**Management's Assertion on Compliance with ApplicableRegulation AB Servicing Criteria**

 

1.       Rialto Capital Advisors, LLC. (the"Asserting Party") is responsible for assessing compliance with theservicing criteria applicable to it under paragraph (d) of Item 1122 ofRegulation AB, as of and for the 12-month period ending December 31, 2019 (the"Reporting Period"), as set forth in Appendix A hereto. Thetransactions covered by this report, include commercial mortgage-asset-backedsecurities transactions, as listed on Exhibit 1 hereto, for which the AssertingParty served as special servicer, and that were registered with the Securitiesand Exchange Commission pursuant to the Securities Act of 1933 (the "Platform");

 

2.       The Asserting Party has engaged certainvendors, which are not servicers as defined in Item 1101(j) of Regulation AB(the "Vendors"), to perform specific, limited or scripted activities,and the Asserting Party elects to take responsibility for assessing compliancewith the servicing criteria or portion of the servicing criteria applicable tosuch Vendors' activities as set forth in Appendix A hereto;

 

3.       Except as set forth in paragraph 4 below,the Asserting Party used the criteria set forth in paragraph (d) of Item 1122of Regulation AB to assess the compliance with the applicable servicingcriteria;

 

4.       The criteria listed in the column titled"Inapplicable Servicing Criteria" on Appendix A hereto areinapplicable to the Asserting Party based on the activities it performs,directly or through its Vendors, with respect to the Platform;

 

5.       The Asserting Party has complied, in allmaterial respects, with the applicable servicing criteria as of December 31,2019 and for the Reporting Period with respect to the Platform taken as awhole;

 

6.       The Asserting Party has not identified andis not aware of any material instance of noncompliance by the Vendors with theapplicable servicing criteria as of December 31, 2019 and for the ReportingPeriod with respect to the Platform taken as a whole;

 

7.       The Asserting Party has not identified anymaterial deficiency in its policies and procedures to monitor the compliance bythe Vendors with the applicable servicing criteria as of December 31, 2019 andfor the Reporting Period with respect to the Platform taken as a whole; and

 

8.       Deloitte & Touche LLP, an independentregistered public accounting firm, has issued an attestation report on theAsserting Party's assessment of compliance with the applicable servicingcriteria for the Reporting Period.

 

 

February 28, 2020

 

 

Name: Adam Singer

 

Title: Managing Director

 

/s/ Adam Singer

 

 

**Exhibit 1**

 

| **Pooling and Servicing Agreements**                                             | **Applicable Certification Period**    |
|----------------------------------------------------------------------------------|----------------------------------------|
| WFRBS 2012-C8                                                                    | January 1, 2019 to December 31, 2019   |
| WFCM 2012-LC5                                                                    | January 1, 2019 to December 31, 2019   |
| UBS-Barclays 2012-C3                                                             | January 1, 2019 to December 31, 2019   |
| UBS-Barclays 2012-C4                                                             | January 1, 2019 to December 31, 2019   |
| GSMS 2012-GCJ9                                                                   | January 1, 2019 to December 31, 2019   |
| JPMCC 2012-LC9                                                                   | January 1, 2019 to December 31, 2019   |
| COMM 2013-LC6                                                                    | January 1, 2019 to December 31, 2019   |
| WFRBS 2013-C12                                                                   | January 1, 2019 to December 31, 2019   |
| UBS-Barclays 2013-C6                                                             | January 1, 2019 to December 31, 2019   |
| GSMS 2013-GCJ12                                                                  | January 1, 2019 to December 31, 2019   |
| WFRBS 2013-C14                                                                   | January 1, 2019 to December 31, 2019   |
| WFRBS 2011-C5                                                                    | January 1, 2019 to December 31, 2019   |
| WFCM 2013-LC12                                                                   | January 1, 2019 to December 31, 2019   |
| WFRBS 2011-C2                                                                    | January 1, 2019 to December 31, 2019   |
| WFRBS 2011-C3                                                                    | January 1. 2019 to December 31, 2019   |
| WFRBS 2011-C4                                                                    | January 1, 2019 to December 31, 2019   |
| UBS-Citigroup 2011-C1                                                            | January 1, 2019 to December 31, 2019   |
| UBS 2012-C1                                                                      | January 1, 2019 to December 31, 2019   |
| WFRBS 2012-C6                                                                    | January 1, 2019 to December 31, 2019   |
| GSMS 2011-GC3                                                                    | January 1, 2019 to December 31, 2019   |
| COMM 2013-LC13                                                                   | January 1, 2019 to December 31, 2019   |
| WFRBS 2013-C16                                                                   | January 1, 2019 to December 31, 2019   |
| GSMS 2013-GCJ16                                                                  | January 1, 2019 to December 31, 2019   |
| WFRBS 2013-C17                                                                   | January 1, 2019 to December 31, 2019   |
| GSMS 2012-GC6                                                                    | January 1, 2019 to December 31, 2019   |
| MSBAM 2013-C13                                                                   | January 1, 2019 to December 31, 2019   |
| COMM 2014-CCRE14                                                                 | January 1, 2019 to December 31, 2019   |
| MSBAM 2014-C14                                                                   | January 1, 2019 to December 31, 2019   |
| WFRBS 2014-LC14                                                                  | January 1, 2019 to December 31, 2019   |
| COMM 2014-LCl5                                                                   | January 1, 2019 to December 31, 2019   |
| WFRBS 2014-C20                                                                   | January 1, 2019 to December 31, 2019   |
| COMM 2014-CCRE18                                                                 | January 1, 2019 to December 31, 2019   |
| CGCMT 2014-GC23                                                                  | January 1, 2019 to December 31, 2019   |
| MSBAM 2014-C17                                                                   | January 1, 2019 to December 31, 2019   |
| COMM 2014-UBS5                                                                   | January 1, 2019 to December 31, 2019   |
| MSBAM 2014-C18                                                                   | January 1, 2019 to December 31, 2019   |
| COMM 2012-CCRE4                                                                  | January 1, 2019 to December 31, 2019   |
| WFRBS 2014-C24                                                                   | January 1, 2019 to December 31, 2019   |
| JPMBB 2014-C25                                                                   | January 1, 2019 to December 31, 2019   |
| LCCM 2014-909                                                                    | January 1, 2019 to December 31, 2019   |
| WFCM 2014-LC18                                                                   | January 1, 2019 to December 31, 2019   |
| COMM 2015-DC1                                                                    | January 1, 2019 to December 31, 2019   |
| GSMS 2015-GC28                                                                   | January 1, 2019 to December 31, 2019   |
| WFCM 2015-C27                                                                    | January 1, 2019 to December 31, 2019   |
| WFCM 2015-LC20                                                                   | January 1, 2019 to December 31, 2019   |
| WFCM 2015-NXS1                                                                   | January 1, 2019 to December 31, 2019   |
| CSAIL 2015-C2                                                                    | January 1, 2019 to December 31, 2019   |
| WFCM 2015-NXS2                                                                   | January 1, 2019 to December 31, 2019   |
| COMM 2015-PCl                                                                    | January 1, 2019 to December 31, 2019   |
| CSAIL 2015-C3                                                                    | January 1, 2019 to December 31, 2019   |
| WFCM 2015-SG1                                                                    | January 1, 2019 to December 31, 2019   |   |
| WFCM 2015-LC22                                                                   | January 1, 2019 to December 31, 2019   |   |
| COMM 2015-CCRE27                                                                 | January 1, 2019 to December 31, 2019   |   |
| WFCM 2015-NXS4                                                                   | January 1, 2019 to December 31, 2019   |   |
| MSCI 2015-UBS8                                                                   | January 1, 2019 to December 31, 2019   |   |
| CSAIL 2016-C5                                                                    | January 1, 2019 to December 31, 2019   |   |
| WFCM 20 l 6-C32                                                                  | January 1, 2019 to December 31, 2019   |   |
| WFCM 2016-NXS5                                                                   | January 1, 2019 to December 31, 2019   |   |
| CGCMT 2015-GC27                                                                  | January 1, 2019 to December 31, 2019   |   |
| WFCM 2016-C33                                                                    | January 1, 2019 to December 31, 2019   |   |
| MSBAM 2016-C29                                                                   | January 1, 2019 to December 31, 2019   |   |
| CFCRE 2016-C4                                                                    | January 1, 2019 to December 31, 2019   |   |
| GSMS 2016-GS2 (Special Servicer solely

for the Veritas Multifamily Pool 2 only) | January 1, 2019 to December 31, 2019   |   |
| BACM 2016-UBS10                                                                  | January 1, 2019 to December 31, 2019   |   |
| SGCMS 2016-C5                                                                    | January 1, 2019 to December 31, 2019   |   |
| WFCM 2016-BNK1                                                                   | January 1, 2019 to December 31, 2019   |   |
| CD 2016-CD1                                                                      | January 1, 2019 to December 31, 2019   |   |
| GSMS 2016-GS3                                                                    | January 1, 2019 to December 31, 2019   |   |
| MSBAM 2016-C31                                                                   | January 1, 2019 to December 31, 2019   |   |
| CGCMT 2016-C3                                                                    | January 1, 2019 to December 31, 2019   |   |
| CFCRE 2016-C6                                                                    | January 1, 2019 to December 31, 2019   |   |
| CSAIL 2016-C7                                                                    | January 1, 2019 to December 31, 2019   |   |
| MSCI 2016-UBS12                                                                  | January 1, 2019 to December 31, 2019   |   |
| BBCMS 2017-C1                                                                    | January 1, 2019 to December 31, 2019   |   |
| GSMS 2017-GS5                                                                    | January 1, 2019 to December 31, 2019   |   |
| CGCMT 2017-P7                                                                    | January 1, 2019 to December 31, 2019   |   |
| BANK 2017-BNK4                                                                   | January 1, 2019 to December 31, 2019   |   |
| CD 2017-CD4                                                                      | January 1, 2019 to December 31, 2019   |   |
| CFCRE 2017-C8                                                                    | January 1, 2019 to December 31, 2019   |   |
| JPMCC 2017-JP6                                                                   | January 1, 2019 to December 31, 2019   |   |
| CD 2017-CD5                                                                      | January 1, 2019 to December 31, 2019   |   |
| GSMS 2017-GS7                                                                    | January 1, 2019 to December 31, 2019   |   |
| BANK 2017-BNK7                                                                   | January 1, 2019 to December 31, 2019   |   |
| CSAIL 2017-CX9                                                                   | January 1, 2019 to December 31, 2019   |   |
| UBS 2017-C4                                                                      | January 1, 2019 to December 31, 2019   |   |
| UBS 2017-C6                                                                      | January 1, 2019 to December 31, 2019   |   |
| BANK 2017-BNK9                                                                   | January 1, 2019 to December 31, 2019   |   |
| GSMS 2018-GS9                                                                    | January 1, 2019 to December 31, 2019   |   |
| UBS 2018-C9                                                                      | January 1, 2019 to December 31, 2019   |   |
| MSCI 2012-C5                                                                     | January 1, 2019 to December 31, 2019   |   |
| WFCM 2018-C44                                                                    | January 1, 2019 to December 31, 2019   |   |
| UBS 2018-C10                                                                     | January 1, 2019 to December 31, 2019   |   |
| WFCM 2015-C30                                                                    | January 1, 2019 to December 31, 2019   |   |
| JPMBB 2014-C23                                                                   | January 1, 2019 to December 31, 2019   |   |
| MSBAM 2014-C19                                                                   | January 1, 2019 to December 31, 2019   |   |
| COMM 2015-LC21                                                                   | January 1, 2019 to December 31, 2019   |   |
| MSCI 2015 -C20                                                                   | January 1, 2019 to December 31, 2019   |   |
| JPMBB 2015-C31                                                                   | January 1, 2019 to December 31, 2019   |   |
| GSMS 2018-GS10                                                                   | January 1, 2019 to December 31, 2019   |   |
| CD 2018-CD7                                                                      | January 1, 2019 to December 31, 2019   |   |
| GSMS 2018-3PCK                                                                   | January 1, 2019 to December 31, 2019   |   |
| BANK 2018-BNK14                                                                  | January 1, 2019 to December 31, 2019   |   |
| DBGS 2018-C1                                                                     | January 1, 2019 to December 31, 2019   |   |
| CSAIL 2018 -C14                                                                  | January 1, 2019 to December 31, 2019   |   |
| UBS 2018-C14                                                                     | January 1, 2019 to December 31, 2019   |   |
| ILPT 2019-SURF                                                                   | March 7, 2019 to December 31, 2019     |   |
| MSCI 2019-L2                                                                     | March 12, 2019 to December 31, 2019    |   |
| WFCM 2019-CS0                                                                    | May 14, 2019 to December 31, 2019      |   |
| BANK 2019-BNK18                                                                  | May 31, 2019 to December 31, 2019      |   |
| WFCM 2015-P2                                                                     | May 31, 2019 to December 31, 2019      |   |
| BMARK 2019-B11                                                                   | June 17, 2019 to December 31, 2019     |   |
| CGCMT 2019-GC41                                                                  | August 20, 2019 to December 31, 2019   |   |
| BBCMS 2019-C4                                                                    | August 28, 2019 to December 31, 2019   |   |
| COMM 2014-CCRE15                                                                 | August 29, 2019 to December 31, 2019   |   |
| UBSCM 2019-C17                                                                   | October 15, 2019 to December 31, 2019  |   |
| BANK 2019-BNK21                                                                  | October 23, 2019 to December 31, 2019  |   |
| CGCMT 2019-GC43                                                                  | November 13, 2019 to December 31, 2019 |   |
| FS RIALTO 2019-FL1                                                               | December 5, 2019 to December 31, 2019  |   |
| CSAIL 2019-C18                                                                   | December 12, 2019 to December 31, 2019 |   |
| COMM 2019-GC44                                                                   | December 12, 2019 to December 31, 2019 |   |
| UBS 2019-C18                                                                     | December 20, 2019 to December 31, 2019 |   |
|                                                                             |                                   |   |   |

 

 

 

 

APPENDIX A

 

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

** **

**Reference**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | ** **

** **

**Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | **Performed by Servicer** | **Inapplicable Servicing**

**Criteria** |
|                                                                     | **General Servicing Considerations**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |
|                                                                     |  

 

1122(d)(l)(i)                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | Policies and procedures are instituted to monitor any  performance or other triggers and events of default in accordance with the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | ** **

**X** |   |
|                                                                     |  

 

1122(d)(l)(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | ** **

**X1** |   |
|                                                                     |  

 

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

**X** |
|                                                                     |  

 

 

1122(d)(l)(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** |   |
|                                                                     |  

 

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

**X** |   |
|                                                                     | **Cash Collection and Administration**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |
|                                                                     |  

 

 

1122(d)(2)(i)                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | Payments on pool assets are deposited into the  appropriate custodial bank accounts and related bank clearing accounts no  more than two business days following receipt, or such other number of days  specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                              | ** **

** **

**X** |   |
|                                                                     |  

 

1122(d)(2)(ii)                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | Disbursements made via wire transfer on behalf of an  obligor or to an investor are made only by authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |   | ** **

**X3** |
|                                                                     |  

 

 

1122(d)(2)(iii)                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | Advances of funds or guarantees regarding  collections, cash flows or distributions, and any interest or other fees  charged for such advances, are made, reviewed and approved as specified in  the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |   | ** **

**X3** |
|                                                                     |  

 

 

1122(d)(2)(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** |   |
|                                                                     |  

 

 

 

 

1122(d)(2)(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 Rule 13k-1(b)(1)  of the Securities Exchange Act.                                                                                                                                                                                                                                                                                                                | ** **

** **

** **

**X** |   |
|                                                                     |  

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

**X** |   |
|                                                                     |  

 

 

 

 

 

 

 

 

 

 

 

 

1122(d)(2)(vii)                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | Reconciliations are prepared on a monthly basis for  all asset-backed securities related bank accounts, including custodial  accounts and related bank clearing accounts. These reconciliations are (A)  mathematically accurate; (B) prepared within 30 calendar days after the bank  statement cutoff date, or such other number of days specified in the  transaction agreements; (C) 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. | ** **

** **

** **

** **

** **

** **

**X** |   |
|                                                                     | **Investor Remittances and Reporting**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |
|                                                                     |  

 

 

 

 

 

 

 

 

 

1122(d)(3)(i)                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | Reports to investors, including those to be filed  with the Commission, are maintained in accordance with the transaction  agreements and applicable Commission requirements. Specifically, such reports  (A) are prepared in accordance with timeframes and other terms set forth in  the transaction agreements; (B) provide information calculated in accordance  with the terms specified in the transaction agreements; (C) are filed with  the Commission as required by its rules and regulations; 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.                                               | ** **

**X4** |   |
|                                                                     |  

 

1122(d)(3)(ii)                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | Amounts due to investors are allocated and remitted  in accordance with timeframes, distribution priority and other terms set  forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |   | ** **

**X** |
|                                                                     |  

 

1122(d)(3)(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** |
|                                                                     |  

 

1122(d)(3)(iv)                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | Amounts remitted to investors per the investor  reports agree with cancelled checks, or other form of payment, or custodial  bank statements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |   | ** **

**X** |
|                                                                     | **Pool Asset Administration**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |
|  

 

1122(d)(4)(i)                                            | Collateral or security on pool assets is maintained  as required by the transaction agreements or related mortgage loan documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                           | ** **

**X**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             |   |
|  

1122(d)(4)(ii)                                                   | pool asset and related documents are safeguarded as  required by the transaction agreements                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | **X**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |   |
|  

 

 

1122(d)(4)(iii)                                  | Any additions, removals or substitutions to the asset  pool are made, reviewed and approved in accordance with any conditions or requirements  in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                | **X**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |   |
|  

 

 

 

1122(d)(4)(iv)                           | Payments on pool assets, including any payoffs, made  in accordance with the related pool asset documents are posted to the  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.                                                                                                                                                                            | ** **

** **

** **

**X2**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |   |
|  

 

1122(d)(4)(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** |
|  

 

 

1122(d)(4)(vi)                                   | Changes with respect to the terms or status of an  obligor's pool assets (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**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |   |
|  

 

 

1122(d)(4)(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.                                                                                                                                                                                                                                                                                   | ** **

** **

**X**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |   |
|  

 

 

 

 

 

 

1122(d)(4)(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**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             |   |
|  

 

1122(d)(4)(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** |
|  

 

 

 

 

 

 

1122(d)(4)(x)    | Regarding any funds held in trust for an obligor  (such as escrow accounts): (A) such funds are analyzed, in accordance with  the obligor's 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) such funds are returned to the  obligor within 30 calendar days of full repayment of the related pool assets,  or such other number of days specified in the transaction agreements. |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | ** **

** **

** **

** **

**X** |
|  

 

 

 

 

 

1122(d)(4)(xi)           | Payments made on behalf of an obligor (such as tax or  insurance payments) are made on or before the related penalty or expiration  dates, as indicated on the appropriate bills or notices for such payments,  provided that such support has been received by the Servicer at least 30  calendar days prior to these dates, or such

other number of days specified in the transaction  agreements.                                                                                                                                                                                        |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | ** **

** **

** **

**X** |
|  

 

 

1122(d)(4)(xii)                                  | Any late payment penalties in connection with any payment  to be made on behalf of an obligor are paid from the Servicer's funds and not  charged to the obligor, unless the late payment was due to the obligor's  error or omission.                                                                                                                                                                                                                                                                                                                                                       |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | ** **

** **

**X** |
|  

 

1122(d)(4)(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** |
|  

 

1122(d)(4)(xiv)                                          | Delinquencies, charge-offs and uncollectible accounts  are recognized and recorded in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                            |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | ** **

**X** |
|  

 

1122(d)(4)(xv)                                           | Any external enhancement or other support, identified  in Item 1114(a)(1) through (3) or Item 1115 of Regulation AB, is maintained  as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                              |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | ** **

**X** |
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**X1**- Rialto Capital Advisors, LLC performs the activitiespertaining to this criterion, except for specific, limited activities performedby its third-party property managers relating to REO Property, if any. Rialtohas elected to take responsibility for assessing compliance with theseservicing criteria with respect to the activities of its third-party propertymanagers.

 

**X2**- Primary responsibility for processing borrowerpayments rests with the Master Servicer, however, Rialto Capital Advisors, LLCmay from time to time receive payments on an exception basis which are forwardedto the Master Servicer in accordance with such criteria. The criteria is markedapplicable as Rialto Capital Advisors, LLC had instances or activity relatingto this criteria for the calendar year of January 1, 2019 to December 31, 2019.

 

**X3**- Rialto Capital Advisors, LLC performs the activitiesunder the criteria, however the related criteria are marked inapplicable asRialto did not have instances/activity during the calendar year of January 1,2019 and ending on December 31, 2019 relating to the criteria.

 

**X4**- Only items (A) and (B) of the Servicing Criteria areapplicable to Rialto Capital Advisors, LLC as special servicer. Items (C) and(D) are inapplicable as the responsibility for filing reports with theCommission and agreeing totals to the Servicer records rests with the Trusteeand/or Certificate Administrator, as applicable.