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REAL ESTATE

 

MIDLAND

LOAN

SERVICES

 

**Management’s Report on Assessment of Compliance withSEC Regulation AB Servicing Criteria**

 

Midland Loan Services, a division of PNC Bank, NationalAssociation (“Midland” or the “Company”), is responsible for compliance withthe applicable servicing criteria set forth in Item 1122(d) of Regulation AB ofthe Securities and Exchange Commission (“Regulation AB”), as set forth inAppendix A.

 

Midland has assessed its compliance with the applicableservicing criteria as of and for the year ended December 31, 2021 (the“Reporting Period”). In making this assessment, Midland used the criteria setforth by the Securities and Exchange Commission (“SEC”) in Item 1122(d) ofRegulation AB. This report covers all transactions serviced on the *Enterprise!*®Loan Management System (the “Platform”) during the Reporting Period. 

 

Midland engaged certain vendors, which are notservicers as defined in item 1101(j) of Regulation AB (the “Vendors”), toperform specific and limited or scripted activities related to portions of theservicing criteria as set forth in Appendix A.  Midland elects to takeresponsibility for assessing compliance with the servicing criteria or portionof the servicing criteria applicable to such Vendors’ activities as set forthin Appendix A. Midland has not identified and is not aware of any materialinstances of noncompliance by the Vendors with the applicable servicingcriteria as of December 31, 2021 and for the Reporting Period with respect tothe Platform taken as a whole, nor has it identified any material deficienciesin its policies and procedures to monitor the compliance by the Vendors withthe applicable servicing criteria as of December 31, 2021 and for the ReportingPeriod with respect to the Platform taken as a whole.

 

Based on this assessment, Midland concludes that, as ofand for the year ended December 31, 2021, Midland has complied in all materialrespects with the applicable servicing criteria set forth in Item 1122(d) ofRegulation AB.

 

PricewaterhouseCoopers LLP, an independent registeredpublic accounting firm, has issued an attestation report on Midland’scompliance with the applicable servicing criteria as of and for the year endedDecember 31, 2021 for all transactions serviced on the *Enterprise!* LoanManagement System.

 

MIDLAND LOAN SERVICES 

a division of PNC Bank, National Association 

 

/s/ David D. Spotts 

David D. Spotts

Senior Vice President

Date: February 18, 2022

 

**APPENDIX A**

|                     | **SERVICING CRITERIA**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     | **APPLICABLE SERVICING  CRITERIA**                                                     |
|--------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------|
| **Reference**            | **Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | **Performed**

**Directly by**

**Midland**                                            | **Performed**

**by Vendor(s)**

**for which**

**Midland is**

**the**

**Responsible**

**Party** |
|                     | **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                                                                                      | 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.                                                                                                                                                                                                                                                                                                                                                                                                         | N/A1                                                                                   |
| 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 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.                                                                                                                                                                                                                                                                                               | X2                                                                                     |   |
| 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.                                                                                                                                                                                                                                                                   | 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:                                                                                                                                                                                                                                                                                                                |                                                                                   |   |
|                     | (A)  Are mathematically accurate;                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | X                                                                                      |   |
|                     | (B) Are prepared within 30 calendar days after the  bank statement    cutoff date, or such other number of days  specified in the transaction agreements;                                                                                                                                                                                                                                                                                                                                                   | X                                                                                      |   |
|                     | (C) Are reviewed and approved by someone other than  the person who prepared the reconciliation; and                                                                                                                                                                                                                                                                                                                                                                                                                       | X                                                                                      |   |
|                     | (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;                                                                                                                                                                                                                                                                                                                                                                                                                   | X2                                                                                     |   |
|                     | (B) Provide information calculated in accordance with  the terms specified in the transaction agreements;                                                                                                                                                                                                                                                                                                                                                                                                                  | N/A1                                                                                   |
|                     | (C) Are filed with the Commission as required by its rules  and regulations; and                                                                                                                                                                                                                                                                                                                                                                                                                                           | N/A1                                                                                   |
|                     | (D) Agree with investor’s or the trustee’s records as  to the total unpaid principal balance and number of pool assets serviced by  the servicer.                                                                                                                                                                                                                                                                                                                                                              | N/A1                                                                                   |
| 1122(d)(3)(ii)           | Amounts due to investors are allocated and remitted  in accordance with timeframes, distribution priority and other terms set  forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                        | N/A1                                                                                   |
| 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.                                                                                                                                                                                                                                                                                                                                    | N/A1                                                                                   |
| 1122(d)(3)(iv)           | Amounts remitted to investors per the investor  reports agree with cancelled checks, or other form of payment, or custodial  bank statements.                                                                                                                                                                                                                                                                                                                                                                              | N/A1                                                                                   |
|                     | **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                                                                                      | 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                                                                                      | 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 asset (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                                                                                      | 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.                                                                                                                                                                                                                 | X2                                                                                     | 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;                                                                                                                                                                                                                                                                                                                                     | X                                                                                      |   |
|                     | (B) Interest on such funds is paid, or  credited, to obligors in accordance with applicable pool asset documents and  state laws; and                                                                                                                                                                                                                                                                                                                                                                                      | X                                                                                      |   |
|                     | (C) Such funds are returned to the obligor  within 30 calendar days of full repayment of the related pool asset, 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                                                                                      | 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                                                                                      | 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.                                                                                                                                                                                                                                                                                                                                            | N/A1                                                                                   |
|                     |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |                                                                                   |   |   |

 

1 Midland has determined servicing criteria 1122(d)(1)(iii), 1122(d)(3)(i)(B),1122(d)(3)(i)(C), 1122(d)(3)(i)(D), 1122(d)(3)(ii), 1122(d)(3)(iii), 1122(d)(3)(iv),and 1122(d)(4)(xv) to be inapplicable to the activities Midland performs withrespect to the Platform.

2 Midland has utilized the CRE Finance Council’s Loan Modification/ForbearanceBest Practices as it relates to the servicing procedures performed for loans inforbearance including advancing and reporting of such loans.