**Management’s Certification on Compliance with ApplicableServicing Criteria**

 

 

PGIM Real Estate Loan Services, Inc. (“PGIM RELS”) isresponsible for assessing compliance by it with the servicing criteria applicableto PGIM RELS under paragraph (d) of Item 1122 of Regulation AB (the “ServicingCriteria”), as of and for the year ended December 31, 2021, as set forth in ExhibitA hereto in connection with all commercial mortgage loans serviced withinthe Platform, as set forth in Exhibit B, during the applicable period; 

 

1. Except as set forth in paragraph 3 and 4 below, theAsserting Parties used the criteria set forth in paragraph (d) of Item 1122 ofRegulation AB to assess the compliance with the Servicing Criteria; 

 

2. The criteria described as not applicable on Exhibit Ahereto are inapplicable to the Asserting Parties based on the activities ofPGIM RELS perform with respect to commercial mortgage securities transactionsinvolving mortgage loans, also PGIM RELS has identified specific servicingcriteria for which no transaction activity occurred; 

 

3. PGIM RELS  has engaged certain vendor(s), which arenot deemed to be servicers as defined in Item 1101(j) of Regulation AB (the“Vendor(s)”), to perform specific and limited activities or activities scriptedby the PGIM RELS as of and during the Reporting Period, and the PGIM RELSelects to take responsibility for assessing compliance with the ServicingCriteria or portion of the Servicing Criteria applicable to such Vendor(s),excluding National Tax Search, LLC (“NTS”) for which CoreLogic Solutions, LLC(“CoreLogic”) acted as the tax service provider, as set forth in Exhibit Ahereto (such criteria, the “Applicable Servicing Criteria Performed by Vendor(s)”).

 

PGIM RELS has policies and procedures in place designed toprovide reasonable assurance that the Vendor(s)’ activities comply in allmaterial respects for purposes of Regulation AB with the Applicable VendorServicing Criteria. PGIM RELS (i) has not identified and are not aware of anymaterial instance of noncompliance by the Vendor(s) with the Applicable VendorServicing Criteria that would affect PGIM RELS’s compliance and (ii) has notidentified any material deficiency in PGIM RELS’s policies and procedures tomonitor the compliance by the Vendor(s) with the Applicable Servicing CriteriaPerformed by Vendor(s) as of December 31, 2021 and for the Reporting Period.

 

4. PGIM RELS has engaged NTS, for which CoreLogic acted asthe tax service provider, to perform specific and limited activities as of andduring the Reporting Period. PGIM RELS is relying on CoreLogic’s Management’sAssertion on Assessment of Compliance with SEC Regulation AB ServicingCriteria, which includes commercial mortgage loan outsourcing customers on theNTS 2001 platform, as issued by Grant Thornton LLP dated January 31, 2022 withrespect to the portion of the Servicing Criteria applicable to NTS. 

 

5. PGIM RELS has complied, in all material respects, with theServicing Criteria as of and for the year ending December 31, 2021; and

 

6. PricewaterhouseCoopers LLP has issued an attestationreport with respect to PGIM RELS’s assessment of compliance with the ServicingCriteria as of and for the year ended December 31, 2021. 

 

February 24, 2022 

 

PGIM Real Estate Loan Services, Inc.

 

/s/ Joni Brown-Haas

Joni Brown-Haas, President

 

/s/ Keith A Kehlbeck

Keith Kehlbeck, Vice President

 

 

**Exhibit A**

 

| **SERVICING CRITERIA**

**Reg AB Portfolio**                                                                                               | **APPLICABLE**

**SERVICING CRITERIA**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | **INAPPLICABLE**

**SERVICING**

**CRITERIA** |
|--------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------|
|  

Reference                                                                                                                          |  

Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | Performed by

Servicer                        | Performed by

Vendor(s) | Performed by

Other

Servicers |   |
| **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 ag reements to maintain  a back-up servicer for the mortgage loans are maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |                                          |   |   | N/A |
| 1122(d)(1)(iv)                                                                                                                             | If 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 Pool assets are deposited into the appropriate  custodial bank account and related bank clearing accounts no more than 2  business days of receipt, or such number of days specified in the transaction  agreement                                                                                                                                                                                                                                                                                                                                                                                                                                                               | 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 transaction  agreements                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | Y                                             |   |   |   |
| 1122(d)(2)(iv)                                                                                                                             | The related accounts for the transaction, such as cash  reserve accounts or accounts established as a form of O/C, are separately  maintained as set forth in the transaction agreement                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | Y                                             |   |   |   |
| 1122(d)(2)(v)                                                                                                                              | Each custodial account is maintained at a federally insured  depository institution as set forth in the transaction agreement.  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 13K1(b)(1) of the Securities Exchange Act.                                                                                                                                                                                                                                                                                          | Y                                             |   |   |   |
| 1122(d)(2)(vi)                                                                                                                             | Unissued checks are safeguarded so as to prevent  unauthorized access                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | Y                                             | Y#2a | Y#2 |   |
| 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: (1) Are mathematically accurate; (2) Are  prepared within 30 calendar days after the bank statement cutoff date, or  such other number of days specified in the transaction agreement; (3) Are  reviewed and approved by someone other than the person who prepared the  reconciliation; and (4) 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 | Y                                             |   |   |   |
| **Investor Remittances and Reporting**                                                                                                     |
| 1122(d)(3)(i)                                                                                                                              | 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; (D) Agree with  investors' or the trustee's records as to the total unpaid principal; balance  and number of pool assets serviced by the servicer.                            | Y #6 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 and other terms set forth  in the transaction agreement                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |                                          |   |   | N/A |
| 1122(d)(3)(iii)                                                                                                                            | Disbursements made to an Investor are posted within 2  business days to the Servicers investor records, or such other number of days  specified in the transaction agreement                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |                                          |   |   | 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 bank statement                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |                                          |   |   | 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 pool asset documents                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | Y                                             |   |   |   |
| 1122(d)(4)(ii)                                                                                                                             | Mortgage loan and related documents are safeguarded as  required by the transaction agreement                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | Y#3                                           |   |   |   |
| 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 agreement                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | Y#4                                           |   |   |   |
| 1122(d)(4)(iv)                                                                                                                             | Payments on mortgage loans, including any payoffs, made in  accordance with the related mortgage loan asset documents are posted to the  applicable servicer's obligor records maintained no more than 2 business days  after receipt, or such other number of days specified, in transaction  agreement and allocated to Principal, Interest, or other items 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 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 deed in lieu of foreclosure, foreclosures                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | Y#5                                           |   |   |   |
|                                                                                                                                       | and repossessions, as applicable) are initiated, conducted  and concluded in accordance with the timeframes or other requirements  established by the transaction agreements                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |                                          |   |   |   |
| 1122(d)(4)(viii)                                                                                                                           | Records documenting collection efforts are maintained  during a period a pool asset is delinquent in accordance with the transaction  agreement. 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 rate or rates of return for  mortgage loans with variable rates are computed based on the related pool asset  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#2b                                          |   |   |   |
| 1122(d)(4)(xiii)                                                                                                                           | Disbursements made on behalf of obligor are posted within 2  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 uncollected 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 

trans agreements                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |                                          |   |   | N/A |

** **

**Y** = Yes 

 

**Y#1** = Fidelity bond and errors and omissions policies in forcefor Prudential.  In addition, fidelity bond and errors and omissionspolicies are in force for the following servicer: National Tax Search, LLC(NTS) ($2MM). 

 

**Y#2** = PGIM RELS transferred the process of paying property taxesto the local government taxing authorities to NTS, a servicer, for whichCoreLogic acted as the tax service provider.  Payment is made only afterreview, authorization and transfer of funds is completed by PGIM RELS. Policiesand procedures are in place to monitor this servicer. 

 

**Y#2a** = In 2Q 2020 as a response to the Covid crisis, EDM GroupLimited (EDM), an existing Prudential vendor, started printing checks on behalfof PGIM RELS.  In the 4th quarter of 2021, this work was transitioned toanother existing Prudential vendor, Fidelity National Information Services,Inc. (FIS).  Both FIS and EDM handle this process on a large scale acrossmultiple Prudential affiliates.  As a result, PGIM RELS adopted both FISand EDM’s existing Policies and Procedures. 

 

**Y#2b** = To the extent there is a late payment penalty that is notdue to the obligor’s error or omission, such late payment penalty would be paidby PGIM RELS or NTS, for which CoreLogic acted as the tax service provider,depending on the circumstances giving rise to the late payment.  No latepayment penalties were assessed in 2021. 

 

**Y#3** = As outlined in the PSAs, the primary responsibility forsafeguarding all original documents (except Letters of Credit, which are heldby PGIM RELS) is with the named Document Custodian.  The named Trustee hasoversight responsibility for the custodian, not the Servicer.  However, tothe extent 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 criterion. 

 

**Y#4** = PGIM RELS’ 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. PGIM RELS as Servicer has notexperienced any of these types of actions in its CMBS asset pools. 

 

**Y#5** = There are currently no transactions during the year thatapplied to this servicing criteria within the Reg AB where PGIM RELS was namedthe special servicer. 

 

**Y#6** = PGIM RELS does not report to investors but reports only tothe master servicer and/or trustee. 

 

**N/A** = Not applicable, as the criteria is not the responsibilityof the primary/master servicer or no event has occurred which triggered anaction by the primary/master servicer. 

 

 

**Exhibit B**

 

List of Commercial Mortgage-Backed Security Transactions –RegAB Portfolio 

 

1. Morgan Stanley Capital I Inc.,Commercial Mortgage Pass-Through Certificates, Series 2003IQ5 ("MSCI2003-IQ5")

2. Morgan Stanley Capital I Inc., Commercial MortgagePass-Through Certificates, Series 2003IQ6 ("MSCI 2003-IQ6")

3. Bear Stearns Commercial Mortgage Securities Inc.,Commercial Mortgage Pass-Through Certificates, Series 2003-PWR2 ("BSCMS2003-PWR2")

4. Bear Stearns Commercial Mortgage Securities Inc., CommercialMortgage Pass-Through Certificates, Series 2004-PWR3 ("BSCMS2004-PWR3")

5. Bear Stearns Commercial Mortgage Securities II Inc.,Commercial Mortgage Pass-Through Certificates, Series 2004-PWR6 ("BSCMS2004-PWR6")

6. Bear Stearns Commercial Mortgage Securities Inc.,Commercial Mortgage Pass-Through Certificates, Series 2005-PWR9 ("BSCMS2005-PWR9")

7. Bear Stearns Commercial Mortgage Securities II Inc.,Commercial Mortgage Pass-Through Certificates, Series 2005-PWR10 ("BSCMS2005-PWR10")

8. Bear Stearns Commercial Mortgage Securities II Inc.,Commercial Mortgage Pass-Through Certificates, Series 2006-PWR11 ("BSCMS2006-PWR11")

9. Bear Stearns Commercial Mortgage Securities Inc.,Commercial Mortgage Pass-Through Certificates, Series 2006-PWR13 ("BSCMS2006-PWR13")

10. Bear Stearns Commercial Mortgage Securities Inc.,Commercial Mortgage Pass-Through Certificates, Series2006-PWR14 ("BSCMS2006-PWR14")

11. Bear Stearns Commercial Mortgage Securities Inc.,Commercial Mortgage Pass-Through Certificates, Series 2007-PWR16 ("BSCMS2007-PWR16")

12. Morgan Stanley Capital I Inc., Commercial MortgagePass-Through Certificates, Series 2007IQ15 ("MSCI 2007-IQ15")

13. Bear Stearns Commercial Mortgage Securities Inc.,Commercial Mortgage Pass-Through Certificates, Series 2007-PWR17 ("BSCMS2007-PWR17")

14. WFRBS Commercial Mortgage Trust 2012-C6, CommercialMortgage Pass-Through Certificates, Series 2012-C6

15. RBS Commercial Mortgage Trust 2012-C7, CommercialMortgage Pass-Through Certificates, Series 2012-C7

16. WFRBS Commercial Mortgage Trust 2012-C8, CommercialMortgage Pass-Through Certificates, Series 2012-C8

17. RBS Commercial Mortgage Trust 2012-C9, CommercialMortgage Pass-Through Certificates, Series 2012-C9

18. WFRBS Commercial Mortgage Trust 2012-C10, CommercialMortgage Pass-Through Certificates, Series 2012-C10

19. RBS Commercial Mortgage Trust 2013-C11, CommercialMortgage Pass-Through Certificates, Series 2013-C11

20. WFRBS Commercial Mortgage Trust 2013-C12, CommercialMortgage Pass-Through Certificates, Series 2013-C12

21. WFRBS Commercial Mortgage Trust 2013-C13, CommercialMortgage Pass-Through Certificates, Series 2013-C13

22. WFRBS Commercial Mortgage Trust 2013-C14, CommercialMortgage Pass-Through Certificates, Series 2013-C14

23. RBS Commercial Mortgage Trust 2013-C15, CommercialMortgage Pass-Through Certificates, Series 2013-C15

24. WFRBS Commercial Mortgage Trust 2013-C16, CommercialMortgage Pass-Through Certificates, Series 2013-C16

25. WFRBS Commercial Mortgage Trust 2013-C17, Commercial MortgagePass-Through Certificates, Series 2013-C17

26. WFRBS Commercial Mortgage Trust 2013-C18, CommercialMortgage Pass-Through Certificates, Series 2013-C18

27. Commercial Mortgage Trust 2013-CCRE13, CommercialMortgage Pass-Through Certificates, Series 2013-CCRE13

28. Commercial Mortgage Trust 2014-CCRE14, CommercialMortgage Pass Through Certificates, Series 2014- CCRE14

29. RBS Commercial Mortgage Trust 2014-C19, CommercialMortgage Pass Through Certificates, Series 2014-C19

30. WFRBS Commercial Mortgage Trust 2014-C20, CommercialMortgage Pass-Through Certificates, Series 2014-C20

31. RBS Commercial Mortgage Trust-2014-C21, CommercialMortgage Pass-Through Certificates, Series 2014-C21

32. WFRBS Commercial Mortgage Trust 2014-C22, CommercialMortgage Pass-Through Certificates, Series 2014-C22

33. RBS Commercial Mortgage Trust 2014-C23, CommercialMortgage Pass-Through Certificates, Series 2014-C23

34. WFRBS Commercial Mortgage Trust 2014-C24, Commercial MortgagePass-Through Certificates, Series 2014-C24

35. WCMF Commercial Mortgage Trust 2014-LC18, CommercialMortgage Pass–Through Certificates, Series 2014-LC18

36. RBS Commercial Mortgage Trust 2014-C25, CommercialMortgage Pass-Through Certificates, Series 2014-C25

37. WFCM Commercial Mortgage Pass-Through Certificates,Series 2015-C26

38. WFCM Commercial Mortgage Pass-Through Certificates,Series 2015-C27

39. WFCM Commercial Mortgage Pass-Through Certificates,Series 2015-C28

40. WFCM Commercial Mortgage Pass-Through Certificates,Series 2015-SG1

41. WFCM Commercial Mortgage Pass-Through Certificates,Series 2015-C31

42. CFCRE 2016-C3 Mortgage Trust, Commercial MortgagePass-Through Certificates, Series 2016-C3

43. SG Commercial Mortgage Securities Trust 2016-Cs,Commercial Mortgage Pass-Through Certificates Series 2016-Cs