(logo)K-Star

 

 

**MANAGEMENT’SREPORT ON ASSESSMENT OF COMPLIANCE WITH THE SECURITIES AND EXCHANGECOMMISSION’S REGULATION AB SERVICING CRITERIA**

** **

March13, 2024

 

1.       K-StarAsset Management LLC (“K-Star”) is responsible for assessing compliance withthe servicing criteria applicable to it under paragraph (d) of Item 1122 ofRegulation AB, as of and for the year ended December 31, 2023 (the “ReportingPeriod”). The transactions covered by this report include all transactions forwhich K-Star acted as special servicer (the “Platform”).

 

2.       Exceptas set forth in paragraph 3 below, K-Star used criteria set forth in paragraph(d) of Item 1122 of Regulation AB to assess the compliance with the applicableservicing criteria.

 

3.       Thecriteria listed in the column title “Inapplicable Servicing Criteria” onAppendix A hereto are not applicable to K-Star based on the activities itperforms with respect to the Platform.

 

4.       K-Starhas complied in all material respects with the applicable servicing criteria asof December 31, 2023 and for the Reporting Period with respect to the Platformtaken as a whole.

 

5.       FORVIS,LLP, an independent registered public accounting firm, has issued anattestation report on K-Star’s assessment of compliance with the applicableservicing criteria for the Reporting Period.

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**K-StarAsset Management LLC**

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/s/Elizabeth Luther

ElizabethLuther, Chief Operations Officer

 

/s/Angela Johnson

AngelaJohnson, Head of Special Servicing

 

 

**APPENDIX A**

 

| **SERVICING****CRITERIA**                                                                                       | **APPLICABLE****SERVICING********CRITERIA**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | **INAPPLICABLE**

**SERVICING CRITERIA**      |
|-----------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------|
| **Reference**                                                                                                   | **Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | **Performed****Directly********by****K-Star** | **Performed********by Vendor(s)********for which K-Star is the****Responsible  Party** | **Performed by****subservicer(s)****or vendor(s) for which K-Star********is********NOT****the****Responsible Party** | **NOT performed by  K-Star or by subservicer(s)********or****vendor(s)****retained by K-****Star** |
| **General********Servicing********Considerations**                                                              |
|  

 

1122(d)(1)(i)                                                                                   | Policies and procedures  are instituted tomonitor any  performanceorothertriggersandeventsofdefaultin accordance with the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | X                                             |   |   |   |
|  

 

 

1122(d)(1)(ii)                                                                          | If any material  servicing activities are outsourced to thirdparties,policiesandprocedures  areinstitutedto monitorthethirdparty’sperformanceandcompliance with such servicing  activities.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |  

Xi                                    |   |   |   |
|  

1122(d)(1)(iii)                                                                                         | Anyrequirementsinthetransactionagreements to maintainaback-upservicerforthepoolassetsare maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |                                          |   |   | X |
|  

 

 

 

1122(d)(1)(iv)                                                                  | A fidelity bond and  errors and omissions policy is in effectonthepartyparticipatingintheservicingfunction throughout the reporting period in the amount of  coveragerequiredbyandotherwiseinaccordancewith the terms of the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                       |  

X                                     |   |   |   |
|  

 

1122(d)(1)(v)                                                                                   | Aggregation of  information, as applicable, is mathematicallyaccurateandtheinformationconveyed accurately reflects the  information.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | Xi                                            |   |   |   |
| **Cash********Collection********and****Administration**                                                         |
|  

 

 

 

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

Xi                                    |   |   |   |
|  

 

1122(d)(2)(ii)                                                                                  | Disbursementsmadeviawiretransferonbehalfofan  obligor or to an investor are madeonly  by authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |                                          |   |   | X |
|  

 

 

 

1122(d)(2)(iii)                                                                 | Advancesoffundsorguaranteesregardingcollections, 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |  

Xi                                    |   |   |   |
|  

 

 

 

1122(d)(2)(iv)                                                                  | Therelatedaccountsforthetransaction,suchascash reserveaccountsoraccountsestablishedas aformof overcollateralization, are separately  maintained (e.g., withrespecttocomminglingofcash)assetforthinthe transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                              |  

Xi                                    |   |   |   |
|  

 

 

 

 

1122(d)(2)(v)                                                           |  Each custodial account is  maintained at a federally insured depository institution as set forth in the  transactionagreements. Forpurposesofthiscriterion, “federallyinsureddepositoryinstitution”withrespectto aforeignfinancialinstitutionmeansaforeignfinancial  institutionthatmeetstherequirementsofRule13k- 1(b)(1) of the Securities Exchange  Act.                                                                                                                                                                                                                                                                                                               |  

 

Xi                            |   |   |   |
|  

1122(d)(2)(vi)                                                                                          | Unissuedchecksaresafeguardedsoastoprevent  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 afterthebankstatementcutoffdate,orsuchothernumberof days specified in the transaction agreements; (C) reviewed and  approved by someone other than the personwhopreparedthereconciliation;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. |  

 

 

 

 

Xi    |   |   |   |
| **Investor********Remittances********and****Reporting**                                                         |
|  

 

 

 

 

 

 

 

 

 

 

 

1122(d)(3)(i)   | Reportstoinvestors,includingthosetobefiledwiththe  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.                          |                                          |   |   |  

 

 

X |
|  

 

1122(d)(3)(ii)                                                                                  | Amountsduetoinvestorsareallocatedandremittedin 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 twobusinessdaystotheServicer’sinvestorrecords,or such other number of days specified  in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             |                                          |   |   | X |
|  

 

 

1122(d)(3)(iv)                                                                          |  

Amounts remitted  to investors per the investor reports agreewithcancelledchecks,orotherformofpayment, or custodial  bank statements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |                                          |   |   | X |
| **Pool********Asset****Administration**                                                                         |
|  

 

1122(d)(4)(i)                                                                                   | Collateralorsecurityonpoolassetsismaintainedas required by the transaction  agreements or related mortgage loan documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | X                                             |   |   |   |
|  

1122(d)(4)(ii)                                                                                          | Poolassetandrelateddocumentsaresafeguardedas required by the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |                                          |   |   | X |
|  

 

 

1122(d)(4)(iii)                                                                         | Any additions,  removals or substitutions to the asset poolaremade,reviewedandapprovedinaccordance  with anyconditions or  requirements inthetransaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | X                                             |   |   |   |
|  

 

 

 

 

 

 

1122(d)(4)(iv)                                          | Payments on pool  assets, including any payoffs, made in accordance with the related pool asset  documents are postedtotheServicer’sobligor records maintained no more than  two business days after receipt, or such other number of days specified in  the transaction agreements,andallocatedtoprincipal,interestorother items(e.g.,escrow)inaccordancewiththerelatedpool asset documents.                                                                                                                                                                                                                                                                                         |                                          |   |   |  

X |
|  

 

1122(d)(4)(v)                                                                                   | TheServicer’srecordsregardingthepoolassetsagree 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'spoolassets(e.g.,loanmodificationsorre-  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,conductedandconcludedinaccordancewith the timeframes or other  requirements established by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                         |  

X                                     |   |   |   |
|  

 

 

 

 

 

 

 

 

1122(d)(4)(viii)                        | Recordsdocumentingcollectioneffortsaremaintained  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)                                                                                  | Adjustmentstointerestratesorratesofreturnforpool  assets withvariablerates arecomputed based onthe  related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |                                          |   |   | X |
|  

 

 

 

 

 

 

 

 

 

1122(d)(4)(x)                   | Regarding any  funds held in trust for an obligor (suchas  escrow accounts): (A) such funds are analyzed, in accordancewiththeobligor’spoolassetdocuments,on at least an annual basis, or such other  period specified in the transaction agreements; (B) interest on such fundsispaid,orcredited,toobligorsinaccordancewith 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,orsuchothernumberofdaysspecifiedinthe transaction agreements.                                                                                                                      |                                          |   |   |  

 

X |
|  

 

 

 

 

 

 

1122(d)(4)(xi)                                          | Payments madeon behalf of an obligor (suchas tax or insurancepayments)aremadeonorbeforetherelated penalty or  expiration dates, as indicated on the appropriatebillsornoticesforsuchpayments,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 paymenttobemadeonbehalfofanobligorarepaid 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)                                                                        | Disbursementsmadeonbehalfofanobligorareposted 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-offsanduncollectibleaccounts are recognized and recorded in  accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | X                                             |   |   |   |
|  

 

 

1122(d)(4)(xv)                                                                          | Anyexternalenhancementorothersupport,identified in Item  1114(a)(1) through (3) or Item 1115 of Regulation AB, is maintained as set  forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |                                          |   |   | X |

 

 

iAlthoughK-StarAssetManagement LLCis responsibleforperformingactivities underthiscriteria,noactions wereperformedwithrespecttosuchcriteria during the year ended December 31, 2023.