Trimont Real Estate Advisors,LLC

 

Management's Report onAssessment of Compliance

with SEC Regulation ABServicing Criteria

 

 

Trimont Real Estate Advisors,LLC (the “Asserting Party”) is responsible for assessing compliance as of and forthe year ended December 31, 2018 (the “Reporting Period”) with the applicableservicing criteria set forth in Item 1122(d) of the Securities and ExchangeCommission's Regulation AB as set forth in Exhibit A hereto (the “ApplicableServicing Criteria”). The transactions covered by this report are only thosetransactions processed by the Asserting Party in capacity as special servicerfor the asset backed securities transactions listed in Exhibit B hereto (the“Platform”).

 

The Asserting Party has used theservicing criteria set forth in Item 1122(d) of the Securities and ExchangeCommission's Regulation AB to assess its compliance with the ApplicableServicing Criteria for the Reporting Period and has concluded that theAsserting Party has complied, in all material respects, with the ApplicableServicing Criteria as of and for the year ended December 31, 2018 with respectto the Platform.

 

Grant Thornton LLP, anindependent registered public accounting firm, has issued an attestation reporton the assessment of compliance with the Applicable Servicing Criteria as ofand for the year ended December 31, 2018 as set forth in this assertion.

 

 

Trimont Real Estate Advisors,LLC 

February 26, 2019

 

 

/s/ Glen Peters

Glen Peters

Chief Financial Officer

 

 

| **Exhibit A**                      |
|------------------------------------|
| **Regulation AB Criteria**         | **JPMCC 2018-MINN** | **COMM 2012-CCRE2** | **GSMS 2018-TWR** | **AHT 2018 Keyes** | **Bancorp 2018-CRE3** | **Bancorp 2018-CRE4** | **GPMT 2018-FL1** | **GSMS 2018-GS10** | **JPMC 2018-MBR MZ** | **CSMC 2017-PFHP** | **CPLV TRUST 2017-VICI** | **MSC 2017-ASHF** |
| ***Section***                      | ***Description*** | ***Criteria*** | ***Applicable Criteria*** |
| General Servicing Considerations   |
| (d)(1)(i)                          | Policies and Procedures | Policies and procedures are instituted to monitor any  performance or other triggers and events of default in accordance with the  transaction agreement. | X | X | X | X | X | X | X | X | X | X | X | X |
| (d)(1)(ii)                         | Policies and Procedures (vendors) | 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. | X7 | X7 | X7 | X7 | X7 | X7 | X7 | X7 | X7 | X7 | X7 | X7 |
| (d)(1)(iii)                        | Back-up Servicer | Any requirements in the transaction agreements to  maintain a back-up servicer for the pool assets are maintained. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| (d)(1)(iv)                         | Fidelity Bond | 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 agreement. | X | X | X | X | X | X | X | X | X | X | X | X |
| (d)(1)(v)                          | Accuracy of Information | Aggregation of information, as applicable, is  mathematically accurate and the information conveyed accurately reflects the  information. | X4 | X4 | X4 | X4 | X4 | X4 | X4 | X4 | X4 | X4 | X4 | X4 |
| Cash Collection and Administration |
| (d)(2)(i)                          | 2 Days to deposit Payments into Custodial Accounts | Payments on pool assets are deposited into the  appropriate custodial bank accounts and related bank clearing accounts no  more than two business days of receipt, or such other number of days  specified in the transaction agreements. | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 |
| (d)(2)(ii)                         | Wire Transfers | Disbursements made via wire transfer on behalf of an  obligor or to an investor are made only by authorized personnel | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| (d)(2)(iii)                        | Advances | 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. | X2 | X1 | X2 | X2 | X2 | X2 | X1 | X1 | X2 | X2 | X2 | X2 |
| (d)(2)(iv)                         | Commingling | The related accounts for the transaction, such as  cash reserve accounts or accounts established as a form of over  collateralization, are separately maintained (e.g., with respect to commingling  of cash) as set forth in the transaction agreements. | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 |
| (d)(2)(v)                          | Federally Insured Institution | 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 §240.13k-1(b)(1)  of this chapter.  I.3 Each custodial account shall be maintained at a  federally insured depository institution in trust for the applicable  investor. | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 |
| (d)(2)(vi)                         | Unissued Checks | Unissued checks are safeguarded so as to prevent  unauthorized access. | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 |
| (d)(2)(vii)                        | Reconciliations | 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. | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 |
| Investor Remittance and Reporting  |
| (d)(3)(i)                          | Reports to the Investor | 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 pool assets serviced by the servicer. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| (d)(3)(ii)                         | Investor Remittance | Amounts due to investors are allocated and remitted in  accordance with timeframes, distribution priority and other terms set forth  in the transaction agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| (d)(3)(iii)                        | Investor's Records | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| (d)(3)(iv)                         | Remittance and Bank Statements | Amounts remitted to investors per the investor reports  agree with cancelled checks, or other form of payment, or custodial bank  statements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| Pool Asset Administration          |
| (d)(4)(i)                          | Collateral/ Security on Pool Assets | Collateral or security on pool assets is maintained  as required by the transaction agreements or related pool asset documents. | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 |
| (d)(4)(ii)                         | Safeguard Pool Assets | Pool assets and related documents are safeguarded as required  by the transaction agreements. | X2 | X2 | X2 | X2 | X2 | X1 | X1 | X2 | X2 | X2 | X2 | X2 |
| (d)(4)(iii)                        | Changes to the Pool Assets | 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. | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 |
| (d)(4)(iv)                         | Obligor's Payment Record | Payments on pool assets, including any payoffs, made  in accordance with the related pool asset documents are posted to the  applicable 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 pool asset documents. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| (d)(4)(v)                          | Pool Asset Records Match UPB | The servicer’s records regarding the pool assets  agree with the servicer's records with respect to an obligor's unpaid  principal balance. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
|  (d)(4)(vi)                   | Loan Modifications | Changes with respect to the terms or status of an  obligor's pool asset (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. | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 |
| (d)(4)(vii)                        | Loss Mitigation Actions | 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 agreement. | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 |
| (d)(4)(viii)                       | Collection Efforts Documented | Records documenting collection efforts are maintained  during the period a pool asset 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 pool assets  including, for example, phone calls, letters and payment rescheduling plans  in cases where delinquency is deemed temporary (e.g., illness or  unemployment) | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 |
| (d)(4)(ix)                         | ARMs | Adjustments to interest rates or rates of return for  pool assets with variable rates are computed based on the related pool asset  documents. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| (d)(4)(x)                          | Escrow Funds | Regarding any funds held in trust for an obligor such  funds are (a) analyzed, in accordance with the obligor's pool asset  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 pool asset documents and state laws;  and (c)returned to the obligor within 30 calendar days of full repayment of  the related pool asset, or such other number of days specified in the  transaction agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| (d)(4)(xi)                         | Timely Payments | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| (d)(4)(xii)                        | Late Payment Penalties | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| (d)(4)(xiii)                       | Obligor's Records | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| (d)(4)(xiv)                        | Delinquencies, Charge-offs, and Other Uncollectible  Accounts | Delinquencies, Charge-offs, and uncollectible  accounts are recognized and recorded in accordance with the transaction  agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| (d)(4)(xv)                         | Any External Enhancement | Any external enhancement or other support, identified  in Item 1114(a)(1) through (3) or Item 1115 of this Regulation AB, is  maintained as set forth in the transaction agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |

 

 

| **Exhibit A**                      |
|------------------------------------|
| **Regulation AB Criteria**         | **VSD 2017-PLT1** | **RPT 2017-ROSS** | **Bancorp 2017-CRE2** | **CGMS 2017 MDDR** | **COLD 2017-ICE3** | **JPM 2016-ASH** | **2016-225L** | **BANCORP 2016-CRE1** | **GSMS 2016-GS3** | **CGBAM 2015-SMRT MZ** | **Lone Star 2015 LSP-MZ** | **WFCG 2015-BXRP** |
| ***Section***                      | ***Description*** | ***Criteria*** | ***Applicable Criteria*** |
| General Servicing Considerations   |
| (d)(1)(i)                          | Policies and Procedures | Policies and procedures are instituted to monitor any  performance or other triggers and events of default in accordance with the  transaction agreement. | X | X | X | X | X | X | X | X | X | X | X | X |
| (d)(1)(ii)                         | Policies and Procedures (vendors) | 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. | X7 | X7 | X7 | X7 | X7 | X7 | X7 | X7 | X7 | X7 | X7 | X7 |
| (d)(1)(iii)                        | Back-up Servicer | Any requirements in the transaction agreements to  maintain a back-up servicer for the pool assets are maintained. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| (d)(1)(iv)                         | Fidelity Bond | 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 agreement. | X | X | X | X | X | X | X | X | X | X | X | X |
| (d)(1)(v)                          | Accuracy of Information | Aggregation of information, as applicable, is  mathematically accurate and the information conveyed accurately reflects the  information. | X2 | X4 | X4 | X4 | X4 | X4 | X4 | X4 | X4 | X4 | X4 | X4 |
| Cash Collection and Administration |
| (d)(2)(i)                          | 2 Days to deposit Payments into Custodial Accounts | Payments on pool assets are deposited into the  appropriate custodial bank accounts and related bank clearing accounts no  more than two business days of receipt, or such other number of days  specified in the transaction agreements. | X2 | X1 | X1 | X1 | X1 | X1 | X1 | X3 | X1 | X1 | X1 | X1 |
| (d)(2)(ii)                         | Wire Transfers | Disbursements made via wire transfer on behalf of an  obligor or to an investor are made only by authorized personnel | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| (d)(2)(iii)                        | Advances | 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. | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X1 | X2 | X2 | X2 |
| (d)(2)(iv)                         | Commingling | The related accounts for the transaction, such as  cash reserve accounts or accounts established as a form of over  collateralization, are separately maintained (e.g., with respect to commingling  of cash) as set forth in the transaction agreements. | X2 | X1 | X1 | X1 | X1 | X1 | X1 | X5 | X1 | X1 | X1 | X1 |
| (d)(2)(v)                          | Federally Insured Institution | 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 §240.13k-1(b)(1)  of this chapter.  I.3 Each custodial account shall be maintained at a  federally insured depository institution in trust for the applicable  investor. | X2 | X1 | X1 | X1 | X1 | X1 | X1 | X5 | X1 | X1 | X1 | X1 |
| (d)(2)(vi)                         | Unissued Checks | Unissued checks are safeguarded so as to prevent  unauthorized access. | X2 | X1 | X1 | X1 | X1 | X1 | X1 | X | X1 | X1 | X1 | X1 |
| (d)(2)(vii)                        | Reconciliations | 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. | X2 | X1 | X1 | X1 | X1 | X1 | X1 | X5 | X1 | X1 | X1 | X1 |
| Investor Remittance and Reporting  |
| (d)(3)(i)                          | Reports to the Investor | 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 pool assets serviced by the servicer. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| (d)(3)(ii)                         | Investor Remittance | Amounts due to investors are allocated and remitted in  accordance with timeframes, distribution priority and other terms set forth  in the transaction agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| (d)(3)(iii)                        | Investor's Records | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| (d)(3)(iv)                         | Remittance and Bank Statements | Amounts remitted to investors per the investor  reports agree with cancelled checks, or other form of payment, or custodial  bank statements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| Pool Asset Administration          |
| (d)(4)(i)                          | Collateral/ Security on Pool Assets | Collateral or security on pool assets is maintained  as required by the transaction agreements or related pool asset documents. | X2 | X1 | X1 | X1 | X1 | X1 | X1 | X6 | X1 | X1 | X1 | X1 |
| (d)(4)(ii)                         | Safeguard Pool Assets | Pool assets and related documents are safeguarded as  required by the transaction agreements. | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 |
| (d)(4)(iii)                        | Changes to the Pool Assets | 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. | X2 | X1 | X1 | X1 | X1 | X1 | X1 | X8 | X1 | X1 | X1 | X1 |
| (d)(4)(iv)                         | Obligor's Payment Record | Payments on pool assets, including any payoffs, made in  accordance with the related pool asset documents are posted to the applicable  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 pool asset documents. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| (d)(4)(v)                          | Pool Asset Records Match UPB | The servicer’s records regarding the pool assets agree  with the servicer's records with respect to an obligor's unpaid principal  balance. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
|  (d)(4)(vi)                   | Loan Modifications | Changes with respect to the terms or status of an obligor's  pool asset (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. | X | X1 | X1 | X1 | X1 | X1 | X1 | X9 | X1 | X1 | X1 | X1 |
| (d)(4)(vii)                        | Loss Mitigation Actions | 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 agreement. | X | X1 | X1 | X1 | X1 | X1 | X1 | X10 | X1 | X1 | X1 | X1 |
| (d)(4)(viii)                       | Collection Efforts Documented | Records documenting collection efforts are maintained  during the period a pool asset 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 pool assets  including, for example, phone calls, letters and payment rescheduling plans  in cases where delinquency is deemed temporary (e.g., illness or  unemployment) | X | X1 | X1 | X1 | X1 | X1 | X1 | X | X1 | X1 | X1 | X1 |
| (d)(4)(ix)                         | ARMs | Adjustments to interest rates or rates of return for  pool assets with variable rates are computed based on the related pool asset  documents. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| (d)(4)(x)                          | Escrow Funds | Regarding any funds held in trust for an obligor such  funds are (a) analyzed, in accordance with the obligor's pool asset  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 pool asset documents and state laws;  and (c)returned to the obligor within 30 calendar days of full repayment of  the related pool asset, or such other number of days specified in the  transaction agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| (d)(4)(xi)                         | Timely Payments | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| (d)(4)(xii)                        | Late Payment Penalties | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| (d)(4)(xiii)                       | Obligor's Records | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| (d)(4)(xiv)                        | Delinquencies, Charge-offs, and Other Uncollectible  Accounts | Delinquencies, Charge-offs, and uncollectible accounts  are recognized and recorded in accordance with the transaction agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| (d)(4)(xv)                         | Any External Enhancement | Any external enhancement or other support, identified  in Item 1114(a)(1) through (3) or Item 1115 of this Regulation AB, is  maintained as set forth in the transaction agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |

 

 

Key

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| X1                                                                                                                                                                                                                 | This criteria is applicable for the securitization;  however, there were no loans serviced under this securitization during the  reporting period.                                                                                                              |
|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| X2                                                                                                                                                                                                                 | With respect to Applicable Servicing  Criteria, the securitization was not in scope based on the transaction  agreement.                                                                                                                                        |
| X3                                                                                                                                                                                                                 | With respect to item 1122(d)(2)(i),  this criteria is applicable for the securitization; however, there was no  cash collected for loans under the securitization during the reporting  period.                                                                 |
| X4                                                                                                                                                                                                                 | With respect to item 1122(d)(1)(v), this  criteria is applicable for the securitization; however, there was no  aggregation of information related to reporting to external parties.                                                                            |
| X5                                                                                                                                                                                                                 | With respect to item 1122(d)(2)(iv),  1122(d)(2)(v) and 1122(d)(2)(vii), the criteria is applicable for the securitization;  however, there were no custodial bank accounts maintained under the  securitization during the reporting period.                   |
| X6                                                                                                                                                                                                                 | With respect to item 1122(d)(4)(i),  the criteria is applicable for the securitization; however, as special  servicer, Trimont was not responsible for maintaining collateral or security  on pool assets under the securitization during the reporting period. |
| X7                                                                                                                                                                                                                 | With respect to Item 1122(d)(1)(ii),  this criteria is applicable for the securitization; however, there were no  material servicing activities outsourced to third parties under this  securitization during the reporting period.                             |
| X8                                                                                                                                                                                                                 | With respect to item  1122(d)(4)(iii), the criteria is applicable for the securitization; however,  there were no additions, removals, or substitutions to the pool assets under  the securitization during the reporting period.                               |
| X9                                                                                                                                                                                                                 | With respect to item 1122(d)(4)(vi),  the criteria is applicable for the securitization; however, there were no  changes to the terms or status of an obligor's pool assets under the securitization  during the reporting period.                              |
| X10                                                                                                                                                                                                                | With respect to item  1122(d)(4)(vii), the criteria is applicable for the securitization; however,  there were no loss mitigation or recovery initiated, conducted and or  concluded on pool assets under the securitization during the reporting  period.      |
| With respect to Applicable Servicing  Criteria cells in Exhibit A that are denoted with an "N/A", per  review of the respective servicing agreement, the criteria was not in scope  for the transaction. |

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** **

| **Exhibit B**                       |
|-------------------------------------|
| **Name**                            | **Transaction** | **Period of Service** |
| CGBAM 2015-SMRT  MZ                 | Special Servicer  for Commercial Mortgage Pass-Through Certificates Series 2014-TISH pursuant  to the Pooling and Servicing Agreement dated April 28, 2015 | January 1, 2018  - December 31, 2018 |
| Lone Star 2015  LSP-MZ              | Special Servicer  for Commercial Mortgage Pass-Through Certificates Series Lone Star 2015  LSP-MZ pursuant to the Pooling and Servicing Agreement dated November 13,  2015 | January 1, 2018  - December 31, 2018 |
| WFCG 2015-BXRP                      | Special Servicer  for Commercial Mortgage Pass-Through Certificates Series WFCG 2015-BXRP  pursuant to the Pooling and Servicing Agreement dated April 1, 2015 | January 1, 2018  - December 31, 2018 |
| 2016-225L                           | Special Servicer  for Commercial Mortgage Pass-Through Certificates Series 2016-225L pursuant  to the Pooling and Servicing Agreement dated February 6, 2016 | January 1, 2018  - December 31, 2018 |
| BANCORP  2016-CRE1                  | Special Servicer  for Commercial Mortgage Pass-Through Certificates Series BANCORP 2016-CRE1  pursuant to the Pooling and Servicing Agreement dated December 6, 2016 | January 1, 2018  - December 31, 2018 |
| JPM 2016-ASH                        | Special Servicer  for Commercial Mortgage Pass-Through Certificates Series JPM 2016-ASH  pursuant to the Pooling and Servicing Agreement dated November 30, 2016 | January 1, 2018  - December 31, 2018 |
| 225 Liberty  Street Trust 2016-225L | Special Servicer  for Commercial Mortgage Pass-Through Certificates Series 2016-225L pursuant to  the Pooling and Servicing Agreement dated February 6, 2016 | January 1, 2018  - December 31, 2018 |
| BANCORP  2016-CRE1                  | Special Servicer  for Commercial Mortgage Pass-Through Certificates Series BANCORP 2016-CRE1  pursuant to the Pooling and Servicing Agreement dated December 6, 2016 | January 1, 2018  - December 31, 2018 |
| JPM 2016-ASH                        | Special Servicer  for Commercial Mortgage Pass-Through Certificates Series JPM 2016-ASH  pursuant to the Pooling and Servicing Agreement dated November 30, 2016 | January 1, 2018  - December 31, 2018 |
| GSMS 2016-GS3                       | Special Servicer  for Commercial Mortgage Pass-Through Certificates Series GSMS 2016-GS3  pursuant to the Pooling and Servicing Agreement dated September 1, 2016 | January 1, 2018  - December 31, 2018 |
| Bancorp  2017-CRE2                  | Special Servicer  for Commercial Mortgage Pass-Through Certificates Series Bancorp 2017-CRE2  pursuant to the Pooling and Servicing Agreement dated August 30, 2017 | January 1, 2018  - December 31, 2018 |
| CGMS 2017 MDDR                      | Special Servicer  for Commercial Mortgage Pass-Through Certificates Series CGMS 2017 MDDR  pursuant to the Pooling and Servicing Agreement dated July 6, 2017 | January 1, 2018  - December 31, 2018 |
| COLD 2017-ICE3                      | Special Servicer  for Commercial Mortgage Pass-Through Certificates Series COLD 2017-ICE3 pursuant  to the Pooling and Servicing Agreement dated April 28, 2017 | January 1, 2018  - December 31, 2018 |
| RPT 2017-ROSS                       | Special Servicer  for Commercial Mortgage Pass-Through Certificates Series RPT 2017-ROSS  pursuant to the Pooling and Servicing Agreement dated June 30, 2017 | January 1, 2018  - December 31, 2018 |
| CPLV TRUST  2017-VICI               | Special Servicer  for Commercial Mortgage Pass-Through Certificates Series CPLV 2017-VICI  pursuant to the Pooling and Servicing Agreement dated November 30, 2017 | January 1, 2018  - December 31, 2018 |
| MSC 2017-ASHF                       | Special Servicer  for Commercial Mortgage Pass-Through Certificates Series MSC 2017-ASHF  pursuant to the Pooling and Servicing Agreement dated December 9, 2017 | January 1, 2018  - December 31, 2018 |
| CSMC 2017-PFHP                      | Special Servicer  for Commercial Mortgage Pass-Through Certificates Series CSMC 2017-PFHP  pursuant to the Pooling and Servicing Agreement dated December 19, 2017 | January 1, 2018  - December 31, 2018 |
| VSD 2017-PLT1                       | Special Servicer  for Commercial Mortgage Pass-Through Certificates Series VSD 2017-PLT1  pursuant to the Pooling and Servicing Agreement dated March 10, 2017 | January 1, 2018  - December 31, 2018 |
| JPMC 2018-MBR MZ                    | Special Servicer  for Commercial Mortgage Pass-Through Certificates Series JPMC 2018-MBR MZ  pursuant to the Pooling and Servicing Agreement dated August 22, 2018 | August 22, 2018  - December 31, 2018 |
| GSMS 2018-GS10                      | Special Servicer  for Commercial Mortgage Pass-Through Certificates Series GSMS 2018-GS10 pursuant  to the Pooling and Servicing Agreement dated July 1, 2018 | July 1, 2018 -  December 31, 2018 |
| GPMT 2018-FL1                       | Special Servicer  for Commercial Mortgage Pass-Through Certificates Series GPMT 2018-FL1  pursuant to the Pooling and Servicing Agreement dated May 9, 2018 | May 9, 2018 -  December 31, 2018 |
| Bancorp  2018-CRE4                  | Special Servicer  for Commercial Mortgage Pass-Through Certificates Series Bancorp 2018-CRE4  pursuant to the Pooling and Servicing Agreement dated September 27, 2018 | September 27,  2018 - December 31, 2018 |
| Bancorp  2018-CRE3                  | Special Servicer  for Commercial Mortgage Pass-Through Certificates Series Bancorp 2018-CRE3  pursuant to the Pooling and Servicing Agreement dated March 29, 2018 | March 29, 2018 -  December 31, 2018 |
| AHT 2018 Keys                       | Special Servicer  for Commercial Mortgage Pass-Through Certificates Series AHT 2018 Keys  pursuant to the Pooling and Servicing Agreement dated July 16, 2018 | July 16, 2018 -  December 31, 2018 |
| GSMS 2018-TWR                       | Special Servicer  for Commercial Mortgage Pass-Through Certificates Series GSMS 2018-TWR  pursuant to the Pooling and Servicing Agreement dated July 31, 2018 | July 31, 2018 -  December 31, 2018 |
| COMM 2012-CCRE2                     | Special Servicer  for Commercial Mortgage Pass-Through Certificates Series COMM 2012-CCRE2 pursuant  to the Pooling and Servicing Agreement dated August 1, 2018 | January 1, 2018  - December 31, 2018 |
| JPMCC 2018-MINN                     | Special Servicer  for Commercial Mortgage Pass-Through Certificates Series JPMCC 2018-MINN  pursuant to the Pooling and Servicing Agreement dated December 7, 2018 | December 7, 2018  - December 31, 2018 |

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