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**REPORTOF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM**

 

 

Boardof Managers

BerkadiaCommercial Mortgage LLC

 

Wehave examined management’s assertion, included in the accompanying Management’sReport on Assessment of Compliance with SEC Regulation AB Servicing Criteria asPrimary Servicer (“Management’s Report”), that Berkadia Commercial Mortgage LLC(the “Company”) complied with the servicing criteria set forth in Item 1122(d)of the U.S. Securities and Exchange Commission’s Regulation AB for the primaryservicing of commercial mortgage loans sold in public securitizations (the“Primary Servicing Platform” or the “Platform”) as of and for the year endedDecember 31, 2021, excluding criteria 1122(d)(1)(iii), (3)(i)(C), (4)(ii),(4)(vii), and (4)(xv), which management has determined are not applicable tothe activities performed by the Company with respect to the Platform. ThePlatform consists of the publicly issued asset-backed transactions andsecurities for which the Company is named the primary servicer of commercialmortgage loans. Management is responsible for the Company’s compliance with theapplicable servicing criteria. Our responsibility is to express an opinion onmanagement’s assertion about the Company’s compliance with the applicableservicing criteria for the Platform based 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-backed transactionsand securities constituting the Platform and evaluating whether the Companyperformed servicing activities related to those transactions and securities incompliance with the applicable servicing criteria for the period covered bythis report. Accordingly, our testing may not have included servicingactivities related to each asset-backed transaction or security constitutingthe Platform. Further, our examination was not designed to detect materialnoncompliance that may have occurred prior to the period covered by this reportand that may have affected the Company’s servicing activities during the periodcovered by this report. We believe that our examination provides a reasonablebasis for our opinion. Our examination does not provide a legal determinationon the Company’s compliance with the applicable servicing criteria.

 

Asdescribed in Management’s Report, the Company engaged various vendors toperform servicing activities with respect to criteria 1122(d)(4)(i) and (4)(xi)through 1122(d)(4)(xiii). The Company determined that each vendor is notconsidered a “servicer,” as that term is defined in Item 1101(j) of RegulationAB, and therefore, the Company is assuming responsibility for compliance withsuch servicing criteria applicable to each vendor’s servicing activities. Inaccordance with Regulation AB and its related interpretations, the requirementfor management to assess compliance with the servicing criteria applicable to avendor’s activities is satisfied if the Company has instituted policies andprocedures to monitor whether such vendor’s activities comply in all materialrespects with such criteria. Compliance with the applicable servicing criteriais achieved if those policies and procedures are designed to provide reasonableassurance that such vendor’s activities comply with such criteria and thosepolicies and procedures are operating effectively for the period covered byManagement’s Report. Our examination does not provide a legal determination ofwhether a vendor is or is not considered a servicer, and therefore, on whetherthe Company, in its Management Report, is eligible to elect to takeresponsibility for assessing compliance with the servicing criteria applicableto each vendor’s servicing activities.

 

Inour opinion, management’s assertion that Berkadia Commercial Mortgage LLCcomplied with the aforementioned applicable servicing criteria as of and forthe year ended December 31, 2021 for the Primary Servicing Platform is fairlystated, in all material respects.

 

 

/s/Grant Thornton LLP

 

Philadelphia,Pennsylvania 

February15, 2022

 

 

GT.COM

 

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