**Certification RegardingCompliance with Applicable Servicing Criteria**

** **

**To PricewaterhouseCoopersLLP**

 

1. Prudential Asset Resources,Inc. (the "Servicer") is responsible for assessing compliance by itwith the servicing criteria applicable to it under paragraph (d) of Item 1122of Regulation AB (the "Servicing Criteria"), as of and for the yearended December 31, 2016, as set forth in Exhibit A hereto in connectionwith commercial mortgage securities transactions for the-mortgage loansecuritizations listed in Exhibit C;

 

2. Except as set forth inparagraph 3 below, the Servicer used the criteria set forth in paragraph (d) ofItem 1122 of Regulation AB to assess the compliance with the ServicingCriteria;

 

3. The criteria described asnot applicable on Exhibit A hereto are inapplicable to the Servicerbased on the activities it performs with respect to commercial mortgagesecurities transactions involving mortgage loans, also the Servicer hasidentified specific servicing criteria for which no transaction activityoccurred;

 

4. The Servicer has engagedcertain vendors, which are not deemed to be servicers as defined in Item1101(j) of Regulation AB (the "Vendors"), to perform specific andlimited activities or activities scripted by the Servicer as of and during theReporting Period, and the Servicer elects to take responsibility for assessingcompliance with the Servicing Criteria or portion of the Servicing Criteriaapplicable to such Vendors as set forth in Exhibit A hereto (such criteria, the"Applicable Servicing Criteria Performed by Vendor(s)").

 

The Servicer has policies andprocedures in place designed to provide reasonable assurance that the Vendor'sactivities comply in all material respects for purposes of Regulation AB withthe Applicable Vendor Servicing Criteria. The Servicer (i) has not identifiedand is not aware of any material instance of noncompliance by the Vendors withthe Applicable Vendor Servicing Criteria that would affect the Servicer'scompliance and (ii) has not identified any material deficiency in its policiesand procedures to monitor the compliance by the Vendor with the ApplicableServicing Criteria Performed by Vendor(s) as of December 31, 2016 and for theReporting Period.

 

5. The Servicer has complied,in all material respects, with the Servicing Criteria as of and for the yearending December 31, 2016; and

 

6. PricewaterhouseCoopers LLPhas issued an attestation report with respect to the Servicer's assessment ofcompliance with the Servicing Criteria as of and for the year ended December31, 2016, which attestation report is included in Exhibit B attachedhereto. This Certification is being provided to PricewaterhouseCoopers LLP infulfillment of its requirement for issuance of the final report.

 

February 22, 2017

 

Prudential Asset Resources,Inc.

 

/s/ Timothy E. Steward

Timothy E. Steward, President

 

/s/ Lukshmi A. Subendranathan

Lukshmi A. Subendranathan,Vice President

 

 

**EXHIBIT A**

 

| **SERVICING   CRITERIA**

**Reg AB   Portfolio** | **APPLICABLE SERVICING CRITERIA**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | **INAPPLICABLE   SERVICING CRITERIA** |                   |
|--------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------|------------------------|
|  

 

Reference                        |  

 

Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     | Performed by Servicer                 | Performed by Vendor(s) |   |   |
| **General Servicing Considerations**             |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |
| 1122(d)(1)(i)                                    | Policies and procedures are  instituted to monitor any performance or other triggers and events of default  in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | Y                                     |                   |   |   |
| 1122(d)(1)(ii)                                   | If any material servicing  activities are outsourced to third parties, policies and procedures are instituted  to monitor the third party's performance and compliance with such servicing  activities.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | Y                                     |                   |   |   |
| 1122(d)(1)(iii)                                  | Any requirements in the transaction  agreements to maintain a back-up servicer for the mortgage loans are maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |                                  |                   | N/A |   |
| 1122(d)(1)(iv)                                   | A fidelity bond and errors  and omissions policy is in effect on the party participating in the servicing  function throughout the reporting period in the amount of coverage required  by and otherwise in accordance with the terms of the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                    | Y#1                                   |                   |   |   |
| 1122(d)(1)(v)                                    | Aggregation  of information, as applicable, is mathematically accurate and the information  conveyed accurately reflects the information.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | Y                                     |                   |   |   |
| **Cash Collection and Administration**           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |
| 1122(d)(2)(i)                                    | Payments on mortgage loans  are deposited into the appropriate custodial bank accounts and related bank clearing  accounts no more than two business days following receipt, or such other  number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                          | Y                                     |                   |   |   |
| 1122(d)(2)(ii)                                   | Disbursements made via wire transfer on behalf of an obligor or  to an investor are made only by authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | Y                                     | Y#2                    |   |   |
| 1122(d)(2)(iii)                                  | Advances of funds or guarantees  regarding collections, cash flows or distributions, and any interest or other  fees charged for such advances, are made, reviewed and approved as specified  in the transactionagreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | Y                                     |                   |   |   |
| 1122(d)(2)(iv)                                   | The related accounts for the transaction,  such as cash reserve accounts or accounts established as a form of  overcollateralization, are separately maintained (e.g., with respect to  commingling of cash) as set forth in  the transactionagreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                | Y                                     |                   |   |   |
| 1122(d)(2)(v)                                    | Each custodial account is  maintained at a federally insured depository institution as set forth in the  transaction agreements. For purposes of this criterion, "federally insured depository institution" with  respect to a foreign financial institution means a foreign financial  institution that meets the requirements of Rule 13k-l(b)(l) of the Securities  ExchangeAct.                                                                                                                                                                                                                                                                                                                | Y                                     |                   |   |   |
| 1122(d)(2)(vi)                                   | Unissued checks are  safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | Y                                     | Y#2                    |   |   |
| 1122(d)(2)(vii)                                  | Reconciliations are  prepared on a monthly basis for all commercial mortgage securities related  bank accounts, including custodial accounts and related bank clearing  accounts. These reconciliations are (A) mathematically accurate; (B) prepared  within 30 calendar days after the bank statement cutoff date, or such other  number of days specified in the transaction agreements; (C) reviewed and approved by someone other than the person who  prepared the reconciliation; and (D) contain explanations for reconcilingitems.Thesereconcilingitemsareresolved within 90  calendar days of their original identification, or such other number of days  specified in the transactionagreements. | Y                                     | Y#3                    |   |   |
| **Investor Remittances and Reporting**           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |
| 1122(d)(3)(i)                                    | Reports to investors,  including those to be filed with the Commission, are maintained in accordance  with the transaction agreements and applicable Commission requirements.  Specifically, suchreports (A) are  prepared in accordance with timeframes and other terms set forth in the  transaction agreements; (B) provide information calculated in accordance with  the terms specified in the transaction agreements; (C) are filed with the Commission as required by its rules and  regulations; and (D) agree with investors' or the trustee's records as to the  total unpaid principal balance and number of mortgage loans serviced by the  Servicer.                                           | Y for (A&B)                       |                   | N/A for (C&D) |   |
| 1122(d)(3)(ii)                                   | Amounts due to investors are allocated and remitted in  accordance with timeframes, distribution priority andothertermssetforthinthetransactionagreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |                                  |                   | N/A |   |
| 1122(d)(3)(iii)                                  | Disbursements made to an investor  are posted within two business days to the Servicer's investor records, or  such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |                                  |                   | N/A |   |
| 1122(d)(3)(iv)                                   | Amounts remitted to investors  per the investor reports agree with cancelled checks, or other form of  payment, or custodial bankstatements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |                                  |                   | N/A |   |
| **Pool Asset Administration**                    |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |
| 1122(d)(4)(i)                                    | Collateral or security on mortgage  loans is maintained as required by the transaction agreements or related  mortgage loan documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | Y                                     |                   |   |   |
| 1122(d)(4)(ii)                                   | Mortgage loan and related  documents are safeguarded as required by the transaction agreements                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | Y#4                                   |                   |   |   |
| 1122(d)(4)(iii)                                  | Any additions, removals or  substitutions to the asset pool are made, reviewed and approved in accordance  with any conditions or requirements in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | Y#5                                   |                   |   |   |
| 1122(d)(4)(iv)                                   | Payments on mortgage loans,  including any payoffs, made in accordance with the related mortgage loan  documents are posted to  the  Servicer's  obligor records  maintained no more than two business days after receipt, or such other number  of days specified in the transaction agreements, and allocated to principal,  interest or other items (e.g., escrow) in accordance with  the   related  mortgage  loan documents.                                                                                                                                                                                                                                        | Y                                     |                   |   |   |
| 1122(d)(4)(v)                                    | The Servicer's records regarding  the mortgage loans agree with the Servicer's records with respect to an  obligor's unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | Y                                     |                   |   |   |
| 1122(d)(4)(vi)                                   | Changes with respect to the  terms or status of an obligor's mortgage loans (e.g., loan modifications or  re-agings) are made, reviewed and approved by authorized personnel in  accordance with the transaction agreements and related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                | Y                                     |                   |   |   |
| 1122(d)(4)(vii)                                  | Loss  mitigation or recovery actions (e.g., forbearance plans, modifications and  deeds in lieu of foreclosure, foreclosures and repossessions, as applicable)  are initiated, conducted and concluded in accordance with the timeframes or other  requirements established by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                   | Y#6                                   |                   |   |
| 1122(d)(4)(viii)                                 | Records  documenting collection efforts are maintained during the period a mortgage loan  is delinquent in accordance with the transaction agreements. Such records are  maintained on at least a monthly basis, or such other period specified in the  transaction agreements, and describe the entity's activities in monitoring  delinquent mortgage loans including, for example, phone calls, letters and  payment rescheduling plans in cases where delinquency is deemed temporary  (e.g., illness or unemployment).                                                                                                                                                                                  | Y                                     |                   |   |
| 1122(d)(4)(ix)                                   | Adjustments  to interest rates or rates of return for mortgage loans with variable rates  are computed based on the related mortgage loan documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | Y                                     |                   |   |
| 1122(d)(4)(x)                                    | Regarding  any funds held in trust for an obligor (such as escrow accounts): (A) such  funds are analyzed, in accordance with the  obligor's mortgage loan  documents, on at least an annual basis, or such other period specified in the  transaction agreements; (B) interest on such funds is paid, or credited, to  obligors in accordance with applicable mortgage loan documents and state  laws; and (C) such funds are returned to the obligor within 30 calendar days  of full repayment of the related mortgage loans, or such other number of days  specified in the transaction agreements.                                                                                                 | Y                                     |                   |   |
| 1122(d)(4)(xi)                                   | Payments  made on behalf of an obligor (such as tax or insurance payments) are made on  or before the related penalty or expiration dates, as indicated on the  appropriate bills or notices for such payments, provided that such support has  been received by the servicer at least 30 calendar days prior to these dates,  or such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                         | Y                                     | Y#2                    |   |
| 1122(d)(4)(xii)                                  | Any  late payment penalties in connection with any payment to be made on behalf of  an obligor are paid from the Servicer's funds and not charged to the obligor,  unless the late payment was due to the obligor's error or omission.                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | Y                                     | Y#2                    |   |
| 1122(d)(4)(xiii)                                 | Disbursements made on  behalf of an obligor are posted within two business days to the obligor's  records maintained by the Servicer, or such other number of days specified in  the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | Y                                     |                   |   |
| 1122(d)(4)(xiv)                                  | Delinquencies, charge-offs  and uncollectible accounts are recognized and recorded in accordance with the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | Y                                     |                   |   |
| 1122(d)(4)(xv)                                   | Any external enhancement or  other support, identified in Item 1114(a)(1) through (3) or Item 1115 of  Regulation AB, is maintained as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |                                  |                   | N/A |
|                                             |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |                                  |                   |   |   |   |   |   |   |   |

 

**Y**=Yes

 

**Y#l** = Fidelity bond and errors and omissions policies inforce for Prudential. In addition, fidelity bond and errors and omissionspolicies are in force for the following vendors: Silverskills ($1MM), NTS($2MM) and Covius ($1MM).

 

**Y#2** = The only third party vendor to whom this applies isNational Tax Search, LLC (NTS). PAR transferred to the vendor the process ofpaying property taxes to the local government taxing authorities. Payment ismade only after review, authorization and transfer of funds is completed byPAR. Policies and procedures are in place to monitor this vendor.

 

**Y#3** = Silverskills Private Limited (SPL) performs monthlyP&I, Tax & Insurance, Reserve, and Suspense account compilationsincluding review and approval of all self reconciling bank accounts. PAR hasprocedures in place to review work performed by SPL.

 

**Y#4** = As outlined in the PSAs, the primary responsibilityfor safeguarding all original documents (except Letters of Credit, which areheld by PAR) is with the named Document Custodian. The named Trustee hasoversight responsibility for the custodian, not the Servicer. However, to theextent that loans are secured by Letters of Credit or loans are modified orsome other credit action occurs which generates a new or revised loan document,then Servicer complies with this criteria.

 

**Y#5** = PAR's role related to additions, removals orsubstitutions to the asset pool only occurs after a decision is made to somodify the asset pool.  The responsibility and any decisions related toadditions, removals or substitutions to the asset pool is with the Trustee,Issuer and related mortgage loan seller. PAR as Servicer has not experiencedany of these types of actions in its CMBS asset pools.

 

**Y#6** = There are currently no transactions during the yearthat applied to this servicing criteria within the Reg AB where PAR was namedthe special servicer.

 

**N/A** = Not applicable, as the criteria is not theresponsibility of the primary/master servicer or no event has occurred whichtriggered an action by the primary/master servicer.

 

 

**EXHIBIT C**

 

**List of CommercialMortgage-Backed Security Transactions - RegAB Portfolio**

 

 

1. Morgan Stanley Capital IInc., Commercial Mortgage Pass-Through Certificates, Series 2006-IQ12("MSCI 2006-IQ12")

 

2. Merrill Lynch MortgageTrust 2006-C2, Commercial Mortgage Pass-Through Certificates, Series 2006-C2("MLMT 2006-C2")

 

3. Bear Steams CommercialMortgage Securities II Inc., Commercial Mortgage Pass-Through Certificates,2006-PWR11 ("BSCMS 2006-PWR11")

 

4. Bear Steams CommercialMortgage Securities Inc., Commercial Mortgage Pass-Through Certificates,2006-PWR12 ("BSCMS 2006-PWR12")

 

5. Bear Stearns CommercialMortgage Securities Inc., Commercial Mortgage Pass-Through Certificates,2006-PWR 13 ("BSCMS 2006-PWR13")

 

6. Bear Stearns CommercialMortgage Securities Inc., Commercial Mortgage Pass-Through Certificates,2006-PWR14 ("BSCMS 2006-PWR14")

 

7. Bear Stearns Commercial MortgageSecurities Inc., Commercial Mortgage Pass-Through Certificates, 2007-PWR15("BSCMS 2007-PWR15")

 

8. Morgan Stanley Capital IInc., Commercial Mortgage Pass-Through Certificates, Series 2007-IQ14("MSCI 2007-IQ14")

 

9. Bear Stearns Commercial MortgageSecurities Inc., Commercial Mortgage Pass-Through Certificates, 2007-PWR16("BSCMS 2007-PWR16")

 

10. Morgan Stanley Capital IInc., Commercial Mortgage Pass-Through Certificates, 2007-IQ15 ("MSCI2007-IQ15")

 

11. Bear Stearns CommercialMortgage Securities Inc., Commercial Mortgage Pass-Through Certificates,2007-PWR17 ("BSCMS 2007-PWR17")

 

12. Bear Stearns CommercialMortgage Securities Inc., Commercial Mortgage Pass-Through Certificates,2007-PWR18 ("BSCMS 2007-PWR18")

 

13. WFRBS Commercial MortgageTrust 2012-C6, Commercial Mortgage Pass-Through Certificates, Series 2012-C6

 

14. WFRBS Commercial MortgageTrust 2012-C7, Commercial Mortgage Pass-Through Certificates, Series 2012-C7

 

15. WFRBS Commercial MortgageTrust 2012-C8, Commercial Mortgage Pass-Through Certificates, Series 2012-C8

 

16. RBS Commercial FundingInc., Commercial Mortgage Pass-Through Certificates, Series 2012-C9

 

17. WFRBS Commercial MortgageTrust 2012-C10, Commercial Mortgage Pass-Through Certificates, Series 2012-C10

 

18. RBS Commercial FundingInc., Commercial Mortgage Pass-Through Certificates, Series 2013- C11

 

19. WFRBS Commercial MortgageTrust 2013-C12, Commercial Mortgage Pass-Through Certificates, Series 2013-C12

 

20. WFRBS Commercial Mortgage Trust2013-C13, Commercial Mortgage Pass-Through Certificates, Series 2013-C13

 

21. WFRBS Commercial MortgageTrust 2013-C14, Commercial Mortgage Pass-Through Certificates, Series 2013-C14

 

22. RBS Commercial Funding Inc.,Commercial Mortgage Pass-Through Certificates, Series 2013- C15

 

23. WFRBS Commercial MortgageTrust 2013-C16, Commercial Mortgage Pass-Through Certificates, Series 2013-C16

 

24. WFRBS Commercial MortgageTrust 2013-C17, Commercial Mortgage Pass-Through Certificates, Series 2013-C17

 

25. WFRBS Commercial MortgageTrust 2013-C18, Commercial Mortgage Pass-Through Certificates, Series 2013-C18

 

26. COMM 2013-CCRE13 MortgageTrust Commercial Mortgage Pass-Through Certificates

 

27. COMM 2014-CCRE14 MortgageTrust Commercial Mortgage Pass-Through Certificates

 

28. RBS Commercial FundingInc., Commercial Mortgage Pass-Through Certificates, Series 2014- C19

 

29. WFRBS Commercial MortgageTrust 2014- C20, Commercial Mortgage Pass-Through Certificates, Series 2014-C20

 

30. RBS Commercial FundingInc., Commercial Mortgage Pass-Through Certificates, Series 2014- C21

 

31. WFRBS Commercial MortgageTrust 2014-C22, Commercial Mortgage Pass-Through Certificates, Series 2014-C22

 

32. RBS Commercial Funding Inc.,Commercial Mortgage Pass-Through Certificates, Series 2014- C23

 

33. WFRBS Commercial MortgageTrust 2014-C24, Commercial Mortgage Pass-Through Certificates, Series 2014-C24

 

34. Wells Fargo CommercialMortgage Trust 2014-LC18, Commercial Mortgage Pass-Through Certificates, Series2014-LC18

 

35. RBS Commercial FundingInc., Commercial Mortgage Pass-Through Certificates, Series 2014- C25

 

36. Wells Fargo CommercialMortgage Trust 2015-C26, Commercial Mortgage Pass-Through Certificates, Series2015-C26

 

37. Wells Fargo CommercialMortgage Trust 2015-C27, Commercial Mortgage Pass-Through Certificates, Series2015-C27

 

38. Wells Fargo CommercialMortgage Trust 2015-C28, Commercial Mortgage Pass-Through Certificates, Series2015-C28

 

39. Wells Fargo CommercialMortgage Trust 2015-SG1, Commercial Mortgage Pass-Through Certificates, Series2015-SG1

 

40. Wells Fargo CommercialMortgage Trust 2015-C31, Commercial Mortgage Pass-Through Certificates, Series2015-C31

 

41. CFCRE 2016-C3 MortgageTrust, Commercial Mortgage Pass-Through Certificates, Series 2016-C3

 

42. SG Commercial MortgageSecurities Trust 2016-C5, Commercial Mortgage Pass-Through Certificates Series2016-C5