Management's Assertion

 

Report on Assessment of Compliance with ApplicableServicing Criteria

 

 

Management of U.S. BankNational Association (“U.S. Bank”) is responsible for assessing compliance asof and for the year ended December 31, 2022 with the servicing criteria setforth in Item 1122 (d) of Regulation AB applicable to it as set forth onExhibit A hereto.  This report covers asset backed securities transactionswithin the **U.S. Bank Corporate Trust Asset-Backed Securities Platform1 (the “Platform”)**

 

U.S. Bank hereby provides thefollowing report on its assessment of compliance with the servicing criteriaset forth in Item 1122 of Regulation AB applicable to it and as described onExhibit A hereto:

 

1.       U.S. Bank is responsible forassessing its compliance with the servicing criteria applicable to it as notedon the accompanying Exhibit A;

 

2.       Except as set forth in paragraph 3below, U.S. Bank used the criteria set forth in paragraph (d) of Item 1122 ofRegulation AB to assess its compliance with the applicable servicing criteria;

 

3.       The criteria listed in the columntitled “Inapplicable Servicing Criteria” on Exhibit A hereto are inapplicableto U.S. Bank based on the servicing activities it performs directly withrespect to the Platform;

 

4.       U.S. Bank has complied, in allmaterial respects, with the applicable servicing criteria as of and for theyear ended December 31, 2022; and

 

5.       Ernst & Young, LLP, aregistered public accounting firm, has issued an attestation report on U.S.Bank’s assessment of compliance with the applicable servicing criteria as ofand for the year ended December 31, 2022.  

 

 

U.S. BANK NATIONAL ASSOCIATION

 

 

/s/ John Stern

Name: John Stern 

Title: Executive VicePresident

 

 

Date: February 27, 2023 

 

 

1 The U.S. Bank Corporate Trust Asset-Backed SecuritiesPlatform (the "Platform") consists of the activities involved in theperformance of servicing functions for which the Company provides documentcustody services for (i) publicly issued asset-backed and mortgage-backedtransactions the securities of which were offered on or after January 1, 2006and (ii) certain asset-backed transactions for which the Issuer has voluntarilyelected to make Regulation AB compliant filings under the Securities ExchangeAct of 1934, as amended.

 

** **

**EXHIBIT A to Management’s Assertion**

| **Reference**                          | **Servicing Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | **Applicable Servicing Criteria** | **Inapplicable Servicing Criteria** |
|----------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------|-------------------------------------|
| **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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | ** **

**X2**                |  

                       |
|  

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**                   |
|  

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 over collateralization, are separately maintained  (e.g., with respect to commingling of cash) as set forth in the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                    | ** **

                 | ** **

**X**                   |
|  

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**                       |
|  

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. 

                          | ** **

                 |  

**X**                       |
|  

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 payment, or custodial bank statements. 

                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | ** **

                 | ** **

**X**                   |
| **Pool Asset Administration**          |
|  

1122(d)(4)(i)                  |  

Collateral  or security on pool assets is maintained as required by the transaction  agreements or related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | ** **

**X**                 |  

                       |
|  

1122(d)(4)(ii)                 |  

Pool  assets 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | ** **

**X**                 |  

                       |
|  

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**

            |
|  

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.                                                                                                                                                                                                                                                                                                          | ** **

                 |  

**X**                       |
|  

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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | ** **

                 | ** **

**X**                   |

 

 

2 No servicing activities were performed by the Companythat required the servicing criteria to be complied with

 

Corporate TrustABS Platform (C)