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**REPORTOF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM**

 

Boardof Managers

BerkadiaCommercial Mortgage LLC

 

We have examined management's assertion, includedin the accompanying Management's Report on Assessment of Compliance with SECRegulation AB ServicingCriteria as Primary Servicer ("Management'sReport"),that Berkadia Commercial Mortgage LLC (the"Company") complied with the servicing criteria set forth in Item1122(d) of the U.S. Securities and Exchange Commission's Regulation AB forthe primary servicing of commercial mortgage loans sold in public securitizations (the “Platform”) as of and for the year ended December31, 2019, excluding criteria 1122(d)(1)(iii), (3)(i)(C), (4)(ii),(4)(vii), and (4)(xv), which management has determined are not applicable tothe activities performed by the Company with respect to the Platform. ThePlatform consists of the publicly issued asset-backed transactions andsecurities for which the Company is named the primary servicer of commercialmortgage loans. Management is responsible for the Company’s compliance with theapplicable servicing criteria. Our responsibility is to express an opinion on management’s assertion about the Company’s compliancewith the applicable servicing criteria for the Platform based on ourexamination.

 

Ourexamination was conducted in accordance with the standards of the PublicCompany Accounting Oversight Board (United States) and in accordance withattestation standards established by the American Institute of Certified PublicAccountants, and, accordingly, included examining, on a test basis, evidenceabout the Company’s compliance with the applicable servicing criteria for thePlatform and performing such other procedures as we considered necessary in thecircumstances. Our examination included testing selected asset-backedtransactions and securities constituting the Platform and evaluating whetherthe Company performed servicing activities related to those transactions andsecurities in compliance with the applicable servicing criteria for the periodcovered by this report. Accordingly, our testing may not have includedservicing activities related to each asset-backed transaction or securityconstituting the Platform. Further, our examination was not designed to detectmaterial noncompliance that may have occurred prior to the period covered bythis report and that may have affected the Company’s servicing activitiesduring the period covered by this report. We believe that our examinationprovides a reasonable basis for our opinion. Our examination does not provide alegal determination on the Company’s compliance with the applicable servicingcriteria.

 

Asdescribed in Management’s Report, the Company engaged various vendors toperform servicing activities with respect to criteria 1122(d)(4)(i) and (4)(xi)through 1122(d)(4)(xiii). The Company determined that each vendor is notconsidered a “servicer,” as that term is defined in Item 1101(j) of RegulationAB, and therefore, the Company is assuming responsibility for compliance withsuch servicing criteria applicable to each vendor’s servicingactivities.  In accordance with Regulation AB and its relatedinterpretations, the requirement for management to assess compliance with theservicing criteria applicable to a vendor’s activities is satisfied if theCompany has instituted policies and procedures to monitor whether such vendor’sactivities comply in all material respects with such criteria. Compliance withthe applicable servicing criteria is achieved if those policies and proceduresare designed to provide reasonable assurance that such vendor’s activitiescomply with such criteria and those policies and procedures are operatingeffectively for the period covered by Management’s Report.  Ourexamination does not provide a legal determination of whether a vendor is or isnot considered a servicer, and therefore, on whether the Company, in itsManagement Report, is eligible to elect to take responsibility for assessingcompliance with the servicing criteria applicable to each vendor’s servicingactivities

 

Inour opinion, management’s assertion that Berkadia Commercial Mortgage LLCcomplied with the aforementioned applicable servicing criteria as of and of theyear ended December 31, 2019 for the Primary Servicing Platform is fairlystated, in all material respects.

 

/s/Grant Thornton LLP

 

Philadelphia,Pennsylvania 

February14, 2020

 

 

GT.COM

 

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