**MANAGEMENT'S ASSERTION OF COMPLIANCE**

 

 

Management of the Agency andTrust division of Citibank, N.A. (or "Company") is responsible forassessing compliance with the servicing criteria set forth in Item 1122(d) of RegulationAB promulgated by the Securities and Exchange Commission.

 

Management has determined thatthe servicing criteria set forth in Item 1122(d) of Regulation AB areapplicable in regard to the servicing platform as of and for the period asfollows:

 

Platform: Publicly-issued (*i.e*., transaction-levelreporting initially required under the Securities Exchange Act of 1934, asamended) and certain privately-issued (*i.e*., for which transaction-levelreporting is required pursuant to contractual obligation) commercialmortgage-backed securities issued on or after January 1, 2011, as listed inAppendix A, for which the Company provides the following servicing functions(the "Platform"):

 

·        paying agent, certificate administrationand trustee; or

·        certificate administration and payingagent

 

ApplicableServicing Criteria: All servicingcriteria set forth in Item 1122(d), to the extent required by Item 1122(d)servicing criteria in regards to the activities performed by the Company withrespect to the Platform as to any transaction, except for the followingservicing criteria: 1122(d)(l)(iii), 1122(d)(4)(i)-1122(d)(4)(ii) andl122(d)(4)(iv)-l122(d)(4)(xv), which management has determined are notapplicable to the activities the Company performs with respect to the Platform(the "Applicable Servicing Criteria"). Servicing criterion1122(d)(l)(v) is applicable only to the activities the Company performs relatedto the mathematically accurate aggregation of information received from servicersand the accurate conveyance of such information within reports to investors.Servicing criterion 1122(d)(4)(iii) is applicable to the activities the Companyperforms with respect to the Platform only as it relates to the Company'sobligation to report additions, removals or substitutions on reports toinvestors in accordance with the transaction agreements. With respect toservicing criteria 1122(d)(2)(iii) and 1122(d)(4)(iii), there were noactivities performed during the twelve months ended December 31, 2019 withrespect to the Platform, because there were no occurrences of events that wouldrequire the Company to perform such activities.

 

Period: Twelve months ended December 31, 2019 (the"Period").

 

With respect to the Platformas of and for the Period, the Company's management provides the followingassertion of compliance with respect to the Applicable Servicing Criteria:

 

·        The Company's management is responsiblefor assessing the Company's compliance with the Applicable Servicing Criteria.

 

·        The Company's management has assessedcompliance with the Applicable Servicing Criteria. In making this assessment,management used the criteria set forth by the Securities and ExchangeCommission in paragraph (d) of Item 1122 of Regulation AB.

 

·        Based on such assessment, the Company hascomplied, in all material respects, with the Applicable Servicing Criteria.

 

KPMG LLP, an independentregistered public accounting firm, has issued an attestation report with respectto management's assertion of compliance with the Applicable Servicing Criteriaas of and for the Period.

 

 

**CITIBANK, N.A.**

** **

By: /s/ Mary McNiff

Its: Managing Director

 

Dated: February 28, 2020

 

 

Appendix A

 

Mortgage-backed Transactions and SecuritiesConstituting the Platform

 

**DEAL NAME**

BMARK 2018-B3 

BMARK 2018-B6 

BMARK 2019-Bl2

BMARK 2019-B15

BMARK 2019-B9 

CCMT 2015-GC27

CCMT16C2

CCMT16GC37

CCMT16P4

CCMT16P6

CD 2017-CD5 Mortgage Trust

CF 2019-CF1 Mortgage Trust

CF 2019-CF2 Mortgage Trust

CFCRE 201l-C2

CGBAM 2015-SMRT

CGCMT 2012-GC8

CGCMT 2013-375P 

CGCMT 2013-GC15

CGCMT 2013-GC17

CGCMT 2013-GCJ11

CGCMT 2014-GC23

CGCMT 2014-GC25

CGCMT 2015-GC29 

CGCMT 2015-GC31

CGCMT 2015-GC33

CGCMT 2015-GC35 

CGCMT 2015-Pl 

CGCMT 2016-C1

CGCMT 2016-C3 

CGCMT 2016-P3

CGCMT 2016-P5

CGCMT2017-Bl 

CGCMT 2017-C4

CGCMT 2017-P7

CGCMT 2017-P8

CGCMT 2018-B2

CGCMT 2018-C5

CGCMT 2018-C6

CGCMT 2019-C7

CGCMT 2019-GC4I 

CGCMT 2019-GC43

CGCMT 225 Liberty Street Trust2016-225L 

GSMC 2011-GC3

GSMST-2011GC5

MAD 2019-650M

MSBAM Trust Series 2014-C17