(logo)CWCapital 

ASSET MANAGEMENT 

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**February28, 2019**

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**Management’sAssertion on Compliance with Regulation AB Criteria**

 

Re:Assessment of Compliance for services provided pursuant to the Pooling andServicing Agreements entered into by CWCapital Asset Management LLC beginningJanuary 1, 2006 for the 12 month period ended December 31, 2018.

 

CWCapitalAsset Management LLC (“CWCAM”) is responsible for assessing compliance withapplicable servicing criteria set forth in Item 1122 (d) of Regulation AB ofthe Securities and Exchange Commission for the securitizations issued beginningJanuary 1, 2006, as listed on Appendix A (“Applicable Servicing Criteria”).

 

CWCAMhas assessed its compliance with the applicable servicing criteria as ofDecember 31, 2018 and for the period from January 1, 2018 to December 31, 2018(the “Reporting Period”).  In making this assessment, management used thecriteria set forth by the Securities and Exchange Commission in paragraph (d)of Item 1122 of Regulation AB, excluding the criteria set forth in Item 1122(d)(1)(iii), (d)(3)(i)(b), (d)(3)(i)(c), (d)(3)(i)(d), (d)(3)(ii), (d)(3)(iii),(d)(3)(iv), (d)(4)(v), (d)(4)(ix), (d)(4)(x), (d)(4)(xi), (d)(4)(xii),(d)(4)(xiii), (d)(4)(xiv), and (d)(4)(xv) of Regulation AB, which CWCAM hasconcluded are not applicable to the activities it performs (collectively, the“Not Applicable Criteria”). With respect to applicable servicing criteria(d)(1)(ii), (d)(2)(vi), (d)(4)(i), (d)(4)(iii), and (d)(4)(iv), CWCAM hasdetermined that there were no occurrences of events that would require CWCAM toperform such activities. The securitizations covered by this report include allsecuritizations wherein CWCAM is named as the Special Servicer for securitizationsissued beginning January 1, 2006, as listed in Appendix B (the “Platform”).

 

Basedon such assessment, management believes, as of December 31, 2018 and for theReporting Period, the following:

1) CWCAM has determined that the NotApplicable Criteria are in fact not applicable to the activities it performswith respect to the Platform.

2) CWCAM has complied in all materialrespects with the servicing criteria set forth in Item 1122 (d), with theexception of the Not Applicable Criteria and any material instance ofnoncompliance described in Schedule A hereto.

 

ScheduleB hereto includes Management’s Discussion of the Material Instance ofNoncompliance noted in Schedule A.

 

CohnReznickLLP, an independent registered public accounting firm, has issued an attestationreport on CWCAM’s compliance with the Applicable Servicing Criteria as ofDecember 31, 2018 and for the Reporting Period.

 

 

CWCapitalAsset Management LLC

 

 

By:/s/ David B. Iannarone

DavidB. Iannarone

ChiefExecutive Officer

Date:February 28, 2019

 

 

By:/s/ James P. Shevlin

JamesP. Shevlin

President/ChiefOperating Officer

Date:February 28, 2019

 

 

By:/s/ Bruce Cunningham

BruceCunningham

ChiefFinancial Officer

Date:February 28, 2019

 

 

Schedule A

 

**Material Instance ofNoncompliance**

 

CWCAM’sassessment of compliance with the Applicable Servicing Criteria set forth bythe Securities and Exchange Commission in paragraph (d) of Item 1122 ofRegulation AB as of December 31, 2018 and for the Reporting Period, disclosed amaterial instance of noncompliance occurred with respect to the servicingcriterion set forth in 1122(d)(2)(vii), as follows:

 

 

•         Withrespect to compliance 1122(d)(2)(vii), CWCAM’s policies and procedures were notproperly followed with respect to timely completion of bank reconciliations.

 

 

Schedule B

 

**Management’sDiscussion on Material Instance of Noncompliance**

 

 

1122(d)(2)(vii),Reconciliations are prepared on a monthly basis for all asset-backed securitiesrelated bank accounts, including custodial accounts and related bank clearingaccounts. These reconciliations (A) are mathematically accurate; (B) areprepared within 30 calendar days after the bank statement cutoff date, or suchother number of days specified in the transaction agreements; (C) are reviewedand approved by someone other than the person who prepared the reconcilingitems; and (D) contain explanations for reconciling items. These reconcilingitems are resolved within 90 calendar days of their original identification, orsuch other number of days specified in the transaction agreements.

 

 

Noncompliance

 

Theinstance of material noncompliance, for the Reporting Period included a failureto complete the required bank reconciliations within 30 calendar days after thebank statement cutoff date.  In five of the twelve months related to theReporting Period, the required reconciliations were not completed within the 30calendar days requirement as follows:

 

February 2018: bank reconciliations wereprepared on June 22, 2018

 

March 2018: bank reconciliations wereprepared on May 1, 2018

 

September 2018: bank reconciliations wereprepared on November 6, 2018

 

November 2018: bank reconciliations wereprepared on February 19, 2019

 

December 2018: bank reconciliations wereprepared on February 6, 2019

 

 

Remediation

 

Inresponse to the lack of adherence to company policy and procedures, theCompliance Committee reviewed the reasons for noncompliance and added twoadditional procedures to supplement its existing procedures:

 

1) the accounting department has added thecompletion of bank account reconciliations within 30 calendar days to itsmonthly closing checklist, which is reviewed and signed off by a CWCAM officer;and

2) the Chief Financial Officer has set upa monthly electronic reminder requiring that the completed bank reconciliationsbe forwarded to the CFO for an additional layer of review.

 

 

Appendix A

 

|             | ***Relevant   Servicing Criteria***                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |                                                                                                                                                  |
|------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------|
| **Reference**    | **Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | **CWCAM**                                                                                                                                             |
|             | **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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | Applicable                                                                                                                                            |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | Applicable                                                                                                                                            |
| 1122(d)(1)(iii)  | Any  requirements in the transaction agreements to maintain a back-up servicer for  the mortgage loans are maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | Not Applicable                                                                                                                                        |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | Applicable                                                                                                                                            |
| 1122(d)(1)(v)    | Aggregation  of information, as applicable, is mathematically accurate and the information  conveyed accurately reflects the information.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | Applicable                                                                                                                                            |
|             | **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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | Applicable                                                                                                                                            |
| 1122(d)(2)(ii)   | Disbursements  made via wire transfer on behalf of an obligor or to an investor are made  only by authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | Applicable                                                                                                                                            |
| 1122(d)(2)(iii)  | Advances  of funds or guarantees regarding collections, cash flows or distributions,  and any interest or other fees charged for such advances, are made, reviewed  and approved as specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | Applicable                                                                                                                                            |
| 1122(d)(2)(iv)   | The  related accounts for the transaction, such as cash reserve accounts or  accounts established as a form of overcollateralization, are separately  maintained (e.g., with respect to commingling of cash) as set forth in the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | Applicable                                                                                                                                            |
| 1122(d)(2)(v)    | Each  custodial account is maintained at a federally insured depository institution  as set forth in the transaction agreements.  For purposes of this  criterion, “federally insured depository institution” with respect to a  foreign financial institution means a foreign financial institution that  meets the requirements of Rule 13k-1(b)(1) of the Securities Exchange  Act.                                                                                                                                                                                                                                                                                                                                           | Applicable                                                                                                                                            |
| 1122(d)(2)(vi)   | Unissued  checks are safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | Applicable                                                                                                                                            |
| 1122(d)(2)(vii)  | Reconciliations  are prepared on a monthly basis for all asset-backed securities related bank  accounts, including custodial accounts and related bank clearing  accounts.  These reconciliations (A) are mathematically accurate;  (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. | Applicable                                                                                                                                            |
|             | **Investor  Remittances and Reporting**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                                                                                                                                  |
| 1122(d)(3)(i)    | Reports  to investors, including those to be filed with the Commission, are maintained  in accordance with the transaction agreements and applicable Commission  requirements.  Specifically, such reports (A) are prepared in  accordance with timeframes and other terms set forth in the transaction  agreements; (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.                                              | (A)    Applicable

(B)    Not  Applicable

(C)    Not  Applicable

(D)    Not  Applicable |
| 1122(d)(3)(ii)   | Amounts  due to investors are allocated and remitted in accordance with timeframes,  distribution priority and other terms set forth in the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | Not Applicable                                                                                                                                        |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | Not Applicable                                                                                                                                        |
| 1122(d)(3)(iv)   | Amounts  remitted to investors per the investor reports agree with cancelled checks,  or other form of payment, or custodial bank statements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | Not Applicable                                                                                                                                        |
|             | **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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | Applicable                                                                                                                                            |
| 1122(d)(4)(ii)   | Mortgage  loan and related documents are safeguarded as required by the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | Applicable                                                                                                                                            |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | Applicable                                                                                                                                            |
| 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.                                                                                                                                                                                                                                                                                                                      | Applicable                                                                                                                                            |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | Not Applicable                                                                                                                                        |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | Applicable                                                                                                                                            |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                         | Applicable                                                                                                                                            |
| 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).                                                                                                                                                                                                                | Applicable                                                                                                                                            |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | Not Applicable                                                                                                                                        |
| 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.                                                                                                                      | Not Applicable                                                                                                                                        |
| 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.                                                                                                                                                                                                                                                                                                                                                   | Not Applicable                                                                                                                                        |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     | Not Applicable                                                                                                                                        |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     | Not Applicable                                                                                                                                        |
| 1122(d)(4)(xiv)  | Delinquencies,  charge-offs and uncollectible accounts are recognized and recorded in  accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     | Not Applicable                                                                                                                                        |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | Not Applicable                                                                                                                                        |

 

 

Appendix B

 

 

| AVENTURA 2018-AVM | GSMS 2012-GCJ7       | UBS 2012-C2     |
|-------------------|----------------------|-----------------|
| BACM 2006-6       | GSMS 2014-GC22       | UBS 2017-C1     |
| BACM 2007-1       | GSMSC 2014-GC26      | WBCMT 2006-C23  |
| BACM 2007-2       | GSMS 2015-GC32       | WBCMT 2006-C25  |
| BACM 2007-3       | HHPT 2017-HYT2 MZB   | WBCMT 2006-C26  |
| BACM 2007-4       | JPMBB 2014-C23       | WBCMT 2006-C28  |
| BACM 2007-5       | JPMC 2006-CIBC17     | WBCMT 2007-C30  |
| BACM 2008-1       | JPMC 2006-LDP9       | WBCMT 2007-C32  |
| BANK 2017-BNK5    | JPMC 2007-CIBC18     | WBCMT 2007-C34  |
| BHMS 2018-ATLS    | JPMC 2008-C2         | WFCM 2015-C30   |
| BMARK2018-B2      | JPMC 2018-LAQ        | WFCM 2016-C35   |
| BENCHMARK 2018-B4 | JPMCC 2013-LC11      | WFCM 2016-LC25  |
| BENCHMARK 2018-B8 | JPMCC 2015-FL7  | WFCM 2016-NXS6  |
| CD 2007-CD4       | JPMCC 2016-WSP MZ    | WFRBS 2013-C15  |
| CFCRE 2016-C3     | JPMCC 2017-JP7       | WFRBS 2013-UBS1 |
| CGCMT 2007-C6     | JPMDB 2017-C5        | WFRBS 2014-C21  |
| CGCMT 2016-P4     | LBCMT 2007-3    | WFRBS 2014-C22  |
| CGCMT 2016-P6     | LBUBS 2006-C4        | WFRBS 2014-C23  |
| COBALT 2007-C2    | LBUBS 2007-C2        | WFRBS 2014-C25  |
| COBALT 2007-C3    | LBUBS 2008-C1        |            |
| COMM 2006-C7      | MBR 2018-MBR         |            |
| COMM 2012-LC4     | MLCFC 2006-1         |            |
| COMM 2015-CCRE23  | MLCFC 2006-2         |            |
| COMM 2015-CCRE25  | MLCFC 2007-5         |            |
| COMM 2015-CCRE26  | MLCFC 2007-6         |            |
| COMM 2016-DC2     | MSBAM 2014-C19       |            |
| CSFB 2006-TFL2    | MSBAM 2015-C20       |            |
| CSFB 2007-C4      | MSBAM 2015-C21       |            |
| CSAIL 2017-CX10   | MSBAM 2015-C27       |            |
| DBUBS 2011-LC3    | MSC 2016-UBS11       |            |
| GRACE 2014-GRCE   | MSCI 2016-UBS9       |            |