(logo)TRIMONT®

 

GlenPeters

ChiefFinancial Officer, Global 

gpeters@trimontrea.com

Direct:404-581-7525

 

3500Lenox Road, 

SuiteG1

Atlanta,GA 30326

 

trimontrea.com

 

 

**Trimont Real EstateAdvisors, LLC**

 

**Management’s Reporton Assessment of Compliance with SEC Regulation AB Servicing Criteria**

 

 

TrimontReal Estate Advisors, LLC (“the Asserting Party”) is responsible for assessingcompliance as of and for the year ended December 31, 2021 (“the ReportingPeriod”) with the applicable servicing criteria set forth in Item 1122(d) ofthe Securities and Exchange Commission’s Regulation AB as set forth in ExhibitA hereto (the “Applicable Servicing Criteria”). The transactions covered bythis report are only those transactions processed by the Asserting Party incapacity as special servicer for the asset backed securities transactionslisted in Exhibit B hereto (the “Platform”).

 

TheAsserting Party has used the servicing criteria set forth in Item 1122(d) ofthe Securities and Exchange Commission’s Regulation AB to assess its compliancewith the Applicable Servicing Criteria for the Reporting Period and hasconcluded that the Asserting Party has complied, in all material respects, withthe Applicable Servicing Criteria as of and for the year ended December 31,2021 with respect to the Platform.

 

GrantThornton, LLP, an independent registered public accounting firm, has issued anattestation report on the assessment of compliance with the ApplicableServicing Criteria as of and for the year ended December 31, 2021 as set forthin this assertion.

 

 

TrimontReal Estate Advisors, LLC 

February28, 2022

 

 

/s/Glen Peters

GlenPeters

ChiefFinancial Officer

 

 

TrimontReal Estate Advisors

 

Amsterdam| Atlanta | Dallas | Kansas City | London | Los Angeles | New York |

 

 

**Exhibit A**

 

| ** **

** **

** **

** **

** **

**Regulation AB  Criteria** | **JPMCC 2018-MINN**                                   | **COMM 2012-CCRE2**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | **GSMS 2018-TWR**                           | **Ashford  Hospitality Trust 2018-KEYS**    | **Bancorp 2018-CRE3**                       | **Bancorp 2018-CRE4**                       | **GSMS 2018-GS10**                          | **CSMC 2017-PFHP**                          | **MSC 2017-ASHF**                           | **JPMCC 2020-ACE**                          | **RPT 2017-ROSS**                           | **Bancorp 2017-CRE2**                       | **CGMS 2017 MDDR**                          | **225 Liberty  Street Trust 2016- 225L**    | **BANCORP 2016-CRE1**                       |
|-----------------------------------------------------------------------------------------|-------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------|---------------------------------------------|---------------------------------------------|---------------------------------------------|---------------------------------------------|---------------------------------------------|---------------------------------------------|---------------------------------------------|---------------------------------------------|---------------------------------------------|---------------------------------------------|---------------------------------------------|---------------------------------------------|
| ***Section***                                                                           | ***Description***                                     | ***Criteria***                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |                                        |                                        |                                        |                                        |                                        |                                        |                                        |                                        |                                        |                                        |                                        |                                        |                                        |   |   |
| General  Servicing Considerations                                                       |
| (d)(1)(i)                                                                               | Policies and  Procedures                              | Policies  and procedures are instituted to monitor any performance or other triggers  and events of default in accordance with the transaction agreement.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |  

X                                   |  

X                                   |  

X                                   |  

X                                   |  

X                                   |  

X                                   |  

X                                   |  

X                                   |  

X                                   |  

X                                   |  

X                                   |  

X                                   |  

X                                   |  

X |  

X |
| (d)(1)(ii)                                                                              | Policies and  Procedures

(vendors)                   | 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |  

X7                                  |  

X7                                  |  

X7                                  |  

X7                                  |  

X7                                  |  

X7                                  |  

X7                                  |  

X7                                  |  

X7                                  |  

X7                                  |  

X7                                  |  

X7                                  |  

X7                                  |  

X7 |  

X7 |
| (d)(1)(iii)                                                                             | Back-up Servicer                                      | Any  requirements in the transaction agreements to maintain a back-up servicer for  the pool assets are maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A | N/A |
| (d)(1)(iv)                                                                              | Fidelity Bond                                         | 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 agreement.                                                                                                                                                                                                                                                                                                                                                                                                                                                   |  

X                                   |  

X                                   |  

X                                   |  

X                                   |  

X                                   |  

X                                   |  

X                                   |  

X                                   |  

X                                   |  

X                                   |  

X                                   |  

X                                   |  

X                                   |  

X |  

X |
| (d)(1)(v)                                                                               | Accuracy of

Information                              | Aggregation  of information, as applicable, is mathematically accurate and the information  conveyed accurately reflects the information.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | X4                                          | X4                                          | X1                                          | X4                                          | X4                                          | X4                                          | X1                                          | X4                                          | X4                                          | X1                                          | X1                                          | X4                                          | X1                                          | X1 | X4 |
| Cash  Collection and Administration                                                     |
| (d)(2)(i)                                                                               | 2 Days to deposit  Payments into Custodial Accounts   | Payments on pool assets  are deposited into the appropriate custodial bank accounts and related bank  clearing accounts no more than two business days of receipt, or such other  number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |  

 

X3                          |  

 

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X1 |  

 

X3 |
| (d)(2)(ii)                                                                              | Wire Transfers                                        | Disbursements  made via wire transfer on behalf of an obligor or to an investor are made  only by authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |  

N/A                                 |  

N/A                                 |  

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N/A                                 |  

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N/A |  

N/A |
| (d)(2)(iii)                                                                             | Advances                                              | 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                          |  

 

X9                          |  

 

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X2 |  

 

X2 |
| (d)(2)(iv)                                                                              | Commingling                                           | 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                             |  

 

X5                          |  

 

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X1                          |  

 

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X1                          |  

 

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X1 |  

 

X5 |
| (d)(2)(v)                                                                               | Federally Insured  Institution                        | 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 §240.13k-1(b)(1) of this chapter.                                                                                                                                                                                                                                                                                                                                   |  

 

 

X5                  |  

 

 

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X5                  |  

 

 

X5                  |  

 

 

X1                  |  

 

 

X5                  |  

 

 

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X1                  |  

 

 

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X5                  |  

 

 

X1                  |  

 

 

X1 |  

 

 

X5 |
| (d)(2)(vi)                                                                              | Unissued Checks                                       | Unissued checks  are safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |  

X                                   |  

X                                   |  

X1                                  |  

X                                   |  

X                                   |  

X                                   |  

X1                                  |  

X                                   |  

X                                   |  

X1                                  |  

X1                                  |  

X                                   |  

X1                                  |  

X1 |  

X |
| (d)(2)(vii)                                                                             | Reconciliations                                       | 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. |  

 

 

 

X5          |  

 

 

 

X5          |  

 

 

 

X1          |  

 

 

 

X5          |  

 

 

 

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X5          |  

 

 

 

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X1 |  

 

 

 

X5 |
| Investor  Remittance and Reporting                                                      |
| (d)(3)(i)                                                                               | Reports to the  Investor                              | 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.                                                     |  

 

 

 

 

N/A |  

 

 

 

 

N/A |  

 

 

 

 

N/A |  

 

 

 

 

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N/A |
| (d)(3)(ii)                                                                              | Investor  Remittance                                  | Amounts  due to investors are allocated and remitted in accordance with timeframes,  distribution priority and other terms set forth in the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |  

N/A                                 |  

N/A                                 |  

N/A                                 |  

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N/A |  

N/A |
| (d)(3)(iii)                                                                             | Investor's  Records                                   | 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/A                                 |  

N/A                                 |  

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N/A |  

N/A |
| (d)(3)(iv)                                                                              | Remittance and  Bank Statements                       | Amounts  remitted to investors per the investor reports agree with cancelled checks,  or other form of payment, or custodial bank statements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |  

N/A                                 |  

N/A                                 |  

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N/A |  

N/A |
| Pool  Asset Administration                                                              |
| (d)(4)(i)                                                                               | Collateral/Security  on Pool Assets                   | Collateral  or security on pool assets is maintained as required by the transaction agreements  or related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | X6                                          | X6                                          | X1                                          | X6                                          | X6                                          | X6                                          | X1                                          | X6                                          | X6                                          | X1                                          | X1                                          | X6                                          | X1                                          | X1 | X6 |
| (d)(4)(ii)                                                                              | Safeguard Pool

Assets                                | Pool  assets and related documents are safeguarded as required by the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A | N/A |
| (d)(4)(iii)                                                                             | Changes to the  Pool Assets                           | 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |  

X8                                  |  

X8                                  |  

X1                                  |  

X8                                  |  

X8                                  |  

X8                                  |  

X1                                  |  

X8                                  |  

X8                                  |  

X1                                  |  

X1                                  |  

X8                                  |  

X1                                  |  

X1 |  

X8 |
| (d)(4)(iv)                                                                              | Obligor's Payment  Record                             | Payments  on pool assets, including any payoffs, made in accordance with the related  pool asset documents are posted to the applicable 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.                                                                                                                                                                                                                                                                                      |  

 

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| (d)(4)(v)                                                                               | Pool Asset  Records Match UPB                         | The  servicers records regarding the pool assets agree with the servicer's records  with respect to an obligor's unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A                                         | N/A | N/A |
| (d)(4)(vi)                                                                              | Loan  Modifications                                   | 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                               |  

 

X10                         |  

 

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X10 |
| (d)(4)(vii)                                                                             | Loss Mitigation  Actions                              | 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  agreement.                                                                                                                                                                                                                                                                                                                                                                                                       |  

 

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X1 |  

 

X |
| (d)(4)(viii)                                                                            | Collection  Efforts Documented                        | 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).                                                                                                                                                                                             |  

 

 

 

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| (d)(4)(ix)                                                                              | ARMs                                                  | Adjustments  to interest rates or rates of return for pool assets with variable rates are  computed based on the related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |  

N/A                                 |  

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| (d)(4)(x)                                                                               | Escrow Funds                                          | Regarding  any funds held in trust for an obligor such funds are (a) 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)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.                                                                                                                                                                       |  

 

 

 

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| (d)(4)(xi)                                                                              | Timely Payments                                       | 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.                                                                                                                                                                                                                                                                                                                   |  

 

 

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| (d)(4)(xii)                                                                             | Late Payment  Penalties                               | 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |  

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| (d)(4)(xiii)                                                                            | Obligor's Records                                     | 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |  

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N/A |  

N/A |
| (d)(4)(xiv)                                                                             | Delinquencies,

Charge-offs, and Other  Uncollectible | Delinquencies,  Charge-offs, and uncollectible accounts are recognized and recorded in  accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |  

N/A                                 |  

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N/A |  

N/A |
| (d)(4)(xv)                                                                              | Any External  Enhancement                             | Any  external enhancement or other support, identified in Item 1114(a)(1) through  (3) or Item 1115 of this Regulation AB, is maintained as set forth in the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |  

N/A                                 |  

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N/A |

 

 

**Exhibit A**

 

| ** **

** **

** **

** **

** **

**Regulation AB  Criteria** | **GSMS 2016-GS3**                                              | **BSREP 2021-DC**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | **GSMS 2021-ROSS**                  | **CF 2019-BOSS**                    | **BANCORP 2019-CRE5**               | **BBCMS 2019-CLP**                  | **BBCMS 2019-Core**                 | **BCMARK 2019-B12**                 | **BX 2019-MMP**                     | **CAMB Trust  2019-LIFE**           | **CF 2019-CF1**                     | **MTRO 2019-TECH**                  | **NOHT 2019-HNLA**                  | **NYT 2019-NYT**                    |
|-----------------------------------------------------------------------------------------|----------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------|-------------------------------------|-------------------------------------|-------------------------------------|-------------------------------------|-------------------------------------|-------------------------------------|-------------------------------------|-------------------------------------|-------------------------------------|-------------------------------------|-------------------------------------|
| ***Section***                                                                           | ***Description***                                              | ***Criteria***                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | ** **                          | ** **                          | ** **                          | ** **                          | ** **                          | ** **                          | ** **                          | ** **                          | ** **                          | ** **                          | ** **                          | ** **                          | ** ** | ** ** |
| General  Servicing Considerations                                                       |
| (d)(1)(i)                                                                               | Policies and  Procedures                                       | Policies  and procedures are instituted to monitor any performance or other triggers  and events of default in accordance with the transaction agreement.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |  

X                           |  

X                           |  

X                           |  

X                           |  

X                           |  

X                           |  

X                           |  

X                           |  

X                           |  

X                           |  

X                           |  

X                           |  

X |  

X |
| (d)(1)(ii)                                                                              | Policies and  Procedures (vendors)                             | 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | X7                                  | X7                                  | X7                                  | X7                                  | X7                                  | X7                                  | X7                                  | X7                                  | X7                                  | X7                                  | X7                                  | X7                                  | X7 | X7 |
| (d)(1)(iii)                                                                             | Back-up Servicer                                               | Any  requirements in the transaction agreements to maintain a back-up servicer for  the pool assets are maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A |  

N/A |
| (d)(1)(iv)                                                                              | Fidelity Bond                                                  | 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 agreement.                                                                                                                                                                                                                                                                                                                                                                                                                                                   |  

 

X                   |  

 

X                   |  

 

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X                   |  

 

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X                   |  

 

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X                   |  

 

X                   |  

 

X |  

 

X |
| (d)(1)(v)                                                                               | Accuracy of  Information                                       | Aggregation  of information, as applicable, is mathematically accurate and the information  conveyed accurately reflects the information.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | X1                                  | X1                                  | X1                                  | X4                                  | X4                                  | X1                                  | X1                                  | X1                                  | X1                                  | X1                                  | X1                                  | X1                                  | X4 | X1 |
| Cash  Collection and Administration                                                     |
| (d)(2)(i)                                                                               | 2 Days to deposit  Payments into Custodial Accounts            | Payments  on pool assets are deposited into the appropriate custodial bank accounts and  related bank clearing accounts no more than two business days of receipt, or  such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |  

 

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X1 |
| (d)(2)(ii)                                                                              | Wire Transfers                                                 | Disbursements  made via wire transfer on behalf of an obligor or to an investor are made  only by authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |  

N/A                         |  

N/A                         |  

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N/A                         |  

N/A                         |  

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N/A |  

N/A |
| (d)(2)(iii)                                                                             | Advances                                                       | 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |  

 

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X2 |
| (d)(2)(iv)                                                                              | Commingling                                                    | 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                             |  

 

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| (d)(2)(v)                                                                               | Federally Insured  Institution                                 | 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 §240.13k-1(b)(1) of this chapter.                                                                                                                                                                                                                                                                                                                                   |  

 

 

 

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| (d)(2)(vi)                                                                              | Unissued Checks                                                | Unissued  checks are safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | X1                                  | X1                                  | X1                                  | X                                   | X                                   | X1                                  | X1                                  | X1                                  | X1                                  | X1                                  | X1                                  | X1                                  | X |  X1 |
| (d)(2)(vii)                                                                             | Reconciliations                                                | 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. |  

 

 

 

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| Investor  Remittance and Reporting                                                      |
| (d)(3)(i)                                                                               | Reports to the  Investor                                       | 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.                                                     |  

 

 

 

N/A |  

 

 

 

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| (d)(3)(ii)                                                                              | Investor  Remittance                                           | Amounts  due to investors are allocated and remitted in accordance with timeframes,  distribution priority and other terms set forth in the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |  

N/A                         |  

N/A                         |  

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N/A                         |  

N/A                         |  

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N/A |  

N/A |
| (d)(3)(iii)                                                                             | Investor's  Records                                            | 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/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

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N/A |  

N/A |
| (d)(3)(iv)                                                                              | Remittance and  Bank Statements                                | Amounts  remitted to investors per the investor reports agree with cancelled checks,  or other form of payment, or custodial bank statements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

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N/A                         |  

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N/A |  

N/A |
| Pool  Asset Administration                                                              |
| (d)(4)(i)                                                                               | Collateral/Security  on Pool Assets                            | Collateral  or security on pool assets is maintained as required by the transaction  agreements or related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |  

X1                          |  

X1                          |  

X1                          |  

X6                          |  

X6                          |  

X1                          |  

X1                          |  

X1                          |  

X1                          |  

X1                          |  

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X1                          |  

X6 |  

X1 |
| (d)(4)(ii)                                                                              | Safeguard Pool  Assets                                         | Pool  assets and related documents are safeguarded as required by the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |  

N/A                         |  

N/A                         |  

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N/A |
| (d)(4)(iii)                                                                             | Changes to the  Pool Assets                                    | 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |  

X1                          |  

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X8                          |  

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X1 |
| (d)(4)(iv)                                                                              | Obligor's Payment  Record                                      | Payments  on pool assets, including any payoffs, made in accordance with the related  pool asset documents are posted to the applicable 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.                                                                                                                                                                                                                                                                                           |  

 

 

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| (d)(4)(v)                                                                               | Pool Asset  Records Match UPB                                  | The  servicers records regarding the pool assets agree with the servicer's records  with respect to an obligor's unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             |  

N/A                         |  

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| (d)(4)(vi)                                                                              | Loan  Modifications                                            | 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                               |  

 

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| (d)(4)(vii)                                                                             | Loss Mitigation  Actions                                       | 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 agreement.                                                                                                                                                                                                                                                                                                                                                                                                              |  

 

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| (d)(4)(viii)                                                                            | Collection  Efforts Documented                                 | 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).                                                                                                                                                                                                  |  

 

 

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| (d)(4)(ix)                                                                              | ARMs                                                           | Adjustments  to interest rates or rates of return for pool assets with variable rates are  computed based on the related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |  

N/A                         |  

N/A                         |  

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N/A                         |  

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N/A                         |  

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N/A |  

N/A |
| (d)(4)(x)                                                                               | Escrow Funds                                                   | Regarding  any funds held in trust for an obligor such funds are (a) 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)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.                                                                                                                                                                       |  

 

 

 

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| (d)(4)(xi)                                                                              | Timely Payments                                                | 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.                                                                                                                                                                                                                                                                                                                   |  

 

 

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| (d)(4)(xii)                                                                             | Late Payment  Penalties                                        | 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |  

 

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N/A |
| (d)(4)(xiii)                                                                            | Obligor's Records                                              | 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |  

N/A                         |  

N/A                         |  

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N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A |  

N/A |
| (d)(4)(xiv)                                                                             | Delinquencies, Charge-offs,  and Other Uncollectible

Accounts | Delinquencies,  Charge-offs, and uncollectible accounts are recognized and recorded in  accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A |  

N/A |
| (d)(4)(xv)                                                                              | Any External  Enhancement                                      | Any  external enhancement or other support, identified in Item 1114(a)(1) through  (3) or Item 1115 of this Regulation AB, is maintained as set forth in the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

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N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A                         |  

N/A |  

N/A |

 

** **

**Exhibit A Key**

 

|  

X1                                                                                                                                                                                                         | This  criteria is applicable for the securitization; however, there were no loans  serviced under this securitization during the reporting period.                                                                                                               |
|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
|  

X2                                                                                                                                                                                                         | With  respect to Applicable Servicing Criteria, the securitization was not in scope  based the transaction agreement.                                                                                                                                            |
|  

X3                                                                                                                                                                                                         | With  respect to item 1122(d)(2)(i), this criteria is applicable for the  securitization; however, there was no cash collected for loans under the  securitization during the reporting period.                                                                  |
|  

X4                                                                                                                                                                                                         | With  respect to item 1122(d)(1)(v), this criteria is applicable for the  securitization; however, there was no aggregation of information related to  reporting to external parties.                                                                            |
|  

X5                                                                                                                                                                                                         | With  respect to item 1122(d)(2)(iv), 1122(d)(2)(v) and 1122(d)(2)(vii), the  criteria is applicable for the securitization; however, there were no  custodial bank accounts maintained under the securitization during the  reporting period.                   |
|  

X6                                                                                                                                                                                                         | With  respect to item 1122(d)(4)(i), the criteria is applicable for the  securitization; however, as special servicer, Trimont was not responsible for  maintaining collateral or security on pool assets under the securitization  during the reporting period. |
|  

X7                                                                                                                                                                                                         | With  respect to item 1122(d)(1)(ii), this criteria is applicable for the  securitization; however, there were no material servicing activities  outsourced to third parties under this securitization during the reporting  period.                             |
|  

X8                                                                                                                                                                                                         | With  respect to item 1122(d)(4)(iii), the criteria is applicable for the  securitization; however, there were no additions, removals, or substitutions  to the pool assets under the securitization during the reporting period.                                |
|  

X9                                                                                                                                                                                                         | With  respect to item 1122(d)(2)(iii), the criteria is applicable for the  securitization; however, there were no advances of funds or guarantees  regarding collections, cash flows or distributions under the securitization  during the reporting period.     |
|  

X10                                                                                                                                                                                                        | With  respect to item 1122(d)(4)(vi), the criteria is applicable for the  securitization; however, there were no loan modifications under the  securitization during the reporting period.                                                                       |
| With  respect to Applicable Servicing Criteria cells in Exhibit A that are denoted  with an "N/A", per review of the respective servicing agreement,  the criteria was not in scope for the transaction. |

 

** **

**Exhibit B**

 

| ** **

**Name**                  | ** **

**Transaction**                                                                                                                                              | ** **

**Period of Service**            |
|---------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------|
|  

GSMS  2021-ROSS               | Special  Servicer for Commercial Mortgage Pass-Through Certificates Series GSMS 2021- ROSS  pursuant to the Pooling and Servicing Agreement dated May 28, 2021           |  

May  28, 2021 - December 31, 2021    |
|  

BSREP  2021-DC                | Special  Servicer for Commercial Mortgage Pass-Through Certificates Series BSREP 2021-  DC pursuant to the Pooling and Servicing Agreement dated August 16, 2021         |  

August  16, 2021 - December 31, 2021 |
|  

225  Liberty Street Trust 201 | Special  Servicer for Commercial Mortgage Pass-Through Certificates Series 2016-225L  pursuant to the Pooling and Servicing Agreement dated February 6, 2016             |  

January  1, 2021 - December 31, 2021 |
|  

Bancorp  2016-CRE1            | Special  Servicer for Commercial Mortgage Pass-Through Certificates Series BANCORP  2016- CRE1 pursuant to the Pooling and Servicing Agreement dated December 6,  2016   |  

January  1, 2021 - August 17, 2021   |
|  

GSMS  2016-GS3                | Special  Servicer for Commercial Mortgage Pass-Through Certificates Series GSMS 2016-  GS3 pursuant to the Pooling and Servicing Agreement dated September 1, 2016       |  

January  1, 2021 - December 31, 2021 |
|  

Bancorp  2017-CRE2            | Special  Servicer for Commercial Mortgage Pass-Through Certificates Series Bancorp  2017- CRE2 pursuant to the Pooling and Servicing Agreement dated August 30,  2017    |  

January  1, 2021 - December 31, 2021 |
|  

CGMS  2017-MDDR               | Special  Servicer for Commercial Mortgage Pass-Through Certificates Series CGMS 2017  MDDR pursuant to the Pooling and Servicing Agreement dated July 6, 2017            |  

January  1, 2021 - December 31, 2021 |
|  

RPT  2017-ROSS                | Special  Servicer for Commercial Mortgage Pass-Through Certificates Series RPT 2017-  ROSS pursuant to the Pooling and Servicing Agreement dated June 30, 2017           |  

January  1, 2021 - June 30, 2021     |
|  

MSC  2017-ASHF                | Special  Servicer for Commercial Mortgage Pass-Through Certificates Series MSC 2017-  ASHF pursuant to the Pooling and Servicing Agreement dated December 9, 2017        |  

January  1, 2021 - December 31, 2021 |
|  

CSMC  2017-PFHP               | Special  Servicer for Commercial Mortgage Pass-Through Certificates Series CSMC 2017-  PFHP pursuant to the Pooling and Servicing Agreement dated December 19, 2017      |  

January  1, 2021 - December 31, 2021 |
|  

GSMS  2018-GS10               | Special  Servicer for Commercial Mortgage Pass-Through Certificates Series GSMS 2018-  GS10 pursuant to the Pooling and Servicing Agreement dated July 1, 2018           |  

January  1, 2021 - December 31, 2021 |
|  

Bancorp  2018-CRE4            | Special  Servicer for Commercial Mortgage Pass-Through Certificates Series Bancorp  2018- CRE4 pursuant to the Pooling and Servicing Agreement dated September  27, 2018 |  

January  1, 2021 - December 31, 2021 |
|  

Bancorp  2018-CRE3            | Special  Servicer for Commercial Mortgage Pass-Through Certificates Series Bancorp  2018- CRE3 pursuant to the Pooling and Servicing Agreement dated March 29,  2018     |  

January  1, 2021 - December 31, 2021 |
|  

Ashford  Hospitality Trust 20 | Special  Servicer for Commercial Mortgage Pass-Through Certificates Series AHT 2018  Keys pursuant to the Pooling and Servicing Agreement dated July 16, 2018            |  

January  1, 2021 - December 31, 2021 |
|  

GSMS  2018-TWR                | Special  Servicer for Commercial Mortgage Pass-Through Certificates Series GSMS 2018-  TWR pursuant to the Pooling and Servicing Agreement dated July 31, 2018           |  

January  1, 2021 - December 31, 2021 |
|  

COMM  2012 CCRE2              | Special  Servicer for Commercial Mortgage Pass-Through Certificates Series COMM 2012-  CCRE2 pursuant to the Pooling and Servicing Agreement dated August 1, 2018        |  

January  1, 2021 - December 31, 2021 |
|  

JPMCC  2018-MINN              | Special  Servicer for Commercial Mortgage Pass-Through Certificates Series JPMCC 2018-  MINN pursuant to the Pooling and Servicing Agreement dated December 7, 2018      |  

January  1, 2021 - December 31, 2021 |
|  

CF  2019-BOSS                 | Special  Servicer for Commercial Mortgage Pass-Through Certificates Series CF-TRUST 19  BOSS pursuant to the Pooling and Servicing Agreement dated November 26, 2019     |  

January  1, 2021 - December 31, 2021 |
|  

Bancorp  2019-CRE5            | Special  Servicer for Commercial Mortgage Pass-Through Certificates Series BANCORP 2019-  CRES pursuant to the Pooling and Servicing Agreement dated March 28, 2019      |  

January  1, 2021 - December 31, 2021 |
|  

BBCMS  2019-CLP               | Special  Servicer for Commercial Mortgage Pass-Through Certificates Series BBCMS 2019-  CLP pursuant to the Pooling and Servicing Agreement dated February 27, 2019      |  

January  1, 2021 - June 15, 2021     |
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BBCMS  2019-CORE              | Special  Servicer for Commercial Mortgage Pass-Through Certificates Series BBCMS 2019-  Core pursuant to the Pooling and Servicing Agreement dated March 15, 2019        |  

January  1, 2021 - December 31, 2021 |
|  

BCMARK  2019-B12              | Special  Servicer for Commercial Mortgage Pass-Through Certificates Series BCMARK  2019- B12 pursuant to the Pooling and Servicing Agreement dated August 1,  2019       |  

January  1, 2021 - June 11, 2021     |
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BX  2019-MMP                  | Special  Servicer for Commercial Mortgage Pass-Through Certificates Series BX 2019-MMP  pursuant to the Pooling and Servicing Agreement dated August 29, 2019            |  

January  1, 2021 - December 31, 2021 |
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CAMB  Trust 2019-LIFE         | Special  Servicer for Commercial Mortgage Pass-Through Certificates Series CAMB 2019-  LIFE pursuant to the Pooling and Servicing Agreement dated January 9, 2019        |  

January  1, 2021 - December 31, 2021 |
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CF  2019-CF1                  | Special  Servicer for Commercial Mortgage Pass-Through Certificates Series CF 2019-CFI  pursuant to the Pooling and Servicing Agreement dated April 1, 2019              |  

January  1, 2021 - June 11, 2021     |
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MTRO  2019-TECH               | Special  Servicer for Commercial Mortgage Pass-Through Certificates Series MTRO 2019-  TECH pursuant to the Pooling and Servicing Agreement dated February 9, 2019       |  

January  1, 2021 - December 31, 2021 |
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NOHT  2019-HNLA               | Special  Servicer for Commercial Mortgage Pass-Through Certificates Series NOHT 2019-  HNLA pursuant to the Pooling and Servicing Agreement dated May 15, 2019           |  

January  1, 2021 - February 19, 2021 |
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NYT  2019-NYT                 | Special  Servicer for Commercial Mortgage Pass-Through Certificates Series NYT  2019-NYT pursuant to the Pooling and Servicing Agreement dated January 30,  2019         |  

January  1, 2021 - December 31, 2021 |
|  

JPMCC  2020-ACE               | Special  Servicer for Commercial Mortgage Pass-Through Certificates Series JPMCC 2020-  ACE pursuant to the Pooling and Servicing Agreement dated February 20, 2020      |  

January  1, 2021 - December 31, 2021 |