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**Management’s Reporton Assessment of Compliance with SEC Regulation AB**

**Servicing Criteriaas Primary Servicer**

 

BerkadiaCommercial Mortgage LLC (“Berkadia”) is responsible for assessing compliance,as of and for the year ended December 31, 2021 (the “Reporting Period”), withthe Servicing Criteria set forth in Item 1122(d) of Regulation AB of the U.S.Securities and Exchange Commission for asset-backed securities transactions.This assertion includes all commercial mortgage loans sold in publicsecuritizations from the period January 1, 2006 through December 31, 2021 forwhich Berkadia served as primary servicer (the “Platform”).

 

Berkadiahas concluded that the criteria are applicable as shown below (indicated by X)to the primary servicing of the loans in the Platform:

 

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**Regulation AB  Criteria 1122(d)**                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | **Applicability**

**of Criteria as**

**the Primary**

**Servicer** |
|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------|
| (1)  General servicing considerations.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             |                                                                 |
| (i)  Policies and procedures are instituted to monitor any performance or other  triggers and events of default in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                     | X                                                                    |
| (ii)  If any material servicing activities are outsourced to third parties,  policies and procedures are instituted to monitor the third party’s  performance and compliance with such servicing activities.                                                                                                                                                                                                                                                                                                                 | X                                                                    |
| (iii)  Any requirements in the transaction agreements to maintain a back-up servicer  for the pool assets are maintained.                                                                                                                                                                                                                                                                                                                                                                                                          | (1)                                                                  |
| (iv)  A fidelity bond and errors and omissions policy is in effect on the party  participating in the servicing function throughout the reporting period in  the amount of coverage required by and otherwise in accordance with the terms  of the transaction agreements.                                                                                                                                                                                                                                                         | X                                                                    |
| (v)  Aggregation of information, as applicable, is mathematically accurate and the  information conveyed accurately reflects the information.                                                                                                                                                                                                                                                                                                                                                                                      | X                                                                    |
| (2)  Cash collection and administration.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |                                                                 |
| (i)  Payments on pool assets are deposited into the 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.                                                                                                                                                                                                                                                                                                  | X                                                                    |
| (ii)  Disbursements made via wire transfer on behalf of an obligor or to an  investor are made only by authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                                       | X                                                                    |
| (iii)  Advances of funds or guarantees regarding collections, cash flows or  distributions, and any interest or other fees charged for such advances, are  made, reviewed and approved as specified in the transection agreements.                                                                                                                                                                                                                                                                                                 | X                                                                    |
| (iv)  The related accounts for the transaction, such as cash reserve accounts or  accounts established as a form of overcollateralization, are separately  maintained (e.g., with respect to commingling of cash) as set forth in the  transaction agreements.                                                                                                                                                                                                                                                                     | X                                                                    |
| (v)  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.                                                                                                                                        | X                                                                    |
| (vi)  Unissued checks are safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                        | X                                                                    |
| (vii)  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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | X                                                                    |
| (B)  Are prepared within 30 calendar days after the bank statement cutoff date, or  such other number of days specified in the transaction agreements;                                                                                                                                                                                                                                                                                                                                                                             | X                                                                    |
| (C)  Are reviewed and approved by someone other than the person who prepared the  reconciliation; and                                                                                                                                                                                                                                                                                                                                                                                                                              | X                                                                    |
| (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.                                                                                                                                                                                                                                                                                                            | X                                                                    |
| (3)  Investor remittances and reporting.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |                                                                 |
| (i)  Reports to investors, including those to be filed with the Commission, are  maintained in accordance with the transaction agreements and applicable  Commission requirements. Specifically, such reports:                                                                                                                                                                                                                                                                                                                     |                                                                 |
| (A)  Are prepared in accordance with timeframes and other terms set forth in the  transaction agreements;                                                                                                                                                                                                                                                                                                                                                                                                                          | X                                                                    |
| (B)  Provide information calculated in accordance with the terms specified in the  transaction agreements;                                                                                                                                                                                                                                                                                                                                                                                                                         | X                                                                    |
| (C)  Are filed with the Commission as required by its rules and regulations; and                                                                                                                                                                                                                                                                                                                                                                                                                                                   | (1)                                                                  |
| (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.                                                                                                                                                                                                                                                                                                                                                                      | X                                                                    |
| (ii)  Amounts due to investors are allocated and remitted in accordance with  timeframes, distribution priority and other terms set forth in the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                          | X                                                                    |
| (iii)  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.                                                                                                                                                                                                                                                                                                                                     | X                                                                    |
| (iv)  Amounts remitted to investors per the investor reports agree with cancelled  checks, or other form of payment, or custodial bank statements.                                                                                                                                                                                                                                                                                                                                                                                 | X                                                                    |
| (4)  Pool asset administration.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |                                                                 |
| (i)  Collateral or security on pool assets is maintained as required by the  transaction agreements or related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                               | X(2)                                                                 |
| (ii)  Pool assets and related documents are safeguarded as required by the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                | (1)                                                                  |
| (iii)  Any additions, removals or substitutions to the asset pool are made, reviewed  and approved in accordance with any conditions or requirements in the transaction  agreements.                                                                                                                                                                                                                                                                                                                                               | X                                                                    |
| (iv)  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.                                                                                           | X                                                                    |
| (v)  The servicer’s records regarding the pool assets agree with the servicer’s  records with respect to an obligor’s unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                  | X                                                                    |
| (vi)  Changes with respect to the terms or status of an obligor’s pool asset (e.g.,  loan modifications or re-agings) are made, reviewed and approved by authorized  personnel in accordance with the transaction agreements and related pool  asset documents.                                                                                                                                                                                                                                                              | X                                                                    |
| (vii)  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 agreements.                                                                                                                                                                                                                   | (1)                                                                  |
| (viii)  Records documenting collection efforts are maintained during the period a  pool asset is delinquent in accordance with the transaction agreements. Such  records are maintained on at least a monthly basis, or such other period  specified in the transaction agreements, and describe the entity’s activities  in monitoring delinquent pool assets including, for example, phone calls,  letters and payment rescheduling plans in cases where delinquency is deemed  temporary (e.g., illness or unemployment). | X                                                                    |
| (ix)  Adjustments to interest rates or rates of return for pool assets with  variable rates are computed based on the related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                | X                                                                    |
| (x)  Regarding any funds held in trust for an obligor (such as escrow accounts):                                                                                                                                                                                                                                                                                                                                                                                                                                                   |                                                                 |
| (A)  Such funds are analyzed, in accordance with the obligor’s pool asset  documents, on at least an annual basis, or such other period specified in the  transaction agreements;                                                                                                                                                                                                                                                                                                                                            | X                                                                    |
| (B)  Interest on such funds is paid, or credited, to obligors in accordance with  applicable pool asset documents and state laws; and                                                                                                                                                                                                                                                                                                                                                                                              | X                                                                    |
| (C)  Such funds are 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.                                                                                                                                                                                                                                                                                                                                           | X                                                                    |
| (xi)  Payments made on behalf of an obligor (such as tax or insurance payments) are  made on or before the related penalty or expiration dates, as indicated on  the appropriate bills or notices for such payments, provided that such  support has been received by the servicer at least 30 calendar days prior to  these dates, or such other number of days specified in the transaction  agreements.                                                                                                                         | X(2)                                                                 |
| (xii)  Any late payment penalties in connection with any payment to be made on  behalf of an obligor are paid from the servicer’s funds and not charged to  the obligor, unless the late payment was due to the obligor’s error or  omission.                                                                                                                                                                                                                                                                          | X(2)                                                                 |
| (xiii)  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.                                                                                                                                                                                                                                                                                                          | X(2)                                                                 |
| (xiv)  Delinquencies, charge-offs and uncollectible accounts are recognized and  recorded in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                           | X                                                                    |
| (xv)  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.                                                                                                                                                                                                                                                                                                                                        | (1)                                                                  |

 

XServicer was responsible for these criteria in its role as Primary Servicer.

(1) Per servicing andpooling agreements, the criteria does not apply to the role of PrimaryServicer.

(2) Vendor(s), forwhich Berkadia is the Responsible Party, contributes to the servicingactivities for these criteria.

 

TheServicing Criteria, after giving effect to the foregoing exclusions, arereferred to as the "Applicable Servicing Criteria".

 

Berkadiautilizes vendors to support its servicing operations, including the use of acommercial tax service which supports its assertions under 1122(d)(4)(xi)through (xiii) and the use of a lien filing firm to support its assertion under1122(d)(4)(i). This vendor activity contributes to the servicing activities towhich Berkadia is asserting. In all cases, the vendors' activities are limited,and Berkadia assumes responsibility for the 1122 assessment for these vendoractivities. These vendors do not fit the definition of servicer under Item1101(j), and Berkadia employs policies and procedures designed to provideassurance that the vendors' activities comply with the Applicable ServicingCriteria to such vendors.

 

Forthe Reporting Period, Berkadia has assessed its compliance with the ApplicableServicing Criteria for the Platform and has concluded that its servicingoperation has complied, in all material respects, with the Applicable ServicingCriteria.

 

GrantThornton LLP, an independent registered public accounting firm, has issued anattestation report on management's assertion of compliance with the ApplicableServicing Criteria.

 

 

BerkadiaCommercial Mortgage LLC 

 

February15, 2022

 

/s/Mark E. McCool

MarkE. McCool 

ExecutiveVice President

BerkadiaCommercial Mortgage LLC