC
    2015-FL7     | WFCM
    2016-NXS6 
|CD
    2007-CD4       | JPMCC
    2016-WSP MZ  | WFRBS
    2013-C15 
|CFCRE
    2016-C3     | JPMCC
    2017-JP7     | WFRBS
    2013-UBS1
|CGCMT
    2007-C6     | JPMDB
    2017-05      | WFRBS
    2014-C21 
|CGCMT
    2016-P4     | LBCMT
    2007-3       | WFRBS
    2014-C22 
|CGCMT
    2016-P6     | LBUBS
    2006-C4      | WFRBS
    2014-C23 
|COBALT
    2007-C2    | LBUBS
    2007-C2      | WFRBS
    2014-C25 
|COBALT
    2007-C3    | LBUBS
    2008-C1      |                    
|COMM
    2006-C7      | MBR
    2018-MBR       |                    
|COMM
    2012-LC4     | MLCFC
    2006-1       |                    
|COMM
    2015-CCRE23  | MLCFC
    2006-2       |                    
|COMM
    2015-CCRE25  | MLCFC
    2007-5       |                    
|COMM
    2015-CCRE26  | MLCFC
    2007-6       |                    
|COMM
    2016-DC2     | MSBAM
    2014-C19     |                    
|CSFB
    2006-TFL2    | MSBAM
    2015-C20     |                    
|CSFB
    2007-C4      | MSBAM
    2015-C21     |                    
|CSAIL
    2017-CX10   | MSBAM
    2015-C27     |                    
|DBUBS
    2011-LC3    | MSC
    2016-UBS11     |                    
|GRACE
    2014-GRCE   | MSCI
    2016-UBS9     |                    







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