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**GRANTTHORNTON LLP**

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**REPORTOF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM**

 

 

Boardof Directors

BerkadiaCommercial Mortgage, LLC

 

Wehave examined management’s assertion, included in the accompanying Management’sReport on Assessment of Compliance with SEC Regulation AB Servicing Criteria (“Management’sReport”), that Berkadia Commercial Mortgage, LLC (the “Company”) complied withthe servicing criteria set forth in Item 1122(d) of the U.S. Securities andExchange Commission’s Regulation AB for the Primary Servicing of CommercialMortgage Loans within Public Securitizations (the “Primary Servicing Platform”or the “Platform”) as of and for the year ended December 31, 2022, excludingcriteria 1122(d)(1)(iii), (3)(i)(C), (4)(ii), (4)(vii), and (4)(xv), whichmanagement has determined are not applicable to the activities performed by theCompany with respect to the Platform. The Platform consists of the of thepublicly issues asset-backed transactions and securities for which the Companyis named the primary servicer of commercial mortgage loans. Management isresponsible for the Company’s compliance with the applicable servicing criteria.Our responsibility is to express an opinion on management’s assertion about theCompany’s compliance with the applicable servicing criteria for the Platformbased on our examination.

 

Ourexamination was conducted in accordance with the standards of the PublicCompany Accounting Oversight Board (United States) and in accordance withattestation standards established by the American Institute of Certified PublicAccountants, and, accordingly, included examining, on a test basis, evidenceabout the Company’s compliance with the applicable servicing criteria for thePlatform and performing such other procedures as we considered necessary in thecircumstances. Our examination included testing selected asset-backedtransactions and securities constituting the Platform and evaluating whetherthe Company performed servicing activities related to those transactions and securitiesin compliance with the applicable servicing criteria for the period covered by thisreport. Accordingly, our testing may not have included servicing activitiesrelated to each asset-backed transaction or security constituting the Platform.Further, our examination was not designed to detect material noncompliance thatmay have occurred prior to the period covered by this report and that may have affectedthe Company’s servicing activities during the period covered by this report. Webelieve that our examination provides a reasonable basis for our opinion. Ourexamination does not provide a legal determination on the Company’s compliancewith the applicable servicing criteria.

 

Weare required to be independent and to meet our other ethical responsibilities inaccordance with relevant ethical requirements relating to the engagement.

 

Asdescribed in Management’s Report, the Company engaged various vendors toperform servicing activities with respect to criteria 1122(d)(2)(i),1122(d)(2)(iii), 1122(d)(4)(i) and 1122(d)(4)(xi) through 1122(d)(4)(xiii). TheCompany determined that each vendor is not considered a “servicer,” as thatterm is defined in Item 1101(j) of Regulation AB, and therefore, the Company isassuming responsibility for compliance with such servicing criteria applicableto each vendor’s servicing activities. In accordance with Regulation AB and itsrelated interpretations, the requirement for management to assess compliancewith the servicing criteria applicable to a vendor’s activities is satisfied ifthe Company has instituted policies and procedures to monitor whether suchvendor’s activities comply in all material respects with such criteria. Compliancewith the applicable servicing criteria is achieved if those policies andprocedures are designed to provide reasonable assurance that such vendor’sactivities comply with such criteria and those policies and procedures areoperating effectively for the period covered by Management’s Report. Ourexamination does not provide a legal determination of whether a vendor is or isnot considered a servicer, and therefore, on whether the Company, in itsManagement Report, is eligible to elect to take responsibility for assessingcompliance with the servicing criteria applicable to each vendor’s servicingactivities.

 

Inour opinion, management’s assertion that Berkadia Commercial Mortgage LLCcomplied with the aforementioned applicable servicing criteria as of and forthe year ended December 31, 2022 for the Primary Servicing Platform is fairlystated, in all material respects.

 

 

/s/Grant Thornton LLP

 

Philadelphia,Pennsylvania 

February15, 2023

 

 

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