**MANAGEMENT’S ASSERTION OFCOMPLIANCE**

 

Management of the Agency andTrust division of Citibank, N.A. (or “Company”) is responsible for assessingcompliance 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, certificateadministration and trustee; or

·        certificate administration andpaying agent

 

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)(1)(iii), 1122(d)(4)(i)-1122(d)(4)(ii) and1122(d)(4)(iv)-1122(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 criterion 1122(d)(1)(v) isapplicable only to the activities the Company performs related to themathematically accurate aggregation of information received from servicers andthe 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 to investorsin accordance with the transaction agreements. With respect to servicingcriteria 1122(d)(2)(iii) and 1122(d)(4)(iii), there were no activitiesperformed during the twelve months ended December 31, 2021 with respect to thePlatform, because there were no occurrences of events that would require theCompany to perform such activities.

 

Period: Twelve months ended December 31, 2021 (the “Period”).

 

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

 

·        The Company’s management isresponsible for assessing the Company’s compliance with the ApplicableServicing Criteria.

 

·        The Company’s management hasassessed compliance with the Applicable Servicing Criteria. In making thisassessment, management used the criteria set forth by the Securities andExchange Commission in paragraph (d) of Item 1122 of Regulation AB.

 

·        Based on such assessment, theCompany has complied, in all material respects, with the Applicable ServicingCriteria.

 

KPMG LLP, an independentregistered public accounting firm, has issued an attestation report withrespect to management’s assertion of compliance with the Applicable ServicingCriteria as of and for the Period. 

 

 

**CITIBANK, N.A.**

 

 

By: /s/Karen J. Montbach

Karen J. Montbach

Its: Managing Director

Dated: February 28, 2022

 

 

Appendix A

 

Mortgage-backedTransactions and Securities Constituting the Platform

 

**DEAL NAME**

 

| Benchmark 2021-B31         | CGCMT 2016-P3                             |
|----------------------------|-------------------------------------------|
| BMARK 2018-B3              | CGCMT 2016-P5                             |
| BMARK 2018-B6              | CGCMT 2017-B1                             |
| BMARK 2019-B12             | CGCMT 2017-C4                             |
| BMARK 2019-B15             | CGCMT 2017-P7                             |
| BMARK 2019-B9              | CGCMT 2017-P8                             |
| BMARK 2020-B19             | CGCMT 2018-B2                             |
| BMARK 2021-B23             | CGCMT 2018-C5                             |
| BMARK 2021-B27             | CGCMT 2018-C6                             |
| BXCMT 2020-VIVA            | CGCMT 2019-C7                             |
| CCMT 2015-GC27             | CGCMT 2019-GC41                           |
| CCMT16C2                   | CGCMT 2019-GC43                           |
| CCMT16GC37                 | CGCMT 2020-420K                           |
| CCMT16P4                   | CGCMT 2020-555                            |
| CCMT16P6                   | CGCMT 2020-GC46                           |
| CD 2017-CD5 Mortgage Trust | CGCMT 225 Liberty Street  Trust 2016-225L |
| CF 2019-CF1 Mortgage Trust | GSMC 2011-GC3                             |
| CF 2019-CF2 Mortgage Trust | GSMST-2011GC5                             |
| CFCRE 2011-C2              | MAD 2019-650M                             |
| CFK Trust 2020-MF2         | MSBAM Trust Series 2014-C17               |
| CGCMT 2012-GC8             | NYC 2021-909                              |
| 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-P1              |                                      |
| CGCMT 2016-C1              |                                      |
| CGCMT 2016-C3              |                                      |