(logo)TRIMONT®

 

 

GlenPeters

ChiefFinancial Officer, Global 

gpeters@trimontrea.com

Direct:404-581-7525

 

 

3500Lenox Road, 

SuiteG1

Atlanta,GA 30326

 

trimontrea.com

 

 

**TrimontReal Estate Advisors, LLC**

 

**Management’sReport on Assessment of Compliance**

**withSEC Regulation AB Servicing Criteria**

 

TrimontReal Estate Advisors, LLC (“the Asserting Party”) is responsible for assessingcompliance as of and for the year ended December 31, 2021 (“the ReportingPeriod”) with the applicable servicing criteria set forth in Item 1122(d) ofthe Securities and Exchange Commission’s Regulation AB as set forth in ExhibitA hereto (the “Applicable Servicing Criteria”). The transactions covered bythis report are only those transactions processed by the Asserting Party in theSenior Trust Advisor, Trust Advisor, and Operating Advisor Services Platformfor the asset backed securities transactions listed in Exhibit B hereto (the“Platform”).

 

TheAsserting Party has used the servicing criteria set forth in Item 1122(d) ofthe Securities and Exchange Commission’s Regulation AB to assess its compliancewith the Applicable Servicing Criteria for the Reporting Period and hasconcluded that the Asserting Party has complied, in all material respects, withthe Applicable Servicing Criteria as of and for the year ended December 31,2021 with respect to the Platform.

 

GrantThornton, LLP, an independent registered public accounting firm, has issued anattestation report on the assessment of compliance with the ApplicableServicing Criteria as of and for the year ended December 31, 2021 as set forthin this assertion.

 

 

TrimontReal Estate Advisors, LLC 

February28, 2022

 

 

/s/Glen Peters

GlenPeters

ChiefFinancial Officer

 

 

TrimontReal Estate Advisors

 

Amsterdam| Atlanta | Dallas | Kansas City | London | Los Angeles | New York |

 

 

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**Regulation AB  Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | **GSMS 2015-GC30**                                            | **WFCM 2015-C27**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | **WFCM 2015-C29**                                                                   | **WFCM 2015-C31**                                                                   | **WFCM 2015-LC20**                                                                  | **WFCM 2015-NXS1**                                                                  | **WFCM 2015-SG1**                                                                   | **WFRBS 2014-C25**                                                                  | **WFRBS 2014-C23**                                                                  | **WFRBS 2014-C21**                                                                  | **GSMS 2014-GC20**                                                                  | **WFRBS 2014-C19**                                                                  | **WFRBS 2013-C17**                                                                  | **MSBAM 2013-C12**                                                                  | **WFRBS 2013-C15**                                                                  | **GSMS 2013-GC13**                                                                  | **WFRBS 2013-C13**                                                                  | **MSBAM 2013-C9**                                                                   | **WFRBS 2013-C11**                                                                  | **GSMS 2013-GC10**                                                                  | **UBS BB 2012-C4**                                                                  | **WFCM 2012-LC5**                                                                   |                                                                                |
|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------|
| ***Section***                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     | ***Description***                                             | ***Criteria***                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | ***Applicable  Criteria***                                                          |                                                                                |
| General Servicing  Considerations                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |
| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |  

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |  

 

 

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| 1122(d)(1)(iii)                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | Back-up Servicer                                              | Any  requirements in the transaction agreements to maintain a back-up servicer for  the pool assets are maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |  

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                   |  

 

 

 

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| 1122(d)(1)(v)                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     | Accuracy of  Information                                      | Aggregation  of information, as applicable, is mathematically accurate and the information  conveyed accurately reflects the information.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |  

 

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|                                                                                                    Cash Collection and  Administration                                                                                                  |                                                          |
| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |  

 

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |  

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |  

 

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                             |  

 

 

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                   |  

 

 

 

 

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| 1122(d)(2)(vi)                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | Unissued Checks                                               | Unissued  checks are safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |  

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| 1122(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. |  

 

 

 

 

 

 

 

 

 

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| Investor  Remittance and Reporting                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                                          |
| 1122(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.                                                     |  

 

 

 

 

 

 

 

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |  

 

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |  

 

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |  

 

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| Pool Asset Administration                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |                                                          |
| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |  

 

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| 1122(d)(4)(ii)                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | Safeguard Pool  Assets                                        | Pool  assets and related documents are safeguarded as required by the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |  

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |  

 

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| 1122(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.                                                                                                                                                                                                                                                                                           |  

 

 

 

 

 

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| 1122(d)(4)(v)                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     | Pool Asset  Records Match UPB                                 | The  servicers records regarding the pool assets agree with the servicer's records  with respect to an obligor's unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             |  

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                              |  

 

 

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                              | X2                                                                                  | X2                                                                                  | X2                                                                                  | X2                                                                                  | X2                                                                                  | X2                                                                                  | X2                                                                                  | X2                                                                                  | X2                                                                                  | X2                                                                                  | X2                                                                                  | X2                                                                                  | X2                                                                                  | X2                                                                                  | X2                                                                                  | X2                                                                                  | X2                                                                                  | X2                                                                                  | X2                                                                                  | X2                                                                                  | X2                                                                                  | X2 |   |
| 1122(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).                                                                                                                                                                                                  |  

 

 

 

 

 

 

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |  

 

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| 1122(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.                                                                                                                                                                       |  

 

 

 

 

 

 

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                   |  

 

 

 

 

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |  

 

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |  

 

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |  

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |  

 

 

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ExhibitA

 

| ** **

** **

** **

** **

** **

** **

**Regulation AB  Criteria** | **WFRBS 2012-C9**                                             | **DBUBS 2011-LC3**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | **WFRBS 2011-C5**                                                                           | **WFCM 2016-NXS6**                                                                          | **WFCM 2016-LC24**                                                                          | **WFCM 2016-C37**                                                                           | **245 Park Ave  Trust 2017-245P**                                                           | **MSC 2017-H1**                                                                             | **WFCM 2017-C39**                                                                           | **WFCM 2017-RB1**                                                                           | **WFCM 2017-C41**                                                                           | **CFCRE 2011-C2**                                                                           | **MSC 2011-C3**                                                                             | **UBS CCMT 2011-C1**                                                                        | **JPMCC 2012-CIBX**                                                                         | **UBS 2012-C1**                                                                             | **WFRBS 2014-LC14**                                                                         | **CGCMT 2014-GC23**                                                                         | **CGCMT 2016-C3**                                                                           | **CGCMT 2017-B1**                                                                           | **GSMS 2012-GC6**                                                                           | **WFRBS 2012-C7**                                                                           |
|-----------------------------------------------------------------------------------------------------|---------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------|
| ***Section***                                                                                       | ***Description***                                             | ***Criteria***                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | ***Applicable  Criteria***                                                                  |
| General Servicing  Considerations                                                                   |
| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |  

 

 

N/A                                                                 |  

 

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |  

 

 

N/A                                                                 |  

 

 

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| 1122(d)(1)(iii)                                                                                     | Back-up Servicer                                              | Any  requirements in the transaction agreements to maintain a back-up servicer for  the pool assets are maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |  

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                      |  

 

 

 

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| 1122(d)(1)(v)                                                                                       | Accuracy of  Information                                      | Aggregation  of information, as applicable, is mathematically accurate and the information  conveyed accurately reflects the information.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |  

 

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| Cash Collection  and Administration                                                                 |
| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |  

 

 

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |  

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |  

 

 

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                |  

 

 

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                      |  

 

 

 

 

 

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| 1122(d)(2)(vi)                                                                                      | Unissued Checks                                               | Unissued  checks are safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |  

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| 1122(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. |  

 

 

 

 

 

 

 

 

 

 

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| Investor  Remittance and Reporting                                                                  |
| 1122(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.                                                        |  

 

 

 

 

 

 

 

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |  

 

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |  

 

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             |  

 

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| Pool Asset  Administration                                                                          |
| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |  

 

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| 1122(d)(4)(ii)                                                                                      | Safeguard Pool Assets                                         | Pool  assets and related documents are safeguarded as required by the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |  

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |  

 

 

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| 1122(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.                                                                                                                                                                                                                                                                                              |  

 

 

 

 

 

 

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| 1122(d)(4)(v)                                                                                       | Pool Asset  Records Match UPB                                 | The  servicers records regarding the pool assets agree with the servicer's records  with respect to an obligor's unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |  

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |  

 

 

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                 | X2                                                                                          | X2                                                                                          | X2                                                                                          | X2                                                                                          | X2                                                                                          | X2                                                                                          | X2                                                                                          | X2                                                                                          | X2                                                                                          | X2                                                                                          | X2                                                                                          | X2                                                                                          | X2                                                                                          | X2                                                                                          | X2                                                                                          | X2                                                                                          | X2                                                                                          | X2                                                                                          | X2                                                                                          | X2                                                                                          | X2 | X2 |
| 1122(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).                                                                                                                                                                                                     |  

 

 

 

 

 

 

 

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |  

 

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| 1122(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.                                                                                                                                                                          |  

 

 

 

 

 

 

 

 

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                      |  

 

 

 

 

 

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |  

 

 

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |  

 

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |  

 

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| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |  

 

 

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**ExhibitA Key**

 

|  

 

X1                                                                                                                                                                                                 | With  respect to Item 1122(d)(3)(i), only parts A and B of this criteria are  applicable for the securitization. There were no activities performed during  the reporting period for the loan(s) that were serviced under this  securitization |
|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| X2                                                                                                                                                                                                                 | With  respect to Item 1122(d)(4)(vii), there were no Loss mitigation or recovery  actions during the reporting period for the loan(s) that were serviced under  this securitization.                                                           |
| X3                                                                                                                                                                                                                 | With  respect to Item 1122(d)(3)(i), only parts A, B, and C are applicable. There were  no activities performed during the reporting period for the loan(s) that were  serviced under this securitization                                      |
| X4                                                                                                                                                                                                                 | With  respect to Item 1122(d)(3)(i), there were no activities performed during the  reporting period for the loan(s) that were serviced under this  securitization.                                                                            |
| X5                                                                                                                                                                                                                 | With  respect to Applicable Servicing Criteria, the securitization was not in scope  based the transaction agreement.                                                                                                                          |
| X6                                                                                                                                                                                                                 | With  respect to Item 1122(d)(3)(i), only parts A and B of this criteria are  applicable for the securitization.                                                                                                                               |
| X7                                                                                                                                                                                                                 | With  respect to Item 1122(d)(3)(i), only parts A, B, and C of this criteria are  applicable for the securitization.                                                                                                                           |
| 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. |

** **

** **

**ExhibitB**

 

| Name                              | Transaction                                                                                                                                             | Period  of Service                     |
|-----------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------|
| DBUBS  2011-LC3                   | Commercial  Mortgage Pass-Through Certificates, DBUBS 2011-LC3 pursuant to the Pooling and  Servicing Agreement dated August 1, 2011                    | January  1, 2021 -

December  31, 2021 |
| WFRBS  2011-C5                    | Commercial  Mortgage Pass-Through Certificates, WFRBS 2011-C5 pursuant to the Pooling and  Servicing Agreement dated November 1, 2011                   | January  1, 2021 -

December  31, 2021 |
| MSC  2011-C3                      | Commercial  Mortgage Pass-Through Certificates, MSC 2011-C3 pursuant to the Pooling and  Servicing Agreement dated October 1, 2011                      | January  1, 2021 -

December  31, 2021 |
| CFCRE  2011-C2                    | Commercial  Mortgage Pass-Through Certificates, CFCRE 2011-C2 pursuant to the Pooling and  Servicing Agreement dated December 11, 2011                  | January  1, 2021 -

December  31, 2021 |
| UBS  CCMT 2011-C1                 | Commercial  Mortgage Pass-Through Certificates, UBS CCMT-2011 pursuant to the Pooling and  Servicing Agreement dated December 1, 2011                   | January  1, 2021 -

December  31, 2021 |
| GSMS  2012-GC6                    | Commercial  Mortgage Pass-Through Certificates, Series 2012-GC6 pursuant to the Pooling  and Servicing Agreement dated February 1, 2012                 | January  1, 2021 -

December  31, 2021 |
| UBS  2012-C1                      | Commercial  Mortgage Pass-Through Certificates, Series 2012-C1 pursuant to the Pooling  and Servicing Agreement dated May 1, 2012                       | January  1, 2021 -

December  31, 2021 |
| JPMCC  2012-CIBX                  | Commercial  Mortgage Pass-Through Certificates, Series 2012-CIBX pursuant to the Pooling  and Servicing Agreement dated June 1, 2012                    | January  1, 2021 -

December  31, 2021 |
| WFRBS  2012-C7                    | Commercial  Mortgage Pass-Through Certificates, Series 2012-C7 pursuant to the Pooling and  Servicing Agreement dated June 1, 2012                      | January  1, 2021 -

December  31, 2021 |
| WFCM  2012-LC5                    | Commercial  Mortgage Pass-Through Certificates, Series 2012-LC5 pursuant to the Pooling  and Servicing Agreement dated September 1, 2012                | January  1, 2021 -

December  31, 2021 |
| WFRBS  2012-C9                    | Commercial  Mortgage Pass-Through Certificates, Series 2012-C9 pursuant to the Pooling  and Servicing Agreement dated October 1, 2012                   | January  1, 2021 -

December  31, 2021 |
| UBS  BB 2012-C4                   | Commercial  Mortgage Pass-Through Certificates, Series 2012-C4 pursuant to the Pooling  and Servicing Agreement dated December 1, 2012                  | January  1, 2021 -

December  31, 2021 |
| GSMS  2013-GC10                   | Commercial  Mortgage Pass-Through Certificates, Series 2013-GC10 pursuant to the Pooling  and Servicing Agreement dated February 1, 2013                | January  1, 2021 -

December  31, 2021 |
| WFRBS  2013-C11                   | Commercial  Mortgage Pass-Through Certificates, Series 2013-C11 pursuant to the Pooling  and Servicing Agreement dated February 1, 2013                 | January  1, 2021 - July 7,

2021       |
| MSBAM  2013-C9                    | Commercial  Mortgage Pass-Through Certificates, Series 2013-C9 pursuant to the Pooling  and Servicing Agreement dated May 1, 2013                       | January  1, 2021 -

December  31, 2021 |
| WFRBS  2013-C13                   | Commercial  Mortgage Pass-Through Certificates, Series 2013-C13 pursuant to the Pooling  and Servicing Agreement dated May 1, 2013                      | January  1, 2021 -

December  31, 2021 |
| GSMS  2013-GC13                   | Commercial  Mortgage Pass-Through Certificates, Series 2013-GC13 pursuant to the Pooling  and Servicing Agreement dated July 1, 2013                    | January  1, 2021 -

December  31, 2021 |
| WFRBS  2013-C15                   | Commercial  Mortgage Pass-Through Certificates, Series 2013-C15 pursuant to the Pooling  and Servicing Agreement dated August 1, 2013                   | January  1, 2021 -

December  31, 2021 |
| MSBAM  2013-C12                   | Commercial  Mortgage Pass-Through Certificates, Series 2013-C12 pursuant to the Pooling  and Servicing Agreement dated October 1, 2013                  | January  1, 2021 -

December  31, 2021 |
| WFRBS  2013-C17                   | Commercial  Mortgage Pass-Through Certificates, Series 2013-C17 pursuant to the Pooling  and Servicing Agreement dated August 1, 2013                   | January  1, 2021 -

December  31, 2021 |
| WFRBS  2014-LC14                  | Commercial  Mortgage Pass-Through Certificates, Series 2014-LC14 pursuant to the Pooling  and Servicing Agreement dated February 1, 2014                | January  1, 2021 -

December  31, 2021 |
| WFRBS  2014-C19                   | Commercial  Mortgage Pass-Through Certificates, Series 2014-C19 pursuant to the Pooling  and Servicing Agreement dated February 26, 2014                | January  1, 2021 -

December  31, 2021 |
| GSMS  2014-GC20                   | Commercial  Mortgage Pass-Through Certificates, Series 2014-GC20 pursuant to the Pooling  and Servicing Agreement dated April 1, 2014                   | January  1, 2021 -

December  31, 2021 |
| WFRBS  2014-C21                   | Commercial  Mortgage Pass-Through Certificates, Series 2014-C21 pursuant to the Pooling  and Servicing Agreement dated August 1, 2014                   | January  1, 2021 -

December  31, 2021 |
| CGCMT  2014-GC23                  | Commercial  Mortgage Pass-Through Certificates, Series 2014-GC23 pursuant to the Pooling and  Servicing Agreement dated August 1, 2014                  | January  1, 2021 -

December  31, 2021 |
| WFRBS  2014-C23                   | Commercial  Mortgage Pass-Through Certificates, Series 2014-C23 pursuant to the Pooling  and Servicing Agreement dated September 1, 2014                | January  1, 2021 -

December  31, 2021 |
| WFRBS  2014-C25                   | Commercial  Mortgage Pass-Through Certificates, Series 2014-C25 pursuant to the Pooling  and Servicing Agreement dated December 1, 2014                 | January  1, 2021 -

December  31, 2021 |
| GSMS  2015-GC30                   | Commercial  Mortgage Pass-Through Certificates, Series 2015-GC30 pursuant to the Pooling  and Servicing Agreement dated May 1, 2015                     | January  1, 2021 -

December  31, 2021 |
| WFCM  2015-C27                    | Commercial  Mortgage Pass-Through Certificates, Series 2015-C27 pursuant to the Pooling  and Servicing Agreement dated March 1, 2015                    | January  1, 2021 -

December  31, 2021 |
| WFCM  2015-C29                    | Commercial  Mortgage Pass-Through Certificates, Series 2015-C29 pursuant to the Pooling  and Servicing Agreement dated June 1, 2015                     | January  1, 2021 -

December  31, 2021 |
| WFCM  2015-C31                    | Commercial  Mortgage Pass-Through Certificates, Series 2015-C31 pursuant to the Pooling  and Servicing Agreement dated November 1, 2015                 | January  1, 2021 -

December  31, 2021 |
| WFCM  2015-LC20                   | Commercial  Mortgage Pass-Through Certificates, Series 2015-LC20 pursuant to the Pooling  and Servicing Agreement dated March 1, 2015                   | January  1, 2021 -

December  31, 2021 |
| WFCM  2015-NXS1                   | Commercial  Mortgage Pass-Through Certificates, Series 2015-NXS1 pursuant to the Pooling  and Servicing Agreement dated April 1, 2015                   | January  1, 2021 -

December  31, 2021 |
| WFCM  2015-SG1                    | Commercial  Mortgage Pass-Through Certificates, Series 2015-SG1 pursuant to the Pooling  and Servicing Agreement dated August 1, 2015                   | January  1, 2021 -

December  31, 2021 |
| WFCM  2016-C37                    | Commercial  Mortgage Pass-Through Certificates, Series WFCM 2016-C37 pursuant to the  Pooling and Servicing Agreement dated December 1, 2016            | January  1, 2021 -

December  31, 2021 |
| CGCMT  2016-C3                    | Commercial  Mortgage Pass-Through Certificates, Series CGCMT 2016-C3 pursuant to the  Pooling and Servicing Agreement dated November 1, 2016            | January  1, 2021 -

December  31, 2021 |
| WFCM  2016-LC24                   | Commercial  Mortgage Pass-Through Certificates, Series WFCM 2016-LC24 pursuant to the  Pooling and Servicing Agreement dated September 1, 2016          | January  1, 2021 -

December  31, 2021 |
| WFCM  2016-NXS6                   | Commercial  Mortgage Pass-Through Certificates, Series WFCM 2016-NXS6 pursuant to the  Pooling and Servicing Agreement dated October 1, 2016            | January  1, 2021 -

December  31, 2021 |
| 245  Park Avenue Trust

2017-245P | Commercial  Mortgage Pass-Through Certificates, Series 245 Park Ave Trust 2017-245P  pursuant to the Pooling and Servicing Agreement dated May 30, 2017 | January  1, 2021 -

December  31, 2021 |
| CGCMT  2017-B1                    | Commercial  Mortgage Pass-Through Certificates, Series CGCMT 2017-B1 pursuant to the  Pooling and Servicing Agreement dated August 29, 2017             | January  1, 2021 -

December  31, 2021 |
| MSC  2017-H1                      | Commercial  Mortgage Pass-Through Certificates, Series MSC 2017-H1 pursuant to the  Pooling and Servicing Agreement dated June 8, 2017                  | January  1, 2021 -

December  31, 2021 |
| WFCM  2017-C39                    | Commercial  Mortgage Pass-Through Certificates, Series WFCM 2017-C39 pursuant to the Pooling  and Servicing Agreement dated August 22, 2017             | January  1, 2021 -

December  31, 2021 |
| WFCM  2017-RB1                    | Commercial  Mortgage Pass-Through Certificates, Series WFCM 2017-RB1 pursuant to the  Pooling and Servicing Agreement dated March 1, 2017               | January  1, 2021 -

December  31, 2021 |
| WFCM  2017-C41                    | Commercial  Mortgage Pass-Through Certificates, Series WFCM 2017-C41 pursuant to the  Pooling and Servicing Agreement dated November 1, 2017            | January  1, 2021 -

December  31, 2021 |