**UNITED STATESSECURITIES AND EXCHANGE COMMISSION**

**Washington, D.C. 20549**

**FORM 10-K**

(Mark One)

**x****  ANNUAL REPORT PURSUANT TO SECTION13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934**

**For the fiscal year ended December 31, 2021or**

**o**** ****TRANSITIONREPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934**

**For the transition period from _____ to _____Commission file number of the issuing entity: 333-226850-02**

**Central Index Key Number of the issuing entity:0001772527**

**BBCMS Mortgage Trust 2019-C3**

**(exact name of the issuing entity as specified in itscharter)**

** **

**Central Index Key Number of the depositor: 0001541480**

**Barclays Commercial MortgageSecurities LLC**

**(exact name of the depositor as specified in itscharter)**

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**Central Index Key Number of the sponsor: 0001549574**

**Barclays Capital Real Estate Inc.**

**(exact name of the sponsor as specified in its charter)**

** **

**Central Index Key Number of the sponsor: 0001755531**

**Societe Generale FinancialCorporation**

**(exact name of the sponsor as specified in its charter)**

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**Central Index Key Number of the sponsor: 0001089877**

**KeyBank National Association**

**(exact name of the sponsor as specified in its charter)**

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**Central Index Key Number of the sponsor: 0001685185**

**UBS AG, acting through its branch locatedat 1285 Avenue of the Americas, New York, New York**

**(exact name of the sponsor as specified in its charter)**

** **

**Central Index Key Number of the sponsor: 0001542256**

**Natixis Real Estate Capital LLC**

**(exact name of the sponsor as specified in its charter)**

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**Central Index Key Number of the sponsor: 0001592182**

**LMF Commercial, LLC**

**(exact name of the sponsor as specified in its charter)**

**(formerly known as RialtoMortgage Finance, LLC)**

** **

| **New York****(State or other jurisdiction of  incorporation or organization of**

**the issuing entity)** | **38-4117282**

**38-4117283**

**(I.R.S. Employer**

**Identification Numbers)** |
|------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------|

**c/o Wells Fargo Bank, National Association**

**as Certificate Administrator**

**9062 Old Annapolis Road**

**Columbia, MD**

**(Address of principal executiveoffices of the issuing entity)**

**21045**

**(Zip Code)**

**Registrant’s telephone number,including area code:**

**(212) 412-4000**

Securities registered pursuant to Section 12(b) of the Act:

| Title of each class | Trading Symbol(s) | Name of each exchange on which registered |
|---------------------|-------------------|-------------------------------------------|
| None                |              |                                      |

 

Securities registered pursuant to Section 12(g) of theAct:  None.

Indicate by check mark if the registrant is a well-knownseasoned issuer, as defined in Rule 405 of the Securities Act.  o Yes ⌧No

Indicate by check mark if the registrant is not required tofile reports pursuant to Section 13 or Section 15(d) of the Act.  o Yes ⌧No

Indicate by check mark whether the registrant (1) has filedall reports required to be filed by Section 13 or 15(d) of the SecuritiesExchange Act of 1934 during the preceding 12 months (or for such shorter periodthat the registrant was required to file such reports), and (2) has beensubject to such filing requirements for the past 90 days.  ⌧ Yes oNo

Indicate by check mark whether the registrant has submittedelectronically and posted on its corporate Web site, if any, every InteractiveData File required to be submitted and posted pursuant to Rule 405 ofRegulation S-T (Section 232.405 of this chapter) during the preceding 12 months(or for such shorter period that the registrant was required to submit and postsuch files).

Not applicable.

Indicate by check mark if disclosure of delinquent filerspursuant to Item 405 of Regulation S-K (Section 229.405 of this chapter) is notcontained herein, and will not be contained, to the best of registrant’sknowledge, in definitive proxy or information statements incorporated byreference in Part III of this Form 10-K or any amendment to this Form10-K.   

Not applicable.

Indicate by check mark whether the registrant is a largeaccelerated filer, an accelerated filer, a non-accelerated filer, a smallerreporting company, or an emerging growth company. See the definitions of “largeaccelerated filer,” “accelerated filer,” “smaller reporting company,” and“emerging growth company” in Rule 12b-2 of the Exchange Act.

Large acceleratedfiler        o                                                                                                       Acceleratedfiler                                     o

Non-acceleratedfiler          ⌧  (Do not check if asmaller reporting company)                          Smaller reporting company                    o

                                                                                                                                                       Emerging growthcompany                    o

If an emerging growth company, indicate by check mark if theregistrant has elected not to use the extended transition period for complyingwith any new or revised financial accounting standards provided pursuant toSection 13(a) of the Exchange Act.  o

Indicate by check mark whether the registrant has filed areport on and attestation to its management’s assessment of the effectivenessof its internal control over financial reporting under Section 404(b) of theSarbanes-Oxley Act (15 U.S.C. 7262(b)) by the registered public accounting firmthat prepared or issued its audit report. o

Indicate by check mark whether the registrant is a shell company(as defined in Rule 12b-2 of the Act).  oYes ⌧ No

State the aggregate market value of the voting and non-votingcommon equity held by non-affiliates computed by reference to the price atwhich the common equity was last sold, or the average bid and asked price ofsuch common equity, as of the last business day of the registrant’s mostrecently completed second fiscal quarter.

Not applicable.

Indicate by check mark whether the registrant has filed alldocuments and reports required to be filed by Section 12, 13 or 15(d) of theSecurities Exchange Act of 1934 subsequent to the distribution of securitiesunder a plan confirmed by a court.  oYes oNo

Not applicable.

Indicate the number of shares outstanding of each of theregistrant’s classes of common stock, as of the latest practicable date.

Not applicable.

**DOCUMENTS INCORPORATED BY REFERENCE**

** **

List hereunder the following documents if incorporated byreference and the Part of the Form 10-K (e.g., Part I, Part II, etc.) intowhich the document is incorporated: (1) Any annual report to security holders;(2) Any proxy or information statement; and (3) Any prospectus filed pursuantto Rule 424(b) or (c) under the Securities Act of 1933. The listed documentsshould be clearly described for identification purposes (e.g., annual report tosecurity holders for fiscal year ended December 24, 1980).

Not applicable.

 

** **

**EXPLANATORY NOTES**

The SSTII Self Storage Portfolio II MortgageLoan, the Vanguard Portfolio Mortgage Loan, the SWVP Portfolio Mortgage Loan,the Inland Devon Self Storage Portfolio Mortgage Loan, the Wolverine PortfolioMortgage Loan, the Kings Mountain Center Mortgage Loan, the Patuxent CrossingMortgage Loan and The Block Northway Mortgage Loan, which constitutedapproximately 6.1%, 5.9%, 4.8%, 4.4%, 3.2%, 2.7%, 2.1% and 1.8%, respectively,of the asset pool of the issuing entity as of its cut-off date, are each anasset of the issuing entity and are each part of a loan combination thatincludes (a) with respect to the SSTII Self Storage Portfolio II Mortgage Loan,three other *pari passu* loans, which are not assets of the issuingentity, (b) with respect to the Vanguard Portfolio Mortgage Loan, four other *paripassu* loans and one subordinate companion loan, each of which are notassets of the issuing entity, (c) with respect to the SWVP Portfolio MortgageLoan, eight other *pari passu* loans, which are not assets of the issuingentity, (d) with respect to the Inland Devon Self Storage Portfolio MortgageLoan, one other *pari passu* loan, which is not an asset of the issuingentity, (e) with respect to the Wolverine Portfolio Mortgage Loan, five other *paripassu* loans, which are not assets of the issuing entity, (f) with respectto the Kings Mountain Center Mortgage Loan, one other *pari passu* loan, whichis not an asset of the issuing entity, (g) with respect to the PatuxentCrossing Mortgage Loan, one other *pari passu* loan, which is not an assetof the issuing entity and (h) with respect to The Block Northway Mortgage Loan,six other *pari passu* loans, which are not assets of the issuing entity.These loan combinations, including the SSTII Self Storage Portfolio II MortgageLoan, the Vanguard Portfolio Mortgage Loan, the SWVP Portfolio Mortgage Loan,the Inland Devon Self Storage Portfolio Mortgage Loan, the Wolverine PortfolioMortgage Loan, the Kings Mountain Center Mortgage Loan, the Patuxent CrossingMortgage Loan and The Block Northway Mortgage Loan, are being serviced andadministered pursuant to the Pooling and Servicing Agreement, which is incorporatedby reference as Exhibit 4.1 to this Annual Report on Form 10-K. 

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Christiana Mall Mortgage Loan, which constitutedapproximately 1.0% of the asset pool of the issuing entity as of its cut-offdate.  The Christiana Mall Mortgage Loan is an asset of the issuing entityand is part of a loan combination that includes the Christiana Mall MortgageLoan and twelve other *pari passu* loans and three subordinate companionloans, which are not assets of the issuing entity. A *pari passu* portionof the loan combination was securitized in the BBCMS 2018-CHRS Mortgage Trusttransaction (the “BBCMS 2018-CHRS Transaction”). This loan combination,including the Christiana Mall Mortgage Loan, is being serviced and administeredpursuant to the trust and servicing agreement for the BBCMS 2018-CHRSTransaction, which is incorporated by reference as Exhibit 4.2 to this AnnualReport on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the 787 Eleventh Avenue Mortgage Loan, whichconstituted approximately 3.2% of the asset pool of the issuing entity as ofits cut-off date.  The 787 Eleventh Avenue Mortgage Loan is an asset ofthe issuing entity and is part of a loan combination that includes the 787Eleventh Avenue Mortgage Loan, three other *pari passu* loans and twosubordinate companion loans, which are not assets of the issuing entity. A *paripassu* portion of the loan combination was securitized in the SG CommercialMortgage Securities Trust 2019-787E transaction (the “SGCMS 2019-787ETransaction”). This loan combination, including the 787 Eleventh AvenueMortgage Loan, is being serviced and administered pursuant to the trust andservicing agreement for the SGCMS 2019-787E Transaction, which is incorporatedby reference as Exhibit 4.3 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the ExchangeRight Net Leased Portfolio 24Mortgage Loan, which constituted approximately 1.6% of the asset pool of theissuing entity as of its cut-off date.  The ExchangeRight Net LeasedPortfolio 24 Mortgage Loan is an asset of the issuing entity and is part of aloan combination that includes the ExchangeRight Net Leased Portfolio 24Mortgage Loan and three other *pari passu* loans, which are not assets ofthe issuing entity. A *pari passu* portion of the loan combination wassecuritized in the CSAIL 2019-C15 Commercial Mortgage Trust transaction,Commission File Number 333-227081-01 (the “CSAIL 2019-C15 Transaction”).This loan combination, including the ExchangeRight Net Leased Portfolio 24Mortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the CSAIL 2019-C15 Transaction, which is incorporatedby reference as Exhibit 4.4 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the ILPT Hawaii Portfolio Mortgage Loan, whichconstituted approximately 1.1% of the asset pool of the issuing entity as ofits cut-off date.  The ILPT Hawaii Portfolio Mortgage Loan is an asset ofthe issuing entity and is part of a loan combination that includes the ILPTHawaii Portfolio Mortgage Loan and seventeen other *pari passu* loans,which are not assets of the issuing entity. A *pari passu* portion of theloan combination was securitized in the ILPT Trust 2019-SURF transaction (the “ILPT2019-SURF Transaction”). This loan combination, including the ILPT HawaiiPortfolio Mortgage Loan, is being serviced and administered pursuant to thetrust and servicing agreement for the ILPT 2019-SURF Transaction, which isincorporated by reference as Exhibit 4.5 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the NEMA San Francisco Mortgage Loan, whichconstituted approximately 3.7% of the asset pool of the issuing entity as ofits cut-off date.  The NEMA San Francisco Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the NEMA SanFrancisco Mortgage Loan, three other *pari passu* loans and threesubordinate companion loans, which are not assets of the issuing entity. A *paripassu* portion of the loan combination was securitized in the NatixisCommercial Mortgage Securities Trust 2019-NEMA transaction (the “NCMS2019-NEMA Transaction”). This loan combination, including the NEMA SanFrancisco Mortgage Loan, is being serviced and administered pursuant to thetrust and servicing agreement for the NCMS 2019-NEMA Transaction, which isincorporated by reference as Exhibit 4.6 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to The Colonnade Office Complex Mortgage Loan andthe Southern Motion Industrial Portfolio Mortgage Loan, which constitutedapproximately 3.2% and 1.1%, respectively, of the asset pool of the issuingentity as of its cut-off date.  The Colonnade Office Complex Mortgage Loanand the Southern Motion Industrial Portfolio Mortgage Loan are each an asset ofthe issuing entity and are each part of a loan combination that includes (a)with respect to The Colonnade Office Complex Mortgage Loan, seven other *paripassu* loans and seven subordinate companion loans, which are not assets ofthe issuing entity or (b) with respect to the Southern Motion IndustrialPortfolio Mortgage Loan, four other *pari passu* loans, which are notassets of the issuing entity. A *pari passu* portion of each loancombination was securitized in the UBS Commercial Mortgage Trust 2019-C16transaction, Commission File Number 333-227784-03 (the “UBS 2019-C16Transaction”). These loan combinations, including The Colonnade OfficeComplex Mortgage Loan and the Southern Motion Industrial Portfolio MortgageLoan, are being serviced and administered pursuant to the pooling and servicingagreement for the UBS 2019-C16 Transaction, which is incorporated by referenceas Exhibit 4.7 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Goodyear Portfolio Mortgage Loan and theHeartland Dental Medical Office Portfolio Mortgage Loan, which constitutedapproximately 1.7% and 1.5%, respectively, of the asset pool of the issuingentity as of its cut-off date.  The Goodyear Portfolio Mortgage Loan andthe Heartland Dental Medical Office Portfolio Mortgage Loan are each an asset ofthe issuing entity and are each part of a loan combination that includes (a)with respect to the Goodyear Portfolio Mortgage Loan, one other *pari passu*loan and one subordinate companion loan, which are not assets of the issuingentity or (b) with respect to the Heartland Dental Medical Office PortfolioMortgage Loan, ten other *pari passu* loans, which are not assets of theissuing entity. The other *pari passu* portion of each loan combinationwas securitized in the Wells Fargo Commercial Mortgage Trust 2019-C50 transaction,Commission File Number 333-226486-05 (the “WFCM 2019-C50 Transaction”).These loan combinations, including the Goodyear Portfolio Mortgage Loan and theHeartland Dental Medical Office Portfolio Mortgage Loan, are being serviced andadministered pursuant to the pooling and servicing agreement for the WFCM2019-C50 Transaction, which is incorporated by reference as Exhibit 4.8 to thisAnnual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the GNL Industrial Portfolio Mortgage Loan andthe ExchangeRight Net Leased Portfolio 26 Mortgage Loan, which constitutedapproximately 5.2% and 2.1%, respectively, of the asset pool of the issuingentity as of its cut-off date.  The GNL Industrial Portfolio Mortgage Loanand ExchangeRight Net Leased Portfolio 26 Mortgage Loan are each an asset ofthe issuing entity and are each part of a loan combination that includes (a)with respect to the GNL Industrial Portfolio Mortgage Loan, one other *paripassu* loan, which is not an asset of the issuing entity or (b) with respectto the ExchangeRight Net Leased Portfolio 26 Mortgage Loan, two other *paripassu* loans, which are not assets of the issuing entity. These loancombinations, including the GNL Industrial Portfolio Mortgage Loan and theExchangeRight Net Leased Portfolio 26 Mortgage Loan, were serviced under thePooling and Servicing Agreement for the issuing entity prior to the closing ofthe securitization of a *pari passu* portion of the GNL IndustrialPortfolio  loan combination and the ExchangeRight Net Leased Portfolio 26loan combination in the CSAIL 2019-C16 Commercial Mortgage Trust transaction,Commission File Number 333-227081-02 (the “CSAIL 2019-C16 Transaction”). After the closing of the CSAIL 2019-C16 Transaction on June 27, 2019, theseloan combinations, including the GNL Industrial Portfolio Mortgage Loan and theExchangeRight Net Leased Portfolio 26 Mortgage Loan were, and will continue tobe, serviced and administered pursuant to the pooling and servicing agreementwith respect to the CSAIL 2019-C16 Transaction, which is incorporated byreference as Exhibit 4.9 to this Annual Report on Form 10-K.

The master servicer of a poolingand servicing agreement or trust and servicing agreement also functions as theprimary servicer of the related mortgage loans serviced and administeredpursuant to such agreement unless a separate primary servicer is identifiedherein.  If this report does not identify a separate primary servicer, theservicer compliance statement provided by the master servicer under any suchagreement also encompasses its responsibilities as primary servicer of therelated mortgage loan or mortgage loans.

Midland Loan Services, a Divisionof PNC Bank, National Association is the master servicer and special servicerof the mortgage loans serviced under the Pooling and Servicing Agreement, theprimary servicer of the GNL Industrial Portfolio Mortgage Loan, theExchangeRight Net Leased Portfolio 26 Mortgage Loan, the Heartland DentalMedical Office Portfolio Mortgage Loan, the ILPT Hawaii Portfolio Mortgage Loanand the ExchangeRight Net Leased Portfolio 24 Mortgage Loan and the primaryservicer and special servicer of The Colonnade Office Complex Mortgage Loan andthe Southern Motion Industrial Portfolio Mortgage Loan. As a result, MidlandLoan Services, a Division of PNC Bank, National Association is a “servicer” asdefined in Item 1108(a)(2)(iii) of Regulation AB, in the capacities described above,because it is servicing mortgage loans that constituted 10% or more of theassets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria, accountants’ attestation reportsand servicer compliance statements delivered by Midland Loan Services, aDivision of PNC Bank, National Association in the capacities described aboveare listed in the Exhibit Index.

Wells Fargo Bank, NationalAssociation is the certificate administrator of the mortgage loans servicedunder the Pooling and Servicing Agreement, the primary servicer and specialservicer of the Christiana Mall Mortgage Loan and the primary servicer of the787 Eleventh Avenue Mortgage Loan and the Goodyear Portfolio Mortgage Loan. Asa result, Wells Fargo Bank, National Association is a “servicer” as defined inItem 1108(a)(2)(iii) of Regulation AB, in the capacities described above,because it is servicing mortgage loans that constituted 10% or more of theassets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria, accountants’ attestation reportsand servicer compliance statements delivered by Wells Fargo Bank, NationalAssociation in the capacities described above are listed in the Exhibit Index.

Wells Fargo Bank, National Association is the custodian ofthe mortgage loans serviced under the Pooling and Servicing Agreement, the GNLIndustrial Portfolio Mortgage Loan, the NEMA San Francisco Mortgage Loan, TheColonnade Office Complex Mortgage Loan, the 787 Eleventh Avenue Mortgage Loan,the ExchangeRight Net Leased Portfolio 26 Mortgage Loan, the Goodyear PortfolioMortgage Loan, the ExchangeRight Net Leased Portfolio 24 Mortgage Loan, theHeartland Dental Medical Office Portfolio Mortgage Loan, the Southern MotionIndustrial Portfolio Mortgage Loan, the ILPT Hawaii Portfolio Mortgage Loan andthe Christiana Mall Mortgage Loan.  As a result, Wells Fargo Bank,National Association is a servicing function participant in the capacitiesdescribed above, because it is servicing mortgage loans that constituted 5% ormore of the assets of the issuing entity as of its cut-off date. Theassessments of compliance with applicable servicing criteria and accountants’attestation reports delivered by Wells Fargo Bank, National Association in thecapacities described above are listed in the Exhibit Index.

Pentalpha Surveillance LLC is the operating advisor of themortgage loans serviced under the Pooling and Servicing Agreement, the GNLIndustrial Portfolio Mortgage Loan and the ExchangeRight Net Leased Portfolio26 Mortgage Loan.  As a result, Pentalpha Surveillance LLC is a servicingfunction participant in the capacities described above, because it is servicingmortgage loans that constituted 5% or more of the assets of the issuing entityas of its cut-off date. The assessments of compliance with applicable servicingcriteria and accountants’ attestation reports delivered by PentalphaSurveillance LLC in the capacities described above are listed in the Exhibit Index.

KeyBank National Association isthe primary servicer of the NEMA San Francisco Mortgage Loan and of six of themortgage loans serviced under the Pooling and Servicing Agreement, includingthe SSTII Self Storage Portfolio II Mortgage Loan. As a result, KeyBankNational Association is a “servicer” as defined in Item 1108(a)(2)(iii) ofRegulation AB, in the capacity described above, because it is servicingmortgage loans that constituted 10% or more of the assets of the issuing entityas of its cut-off date. The assessments of compliance with applicable servicingcriteria, accountants’ attestation reports and servicer compliance statementsdelivered by KeyBank National Association in the capacity described above arelisted in the Exhibit Index.

Park Bridge Lender Services LLC is the operating advisor ofThe Colonnade Office Complex Mortgage Loan, the Goodyear Portfolio MortgageLoan, the ExchangeRight Net Leased Portfolio 24 Mortgage Loan, the HeartlandDental Medical Office Portfolio Mortgage Loan, the Southern Motion IndustrialPortfolio Mortgage Loan and the ILPT Hawaii Portfolio Mortgage Loan.  As aresult, Park Bridge Lender Services LLC is a servicing function participant inthe capacities described above, because it is servicing mortgage loans that constituted5% or more of the assets of the issuing entity as of its cut-off date. Theassessments of compliance with applicable servicing criteria and accountants’attestation reports delivered by Park Bridge Lender Services LLC in thecapacities described above are listed in the Exhibit Index.

LNR Partners, LLC is the specialservicer of the ExchangeRight Net Leased Portfolio 26 Mortgage Loan and the GNLIndustrial Portfolio Mortgage Loan.  These mortgage loans constitute morethan 5%, but less than 10%, of the pool assets of the issuing entity. Therefore, the Depositor included in this Annual Report on Form 10-K anassessment of compliance with applicable servicing criteria for LNR Partners,LLC and an accountants’ attestation report pursuant to Item 1122 of RegulationAB because LNR Partners, LLC is servicing more than 5% of the poolassets.  However, the Depositor is not required to include in this AnnualReport on Form 10-K a servicer compliance statement pursuant to Item 1123 ofRegulation AB of LNR Partners, LLC because LNR Partners, LLC is an unaffiliatedservicer servicing less than 10% of pool assets.

Situs Holdings, LLC is the specialservicer of the NEMA San Francisco Mortgage Loan and the 787 Eleventh AvenueMortgage Loan on and after March 30, 2021.  These mortgage loansconstitute more than 5%, but less than 10%, of the pool assets of the issuingentity.  Therefore, the Depositor included in this Annual Report on Form10-K an assessment of compliance with applicable servicing criteria for Situs Holdings,LLC and an accountants’ attestation report pursuant to Item 1122 of RegulationAB because Situs Holdings, LLC is servicing more than 5% of the poolassets.  However, the Depositor is not required to include in this AnnualReport on Form 10-K a servicer compliance statement pursuant to Item 1123 ofRegulation AB of Situs Holdings, LLC because Situs Holdings, LLC is anunaffiliated servicer servicing less than 10% of pool assets.

Wells Fargo Bank, NationalAssociation acts as trustee of the SSTII Self Storage Portfolio II MortgageLoan, the Vanguard Portfolio Mortgage Loan, the SWVP Portfolio Mortgage Loan,the Inland Devon Self Storage Portfolio Mortgage Loan, the Wolverine PortfolioMortgage Loan, the Kings Mountain Center Mortgage Loan, the Patuxent CrossingMortgage Loan, The Block Northway Mortgage Loan, the ExchangeRight Net LeasedPortfolio 24 Mortgage Loan, the ILPT Hawaii Portfolio Mortgage Loan, the NEMASan Francisco Mortgage Loan, The Colonnade Office Complex Mortgage Loan, theSouthern Motion Industrial Portfolio Mortgage Loan, the GNL IndustrialPortfolio Mortgage Loan and the ExchangeRight Net Leased Portfolio 26 MortgageLoan.  Pursuant to the Pooling and Servicing Agreement, the pooling andservicing agreement for the CSAIL 2019-C15 Transaction, the trust and servicingagreement for the ILPT 2019-SURF Transaction, the trust and servicing agreementfor the NCMS 2019-NEMA Transaction, the pooling and servicing agreement for theUBS 2019-C16 Transaction and the pooling and servicing agreement for the CSAIL2019-C16 Transaction, the trustee is required to provide an assessment ofcompliance with applicable servicing criteria solely with respect to Item1122(d)(2)(iii) of Regulation AB (regarding advances of funds or guaranteesregarding collections, cash flows or distributions, and any interest or otherfees charged for such advances, are made, reviewed and approved as specified inthe transaction agreements). However, during the reporting period, the trusteedid not perform any servicing function with respect to the servicing criteriaspecified in Item 1122(d)(2)(iii) of Regulation AB.  The master serviceror the special servicer, to the extent required, performed the servicingfunction identified with respect to Item 1122(d)(2)(iii) of Regulation AB, andeach such party included Item 1122(d)(2)(iii) of Regulation AB in theassessment of compliance with applicable servicing criteria and accountant’sattestation report for the subject transaction.  As a result, this AnnualReport on Form 10-K does not include an assessment of compliance withapplicable servicing criteria of the trustee. One or more other servicers ofthe SSTII Self Storage Portfolio II Mortgage Loan, the Vanguard PortfolioMortgage Loan, the SWVP Portfolio Mortgage Loan, the Inland Devon Self StoragePortfolio Mortgage Loan, the Wolverine Portfolio Mortgage Loan, the KingsMountain Center Mortgage Loan, the Patuxent Crossing Mortgage Loan, The BlockNorthway Mortgage Loan, the ExchangeRight Net Leased Portfolio 24 Mortgage Loan,the ILPT Hawaii Portfolio Mortgage Loan, the NEMA San Francisco Mortgage Loan,The Colonnade Office Complex Mortgage Loan, the Southern Motion IndustrialPortfolio Mortgage Loan, the GNL Industrial Portfolio Mortgage Loan and theExchangeRight Net Leased Portfolio 26 Mortgage Loan have delivered one or moreassessments of compliance with respect to Item 1122(d)(2)(iii) of RegulationAB.

Wilmington Trust, NationalAssociation acts as trustee of the Christiana Mall Mortgage Loan, the 787Eleventh Avenue Mortgage Loan, the Goodyear Portfolio Mortgage Loan and theHeartland Dental Medical Office Portfolio Mortgage Loan.  Pursuant to thetrust and servicing agreement for the BBCMS 2018-CHRS Transaction, the trustand servicing agreement for the SGCMS 2019-787E Transaction and the pooling andservicing agreement for the WFCM 2019-C50 Transaction, the trustee is requiredto provide an assessment of compliance with applicable servicing criteriasolely with respect to Item 1122(d)(2)(iii) of Regulation AB (regarding advancesof funds or guarantees regarding collections, cash flows or distributions, andany interest or other fees charged for such advances, are made, reviewed andapproved as specified in the transaction agreements). However, during thereporting period, the trustee did not perform any servicing function withrespect to the servicing criteria specified in Item 1122(d)(2)(iii) ofRegulation AB.  The master servicer or the special servicer, to the extentrequired, performed the servicing function identified with respect to Item1122(d)(2)(iii) of Regulation AB, and each such party included Item1122(d)(2)(iii) of Regulation AB in the assessment of compliance withapplicable servicing criteria and accountant’s attestation report for thesubject transaction.  As a result, this Annual Report on Form 10-K doesnot include an assessment of compliance with applicable servicing criteria ofthe trustee. One or more other servicers of the Christiana Mall Mortgage Loan,the 787 Eleventh Avenue Mortgage Loan, the Goodyear Portfolio Mortgage Loan andthe Heartland Dental Medical Office Portfolio Mortgage Loan have delivered oneor more assessments of compliance with respect to Item 1122(d)(2)(iii) ofRegulation AB.

This Annual Report on Form 10-Kincludes assessments of compliance with applicable servicing criteria andaccountants’ attestation reports from CoreLogic Solutions, LLC  Thisentity was engaged by the primary servicer of the 787 Eleventh Avenue MortgageLoan, the Goodyear Portfolio Mortgage Loan and the Christiana Mall MortgageLoan to remit tax payments received from the escrow accounts of borrowers tolocal taxing authorities, to report tax amounts due, to verify tax parcelinformation, and to verify non-escrow tax payments. These servicing functionsare included within the servicing criteria set forth in Items 1122(d)(4)(xi)and 1122(d)(4)(xii) of Regulation AB.  Therefore, under theprinciples-based definition of “servicer” set forth in Item 1101(j) ofRegulation AB that looks to the functions that an entity performs, this vendoris a “servicer” for the purposes of Item 1122 of Regulation AB.  *See*Compliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

This Annual Report on Form 10-Kincludes an assessment of compliance with applicable servicing criteria,accountants’ attestation report and servicer compliance statement fromComputershare Trust Company, National Association (“CTCNA”).  CTCNAwas engaged by Wells Fargo Bank, National Association (“Wells Fargo”),in its capacity as certificate administrator and custodian, to perform certainspecified servicing functions identified in the assessment of compliance withapplicable servicing criteria and accountants’ attestation reports.  WellsFargo engaged CTCNA in connection with the sale of Wells Fargo’s corporatetrust services business to CTCNA and its affiliates.  Further, under theprinciples-based definition of “servicer” set forth in Item 1101(j) ofRegulation AB that looks to the functions that an entity performs, this partyis a “servicer” for the purposes of Item 1123 of Regulation AB.  SeeCompliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

Theassessments of compliance with applicable servicing criteria, accountants’attestation reports and servicer compliance statements of the certificateadministrator of the Christiana Mall Mortgage Loan, the 787 Eleventh AvenueMortgage Loan, the ExchangeRight Net Leased Portfolio 24 Mortgage Loan, theILPT Hawaii Portfolio Mortgage Loan, the NEMA San Francisco Mortgage Loan, The ColonnadeOffice Complex Mortgage Loan, the Southern Motion Industrial Portfolio MortgageLoan, the Goodyear Portfolio Mortgage Loan, the Heartland Dental Medical OfficePortfolio Mortgage Loan, the GNL Industrial Portfolio Mortgage Loan and theExchangeRight Net Leased Portfolio 26 Mortgage Loan are omitted from thisAnnual Report on Form 10-K as the certificate administrator pursuant to therelated pooling and servicing agreement or trust and servicing agreement doesnot perform any activities that address servicing criteria with respect to theissuing entity and because they are each not a “servicer” that meets thecriteria in Item 1108(a)(2)(i) through (iii) of Regulation AB.

With respect to the pari passuloan combinations that include the 787 Eleventh Avenue Mortgage Loan, the ILPTHawaii Portfolio Mortgage Loan, the Goodyear Portfolio Mortgage Loan, theHeartland Dental Medical Office Portfolio Mortgage Loan, the NEMA San FranciscoMortgage Loan, the GNL Industrial Portfolio Mortgage Loan, the ExchangeRightNet Leased Portfolio 26 Mortgage Loan and the ExchangeRight Net LeasedPortfolio 24 Mortgage Loan, (i) the reports on assessment of compliance withservicing criteria and attestation reports on assessment of compliance withservicing criteria of AEGON USA Realty Advisors, LLC as special servicer of the787 Eleventh Avenue Mortgage Loan prior to March 30, 2021, 3650 REIT LoanServicing LLC as special servicer of the ExchangeRight Net Leased Portfolio 24Mortgage Loan, and Rialto Capital Advisors, LLC as special servicer of the ILPTHawaii Portfolio Mortgage Loan, the Goodyear Portfolio Mortgage Loan and theHeartland Dental Medical Office Portfolio Mortgage Loan, listed on the ExhibitIndex are omitted from this Annual Report on Form 10-K as they are not requiredto be included on this Annual Report on Form 10-K per Instruction 3 to Item1122 of Regulation AB because they are parties performing activities thataddress servicing criteria relating to 5% or less of the assets of the issuingentity; and (ii) the servicer compliance statements of AEGON USA RealtyAdvisors, LLC as special servicer of the 787 Eleventh Avenue Mortgage Loanprior to March 30, 2021, 3650 REIT Loan Servicing LLC as special servicer ofthe ExchangeRight Net Leased Portfolio 24 Mortgage Loan, Rialto CapitalAdvisors, LLC as special servicer of the ILPT Hawaii Portfolio Mortgage Loan,the Goodyear Portfolio Mortgage Loan and the Heartland Dental Medical OfficePortfolio Mortgage Loan, Situs Holdings, LLC as special servicer of the NEMA SanFrancisco Mortgage Loan and the 787 Eleventh Avenue Mortgage Loan on and afterMarch 30, 2021 and LNR Partners, LLC as special servicer of the GNL IndustrialPortfolio Mortgage Loan and the ExchangeRight Net Leased Portfolio 26 MortgageLoan, listed on the Exhibit Index are omitted from this Annual Report on Form10-K as they are not required by Item 1123 of Regulation AB to be included onthis Annual Report on Form 10-K because they are each an unaffiliated partythat is not a “servicer” that meets the criteria in Item 1108(a)(2)(i) through(iii) of Regulation AB.

**PART I**

**Item 1.  Business.**

Omitted.

**Item 1A.  Risk Factors.**

Omitted.

**Item 1B.  Unresolved Staff Comments.**

None.

**Item 2.  Properties.**

Omitted.

**Item 3.  Legal Proceedings.**

Omitted.

**Item 4.  Mine Safety Disclosures.**

Not applicable.

**PART II**

**Item 5.  Market for Registrant’s Common Equity,Related Stockholder Matters and Issuer Purchases of Equity Securities.**

Omitted.

**Item 6.  Selected Financial Data.**

Omitted.

**Item 7.  Management’s Discussion and Analysis ofFinancial Condition and Results of Operations.**

Omitted.

**Item 7A.  Quantitative and Qualitative DisclosuresAbout Market Risk.**

Omitted.

**Item 8.  Financial Statements and Supplementary Data.**

Omitted.

**Item 9.  Changes in and Disagreements With Accountantson Accounting and Financial Disclosure.**

Omitted.

**Item 9A.  Controls and Procedures.**

Omitted.

**Item 9B.  Other Information.**

None.

**PART III**

**Item 10.  Directors, Executive Officers and CorporateGovernance.**

Omitted.

**Item 11.  Executive Compensation.**

Omitted.

**Item 12.  Security Ownership of Certain BeneficialOwners and Management and Related Stockholder Matters.**

Omitted.

**Item 13.  Certain Relationships and RelatedTransactions, and Director Independence.**

Omitted.

**Item 14.  Principal Accounting Fees and Services.**

Omitted.

**ADDITIONAL DISCLOSURE ITEMS FOR REGULATION AB**

**Item 1112(b) of Regulation AB, Significant ObligorFinancial Information.**

No single obligor represents 10% or more of the pool assetsheld by the issuing entity. 

 

**Item 1114(b)(2) of Regulation AB, Significant EnhancementProvider Financial Information.**

No entity or group of affiliated entities provides any externalcreditenhancement or other support for the certificates within this transaction asdescribed under Item 1114(a) of Regulation AB.

**Item 1115(b) of Regulation AB, Certain DerivativesInstruments (Financial Information).**

No entity or group of affiliated entities provides anyderivative instruments or other support for the certificates within thistransaction as described under Item 1115 of Regulation AB.

**Item 1117 of Regulation AB, Legal Proceedings.**

The registrant knows of no material pending legal proceedinginvolving the trust or any party related to the trust, other than routinelitigation incidental to the duties of those respective parties, and thefollowing, with respect to Wells Fargo Bank, National Association, as trustee,as certificate administrator and as custodian.

 

In December 2014, Phoenix LightSF Limited and certain related entities and the National Credit Union Administration(NCUA) filed complaints in the United States District Court for the SouthernDistrict of New York against Wells Fargo Bank, alleging claims against WellsFargo Bank in its capacity as trustee for a number of residentialmortgage-backed securities trusts. Complaints raising similar allegations havebeen filed by Commerzbank AG in the Southern District of New York and by IKBInternational and IKB Deutsche Industriebank in New York state court. In eachcase, the plaintiffs allege that Wells Fargo Bank, as trustee, caused losses toinvestors, and plaintiffs assert causes of action based upon, among otherthings, the trustee’s alleged failure to notify and enforce repurchaseobligations of mortgage loan sellers for purported breaches of representationsand warranties, notify investors of alleged events of default, and abide byappropriate standards of care following alleged events of default. Wells FargoBank previously settled two class action lawsuits with similar allegations thatwere filed in November 2014 and December 2016 by institutional investors in theSouthern District of New York and New York state court, respectively. Inaddition, Park Royal I LLC and Park Royal II LLC have filed complaints in NewYork state court alleging Wells Fargo Bank, N.A., as trustee, failed to takeappropriate actions upon learning of defective mortgage loan documentation. InMarch 2021, the Company entered into an agreement to resolve the case filed bythe NCUA.

 

In addition to the foregoingcases, in August 2014 and August 2015 Nomura Credit & Capital Inc. (“Nomura”)and Natixis Real Estate Holdings, LLC (“Natixis”) filed a total of seventhird-party complaints against Wells Fargo Bank in New York state court. In theunderlying first-party actions, Nomura and Natixis have been sued for allegedbreaches of representations and warranties made in connection with residentialmortgage-backed securities sponsored by them. In the third-party actions,Nomura and Natixis allege that Wells Fargo Bank, as master servicer, primaryservicer or securities administrator, failed to notify Nomura and Natixis oftheir own breaches, failed to properly oversee the primary servicers, andfailed to adhere to accepted servicing practices. Natixis additionally allegesthat Wells Fargo Bank failed to perform default oversight duties. Wells FargoBank has asserted counterclaims alleging that Nomura and Natixis failed toprovide Wells Fargo Bank notice of their representation and warrantybreaches. 

With respect to each of the foregoing litigations, WellsFargo Bank believes plaintiffs' claims are without merit and intends to contestthe claims vigorously, but there can be no assurances as to the outcome of thelitigations or the possible impact of the litigations on Wells Fargo Bank orthe related RMBS trusts.

**Item 1119 of Regulation AB, Affiliations and CertainRelationships and Related Transactions.**

The information regarding this Item has been previouslyprovided in the prospectus of the Registrant relating to the issuing entityfiled on June 11, 2019 pursuant to Rule 424(b)(2).

**Item 1122 of Regulation AB, Compliance with ApplicableServicing Criteria.**

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the mortgage loans are attachedhereto under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit AAto the Pooling and Servicing Agreement incorporated by reference as Exhibit 4.1to this Annual Report on Form 10-K is a chart identifying the entitiesparticipating in a servicing function for the transaction responsible for eachapplicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicing criteriafor asset-backed securities and related attestation reports on such assessmentsof compliance with respect to the Christiana Mall Mortgage Loan, which is beingserviced and administered pursuant to the trust and servicing agreement for theBBCMS 2018-CHRS Transaction, are attached hereto under Item 15 to this AnnualReport on Form 10-K. Attached as Exhibit L  to the trust and servicingagreement for the BBCMS 2018-CHRS Transaction incorporated by reference asExhibit 4.2 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the BBCMS 2018-CHRSTransaction responsible for each applicable servicing criteria set forth inItem 1122(d).

The reports on assessments of compliance with the servicing criteriafor asset-backed securities and related attestation reports on such assessmentsof compliance with respect to the 787 Eleventh Avenue Mortgage Loan, which isbeing serviced and administered pursuant to the trust and servicing agreementfor the SGCMS 2019-787E Transaction, are attached hereto under Item 15 to thisAnnual Report on Form 10-K. Attached as Exhibit L  to the trust andservicing agreement for the SGCMS 2019-787E Transaction incorporated byreference as Exhibit 4.3 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the SGCMS2019-787E Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the ExchangeRight Net LeasedPortfolio 24 Mortgage Loan, which is being serviced and administered pursuantto the pooling and servicing agreement for the CSAIL 2019-C15 Transaction, areattached hereto under Item 15 to this Annual Report on Form 10-K. Attached asExhibit AA  to the pooling and servicing agreement for the CSAIL 2019-C15Transaction incorporated by reference as Exhibit 4.4 to this Annual Report onForm 10-K is a chart identifying the entities participating in a servicingfunction for the CSAIL 2019-C15 Transaction responsible for each applicableservicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the ILPT Hawaii Portfolio MortgageLoan, which is being serviced and administered pursuant to the trust and servicingagreement for the ILPT 2019-SURF Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit L to the trust andservicing agreement for the ILPT 2019-SURF Transaction incorporated byreference as Exhibit 4.5 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the ILPT2019-SURF Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the NEMA San Francisco Mortgage Loan,which is being serviced and administered pursuant to the trust and servicingagreement for the NCMS 2019-NEMA Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit K to the trust andservicing agreement for the NCMS 2019-NEMA Transaction incorporated byreference as Exhibit 4.6 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the NCMS2019-NEMA Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to The Colonnade Office Complex MortgageLoan and the Southern Motion Industrial Portfolio Mortgage Loan, which arebeing serviced and administered pursuant to the pooling and servicing agreementfor the UBS 2019-C16 Transaction, are attached hereto under Item 15 to thisAnnual Report on Form 10-K. Attached as Exhibit Z to the pooling and servicingagreement for the UBS 2019-C16 Transaction incorporated by reference as Exhibit4.7 to this Annual Report on Form 10-K is a chart identifying the entitiesparticipating in a servicing function for the UBS 2019-C16 Transactionresponsible for each applicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Goodyear Portfolio Mortgage Loanand the Heartland Dental Medical Office Portfolio Mortgage Loan, which arebeing serviced and administered pursuant to the pooling and servicing agreementfor the WFCM 2019-C50 Transaction, are attached hereto under Item 15 to thisAnnual Report on Form 10-K. Attached as Exhibit AA to the pooling and servicingagreement for the WFCM 2019-C50 Transaction incorporated by reference asExhibit 4.8 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the WFCM 2019-C50Transaction responsible for each applicable servicing criteria set forth inItem 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the GNL Industrial Portfolio MortgageLoan and the ExchangeRight Net Leased Portfolio 26 Mortgage Loan, which arebeing serviced and administered pursuant to the pooling and servicing agreementfor the CSAIL 2019-C16 Transaction, are attached hereto under Item 15 to thisAnnual Report on Form 10-K. Attached as Exhibit AA  to the pooling andservicing agreement for the CSAIL 2019-C16 Transaction incorporated byreference as Exhibit 4.9 to this Annual Report on Form 10-K is a chart identifyingthe entities participating in a servicing function for the CSAIL 2019-C16Transaction responsible for each applicable servicing criteria set forth inItem 1122(d).

The report on assessment of compliance for the twelve monthsended December 31, 2021, furnished pursuant to Item 1122 of Regulation AB byAegon USA Realty Advisors, LLC (“Aegon” or the “Company”), as special servicer,discloses that the following material instance of noncompliance occurred withrespect to its platform:

The examination performed by PWC identified an instance ofmaterial noncompliance with the servicing criteria set forth in Item1122(d)(3)(i)(A) of Regulation AB applicable to the Company during year endedDecember 31, 2021. More specifically, for the only active special serviced dealsubject to Item 1122(d)(3)(i)(A), the report to the investors was not preparedin accordance with the timeframes and other terms set forth in the transactionagreements for the period of January 1, 2021 to January 21, 2021. UBSCM 2017-C4is the specific deal related to the aforementioned finding. No other dealswithin Aegon’s CMBS special servicing portfolio were related to or impacted bythis instance of non-compliance.

Management acknowledges the timeframe for reporting for thisactive special serviced deal was missed by two days. Despite the timingdiscrepancy, there was no impact on any investor reporting, issuing, orservicing. No additional testing was available for this particular criteria dueto the downsizing of the CMBS portfolio given Aegon’s pending exit from thebusiness line.

**Item 1123 of Regulation AB, Servicer Compliance Statement.**

The servicer compliance statements are attached as Exhibitsto this Annual Report on Form 10-K.

The servicer compliance statement for the twelve months endedDecember 31, 2021, furnished pursuant to Item 1123 of Regulation AB by AegonUSA Realty Advisors, LLC (“Aegon” or the “Company”), as special servicer,discloses that the following material instance of noncompliance occurred withrespect to its platform:

The examination performed by PWC identified an instance ofmaterial noncompliance with the servicing criteria set forth in Item1122(d)(3)(i)(A) of Regulation AB applicable to the Company during year endedDecember 31, 2021. More specifically, for the only active special serviced dealsubject to Item 1122(d)(3)(i)(A), the report to the investors was not preparedin accordance with the timeframes and other terms set forth in the transactionagreements for the period of January 1, 2021 to January 21, 2021. UBSCM 2017-C4is the specific deal related to the aforementioned finding. No other dealswithin Aegon’s CMBS special servicing portfolio were related to or impacted bythis instance of non-compliance.

Management acknowledges the timeframe for reporting for thisactive special serviced deal was missed by two days. Despite the timingdiscrepancy, there was no impact on any investor reporting, issuing, orservicing. No additional testing was available for this particular criteria dueto the downsizing of the CMBS portfolio given Aegon’s pending exit from thebusiness line.

 

**PART IV**

**Item 15. Exhibits, Financial Statement Schedules**

(a) The following is a list of documents filed as part ofthis Annual Report on Form 10-K:

(1) Not applicable

(2) Not applicable

(3) See below

4.1          Poolingand Servicing Agreement, dated as of June 1, 2019, by and among Barclays CommercialMortgage Securities LLC, as Depositor, Midland Loan Services, a Division of PNCBank, National Association, as Master Servicer, Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer, Wells FargoBank, National Association, as Certificate Administrator, Wells Fargo Bank,National Association, as Trustee, and Pentalpha Surveillance LLC, as OperatingAdvisor and as Asset Representations Reviewer (filed as Exhibit 4.1 to theregistrant’s Current Report on Form 8-K filed on June 11, 2019 under CommissionFile No. 333-226850-02 and incorporated by reference herein).

4.2          Trustand Servicing Agreement, dated as of August 9, 2018, by and among BarclaysCommercial Mortgage Securities LLC, as Depositor, Wells Fargo Bank, NationalAssociation, as Servicer and Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator and Custodian, and Wilmington Trust,National Association, as Trustee (filed as Exhibit 4.8 to the registrant’sCurrent Report on Form 8-K filed on June 11, 2019 under Commission File No.333-226850-02 and incorporated by reference herein).

4.3          Trustand Servicing Agreement, dated as of February 20, 2019, by and among SGCommercial Mortgage Securities, LLC, as Depositor, Wells Fargo Bank, NationalAssociation, as Servicer, AEGON USA Realty Advisors, LLC, as Special Servicer,Wells Fargo Bank, National Association, as Certificate Administrator, andWilmington Trust, National Association, as Trustee (filed as Exhibit 4.3 to theregistrant’s Current Report on Form 8-K filed on June 11, 2019 under CommissionFile No. 333-226850-02 and incorporated by reference herein).

4.4          Poolingand Servicing Agreement, dated as of March 1, 2019, by and among Credit SuisseCommercial Mortgage Securities Corp., as Depositor, Midland Loan Services, aDivision of PNC Bank, National Association, as Master Servicer and as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administratorand as Trustee, and Park Bridge Lender Services LLC, as Operating Advisor andas Asset Representations Reviewer (filed as Exhibit 4.6 to the registrant’sCurrent Report on Form 8-K filed on June 11, 2019 under Commission File No. 333-226850-02and incorporated by reference herein).

4.5          Trustand Servicing Agreement, dated as of March 7, 2019, by and among Morgan StanleyCapital I Inc., as Depositor, Midland Loan Services, a Division of PNC Bank,National Association, as Servicer, Rialto Capital Advisors, LLC, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administrator,Custodian and Trustee, and Park Bridge Lender Services LLC, as OperatingAdvisor (filed as Exhibit 4.7 to the registrant’s Current Report on Form 8-Kfiled on June 11, 2019 under Commission File No. 333-226850-02 and incorporatedby reference herein).

4.6          Trustand Servicing Agreement, dated as of March 29, 2019, by and among Natixis CommercialMortgage Securities LLC, as Depositor, KeyBank National Association, asServicer, Situs Holdings, LLC, as Special Servicer, and Wells Fargo Bank,National Association, as Trustee, Certificate Administrator and Custodian(filed as Exhibit 4.2 to the registrant’s Current Report on Form 8-K filed onJune 11, 2019 under Commission File No. 333-226850-02 and incorporated byreference herein).

4.7          Poolingand Servicing Agreement, dated as of April 1, 2019, by and among UBS CommercialMortgage Securitization Corp., as Depositor, Midland Loan Services, a Divisionof PNC Bank, National Association, as Master Servicer and as Special Servicer,Wells Fargo Bank, National Association, as Certificate Administrator and asTrustee, and Park Bridge Lender Services LLC, as Operating Advisor and as AssetRepresentations Reviewer (filed as Exhibit 4.4 to the registrant’s CurrentReport on Form 8-K filed on June 11, 2019 under Commission File No.333-226850-02 and incorporated by reference herein).

4.8          Poolingand Servicing Agreement, dated as of May 1, 2019, by and among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, Rialto Capital Advisors, LLC, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Park Bridge LenderServices LLC, as Operating Advisor and as Asset Representations Reviewer (filedas Exhibit 4.5 to the registrant’s Current Report on Form 8-K filed on June 11,2019 under Commission File No. 333-226850-02 and incorporated by referenceherein).

4.9          Poolingand Servicing Agreement, dated as of June 1, 2019, by and among Credit SuisseCommercial Mortgage Securities Corp., as Depositor, Midland Loan Services, aDivision of PNC Bank, National Association, as Master Servicer, LNR Partners,LLC, as Special Servicer, Wells Fargo Bank, National Association, asCertificate Administrator and as Trustee, and Pentalpha Surveillance LLC, asOperating Advisor and as Asset Representations Reviewer (filed as Exhibit 4.1to the registrant’s Current Report on Form 8-K filed on June 28, 2019 underCommission File No. 333-226850-02 and incorporated by reference herein).

4.10        AgreementBetween Noteholders, dated as of March 14, 2019, by and among KeyBank NationalAssociation, as Initial Note A-1 Holder, and KeyBank National Association, asInitial Note A-2 Holder, Initial Note A-3 Holder and Initial Note A-4 Holder(filed as Exhibit 4.9 to the registrant’s Current Report on Form 8-K filed onJune 11, 2019 under Commission File No. 333-226850-02 and incorporated byreference herein).

4.11        Amendedand Restated Co-Lender Agreement, dated as of June 11, 2019, by and amongNatixis Real Estate Capital LLC, as Note A-1 Holder, Natixis Real EstateCapital LLC, as Note A-2 Holder, Natixis Real Estate Capital LLC, as Note A-3Holder, Natixis Real Estate Capital LLC, as Note A-4 Holder, Natixis RealEstate Capital LLC, as Note A-5 Holder, Natixis Real Estate Capital LLC, asNote A-6 Holder, and TCM CRE REIT LLC, as Note B Holder (filed as Exhibit 4.10to the registrant’s Current Report on Form 8-K filed on June 11, 2019 underCommission File No. 333-226850-02 and incorporated by reference herein).

4.12        AgreementBetween Noteholders, dated as of April 12, 2019, by and between ColumnFinancial, Inc., as Initial Note A-1 Holder, and Société Générale FinancialCorporation, as Initial Note A-2 Holder (filed as Exhibit 4.11 to theregistrant’s Current Report on Form 8-K filed on June 11, 2019 under CommissionFile No. 333-226850-02 and incorporated by reference herein).

4.13        Co-LenderAgreement, dated as of June 11, 2019, by and between Societe Generale FinancialCorporation and JPMorgan Chase Bank, National Association (filed as Exhibit4.12 to the registrant’s Current Report on Form 8-K filed on June 11, 2019under Commission File No. 333-226850-02 and incorporated by reference herein).

4.14        AgreementBetween Note Holders, dated as of April 24, 2019, by and between BarclaysCapital Real Estate Inc., as Initial Note A-1 Holder, and Barclays Capital RealEstate Inc., as Initial Note A-2 Holder (filed as Exhibit 4.13 to the registrant’sCurrent Report on Form 8-K filed on June 11, 2019 under Commission File No.333-226850-02 and incorporated by reference herein).

4.15        Co-LenderAgreement, dated as of March 27, 2019, by and among Natixis Real EstateCapital, as Note A-1 Holder, Natixis Real Estate Capital LLC, as Note A-2Holder, Natixis Real Estate Capital LLC, as Note A-3 Holder, Natixis RealEstate Capital LLC, as Note A-4 Holder, Natixis Real Estate Capital LLC, asNote A-5 Holder, Natixis Real Estate Capital LLC, as Note A-B Holder, NatixisReal Estate Capital LLC, as Note B-1 Holder, and Natixis Real Estate CapitalLLC, as Note B-2 Holder (filed as Exhibit 4.14 to the registrant’s CurrentReport on Form 8-K filed on June 11, 2019 under Commission File No.333-226850-02 and incorporated by reference herein).

4.16        AgreementBetween Noteholders, dated as of January 9, 2019, by and between, SocieteGenerale Financial Corporation, as Initial Note A-1A Holder, Societe GeneraleFinancial Corporation, as Initial Note A-1B Holder, Societe Generale FinancialCorporation, as Initial Note A-1C Holder, Societe Generale FinancialCorporation, as Initial Note A-1D Holder, Societe Generale FinancialCorporation, as Initial Note A-2 Holder, and Societe Generale FinancialCorporation, as Initial Note B Holder (filed as Exhibit 4.15 to theregistrant’s Current Report on Form 8-K filed on June 11, 2019 under CommissionFile No. 333-226850-02 and incorporated by reference herein).

4.17        Amendedand Restated Agreement Among Noteholders, dated as of March 25, 2019, by andamong UBS AG, by and through its branch office at 1285 Avenue of the Americas,New York, New York, as Note A-1 Holder, Note A-2-1 Holder, Note A-2-2 Holder,Note A-2-3 Holder, Note A-3 Holder, Note A-4 Holder, Note A-5 Holder, Note A-6Holder, Note A-7 Holder and Note A-8 Holder, The Lincoln National LifeInsurance Company, as Note B-1 Holder, Athene Annuity & Life AssuranceCompany, as Note B-2 Holder, Note B-5 Holder and Note B-6 Holder, AtheneAnnuity and Life Company, as Note B-3 Holder, American Equity Investment LifeInsurance Company, as Note B-4 Holder, and Nonghyup Bank as Trustee for UPGlobal Private Real Estate Fund V, as Note C Holder (filed as Exhibit 4.16 tothe registrant’s Current Report on Form 8-K filed on June 11, 2019 underCommission File No. 333-226850-02 and incorporated by reference herein).

4.18        AgreementBetween Note Holders, dated as of May 14, 2019, by and between UBS AG, by andthrough its branch office at 1285 Avenue of the Americas, New York, New York,as Initial Note A-1 Holder, Initial Note A-2 Holder, Initial Note A-3 Holder,Initial Note A-4 Holder, Initial Note A-5 Holder, Initial Note A-6 Holder,Initial Note A-7 Holder, Initial Note A-8 Holder, Initial Note A-9 Holder andInitial Note A-10 Holder (filed as Exhibit 4.17 to the registrant’s CurrentReport on Form 8-K filed on June 11, 2019 under Commission File No.333-226850-02 and incorporated by reference herein).

4.19        AgreementBetween Note Holders, dated as of June 11, 2019, by and among Societe GeneraleFinancial Corporation, as Initial Note A-1 Holder, Societe Generale FinancialCorporation, as Initial Note A-2 Holder, Societe Generale FinancialCorporation, as Initial Note A-3 Holder, and Societe Generale FinancialCorporation, as Initial Note A-4 Holder (filed as Exhibit 4.18 to theregistrant’s Current Report on Form 8-K filed on June 11, 2019 under CommissionFile No. 333-226850-02 and incorporated by reference herein).

4.20        AgreementBetween Note Holders, dated as of June 11, 2019, by and among Societe GeneraleFinancial Corporation, as Initial Note A-1 Holder, Societe Generale FinancialCorporation, as Initial Note A-2 Holder, and Societe Generale FinancialCorporation, as Initial Note A-3 Holder (filed as Exhibit 4.19 to theregistrant’s Current Report on Form 8-K filed on June 11, 2019 under CommissionFile No. 333-226850-02 and incorporated by reference herein).

4.21        AgreementBetween Note Holders, dated as of April 4, 2019, by and between Barclays CapitalReal Estate Inc., as Initial Note A-1 Holder, and Barclays Capital Real EstateInc., as Initial Note A-2 Holder (filed as Exhibit 4.20 to the registrant’sCurrent Report on Form 8-K filed on June 11, 2019 under Commission File No.333-226850-02 and incorporated by reference herein).

4.22        AgreementBetween Note Holders, dated as of March 14, 2019, by and between UBS AG, by andthrough its branch office at 1285 Avenue of the Americas, New York, New York,as Initial Note A-1 Holder, Initial Note A-3 Holder, Initial Note A-6 Holderand Initial Note A-7-1 Holder, and Morgan Stanley Mortgage Capital HoldingsLLC, as Initial Note A-2 Holder, Initial Note A-4 Holder, Initial Note A-5Holder, Initial Note A-7-2 Holder and Initial Note A-8 Holder (filed as Exhibit4.21 to the registrant’s Current Report on Form 8-K filed on June 11, 2019under Commission File No. 333-226850-02 and incorporated by reference herein).

4.23        AgreementBetween Noteholders, dated as of April 9, 2019, by and between Rialto MortgageFinance, LLC, as Note A-1 Holder, Rialto Mortgage Finance, LLC, as Note A-2Holder, Rialto Mortgage Finance, LLC, as Note A-3 Holder, Rialto MortgageFinance, LLC, as Note A-4 Holder, Rialto Mortgage Finance, LLC, as Note A-5Holder, and Townsend Real Estate Fund, L.P., as Note B Holder (filed as Exhibit4.22 to the registrant’s Current Report on Form 8-K filed on June 11, 2019under Commission File No. 333-226850-02 and incorporated by reference herein).

4.24        AgreementBetween Note Holders, dated as of December 28, 2018, by and among SociétéGénérale, as Initial Note A-1 Holder, Société Générale, as Initial Note A-2Holder, Société Générale, as Initial Note A-3 Holder, and Société Générale, asInitial Note A-4 Holder (filed as Exhibit 4.23 to the registrant’s CurrentReport on Form 8-K filed on June 11, 2019 under Commission File No.333-226850-02 and incorporated by reference herein).

4.25        Amendedand Restated Agreement Between Note Holders, dated as of May 14, 2019, by andbetween Wells Fargo Bank, National Association, as Trustee for the Benefit ofthe Restricted Holders of UBS Commercial Mortgage Trust 2018-C14 CommercialMortgage Pass-Through Certificates Series 2018-C14, as Note A-1 Holder and NoteA-10 Holder, UBS AG, by and through its branch office at 1285 Avenue of theAmericas, New York, New York, as Note A-2 Holder and Note A-9 Holder, DeutscheBank AG, New York Branch, as Note A-3 Holder, Wells Fargo Bank, NationalAssociation, as Trustee for the Benefit of the Registered Holders of UBSCommercial Mortgage Trust 2018-C15 Commercial Mortgage Pass-Through CertificatesSeries 2018-C15, as Note A-4 Holder, Note A-5 Holder and Note A-6 Holder, andWells Fargo Bank, National Association, as Trustee for the Benefit of theRegistered Holders of UBS Commercial Mortgage Trust 2019-C16 CommercialMortgage Pass-Through Certificates Series 2019-C16, as Note A-7 Holder and NoteA-8 Holder (filed as Exhibit 4.24 to the registrant’s Current Report on Form8-K filed on June 11, 2019 under Commission File No. 333-226850-02 andincorporated by reference herein).

4.26        AgreementBetween Note Holders, dated as of March 7, 2019, by and between Morgan StanleyBank, N.A., as Initial Note A-1 Holder, Initial Note A-5-1 Holder, Initial NoteA-5-2 Holder, Initial Note A-5-3 Holder and Initial Note A-5-4 Holder, CitiReal Estate Funding Inc., as Initial Note A-2 Holder, Initial Note A-6-1Holder, Initial Note A-6-2 Holder and Initial Note A-6-3 Holder, UBS AG, by andthrough its branch office at 1285 Avenue of the Americas, New York, New York,as Initial Note A-3 Holder, Initial Note A-7-1 Holder, Initial Note A-7-2Holder, Initial Note A-9 Holder, Initial Note A-10 Holder and Initial Note A-11Holder, and JPMorgan Chase Bank, National Association, as Initial Note A-4Holder, Initial Note A-8-1 Holder and Initial Note A-8-2 Holder (filed asExhibit 4.25 to the registrant’s Current Report on Form 8-K filed on June 11,2019 under Commission File No. 333-226850-02 and incorporated by referenceherein).

4.27        AgreementBetween Note Holders, dated as of April 16, 2019, by and between UBS AG, by andthrough its branch office at 1285 Avenue of the Americas, New York, New York,as Initial Note A-1 Holder, Initial Note A-2 Holder, Initial Note A-3 Holder,Initial Note A-4 Holder, Initial Note A-5 Holder and Initial Note A-6 Holder(filed as Exhibit 4.26 to the registrant’s Current Report on Form 8-K filed onJune 11, 2019 under Commission File No. 333-226850-02 and incorporated byreference herein).

4.28        Co-LenderAgreement, dated as of August 9, 2018, by and among Barclays Bank PLC, asInitial Note 1 Holder, Société Générale, as Initial Note 2 Holder, and DeutscheBank AG, New York Branch, as Initial Note 3 Holder (filed as Exhibit 4.27 tothe registrant’s Current Report on Form 8-K filed on June 11, 2019 underCommission File No. 333-226850-02 and incorporated by reference herein).

4.29        PrimaryServicing Agreement, dated as of June 1, 2019, between Midland Loan Services, aDivision of PNC Bank, National Association, as Master Servicer, and KeyBankNational Association, as Primary Servicer (filed as Exhibit 4.28 to theregistrant’s Current Report on Form 8-K filed on June 11, 2019 under CommissionFile No. 333-226850-02 and incorporated by reference herein).

31           Rule 13a-14(d)/15d-14(d) Certifications.

33           Reports on assessment of compliance with servicing criteria for asset-backedsecurities.

33.1        Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer

33.2        Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer (see Exhibit 33.1)

33.3        Wells Fargo Bank, National Association, as Trusteeand Certificate Administrator

33.4        Wells Fargo Bank, National Association, asCustodian

33.5        Pentalpha Surveillance LLC, as Operating Advisor

33.6        KeyBank National Association, as Primary Servicer            

33.7        Computershare Trust Company, National Association,as Servicing Function Participant for the Trustee and Certificate Administratoron and after November 1, 2021

33.8        Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021

33.9        KeyBank National Association, as Primary Servicerof the SSTII Self Storage Portfolio II Mortgage Loan (see Exhibit 33.6)

33.10      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the SSTII Self Storage PortfolioII Mortgage Loan (see Exhibit 33.1)

33.11      Wells Fargo Bank, National Association, as Trustee of the SSTII Self StoragePortfolio II Mortgage Loan (Omitted. See Explanatory Notes.)

33.12      Wells Fargo Bank, National Association, asCustodian of the SSTII Self Storage Portfolio II Mortgage Loan (see Exhibit33.4)

33.13      Pentalpha Surveillance LLC, as Operating Advisor ofthe SSTII Self Storage Portfolio II Mortgage Loan (see Exhibit 33.5)          

33.14      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

33.15      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Vanguard Portfolio MortgageLoan (see Exhibit 33.1)

33.16      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Vanguard Portfolio MortgageLoan (see Exhibit 33.1)

33.17      Wells Fargo Bank, National Association, as Trustee of the Vanguard PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.18      Wells Fargo Bank, National Association, asCustodian of the Vanguard Portfolio Mortgage Loan (see Exhibit 33.4)

33.19      Pentalpha Surveillance LLC, as Operating Advisor ofthe Vanguard Portfolio Mortgage Loan (see Exhibit 33.5)            

33.20      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

33.21      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the SWVP Portfolio Mortgage Loan(see Exhibit 33.1)

33.22      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the SWVP Portfolio Mortgage Loan(see Exhibit 33.1)

33.23      Wells Fargo Bank, National Association, as Trustee of the SWVP PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.24      Wells Fargo Bank, National Association, asCustodian of the SWVP Portfolio Mortgage Loan (see Exhibit 33.4)

33.25      Pentalpha Surveillance LLC, as Operating Advisor ofthe SWVP Portfolio Mortgage Loan (see Exhibit 33.5)  

33.26      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

33.27      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Inland Devon Self StoragePortfolio Mortgage Loan (see Exhibit 33.1)

33.28      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Inland Devon Self StoragePortfolio Mortgage Loan (see Exhibit 33.1)

33.29      Wells Fargo Bank, National Association, as Trustee of the Inland Devon SelfStorage Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.30      Wells Fargo Bank, National Association, asCustodian of the Inland Devon Self Storage Portfolio Mortgage Loan (see Exhibit33.4)

33.31      Pentalpha Surveillance LLC, as Operating Advisor ofthe Inland Devon Self Storage Portfolio Mortgage Loan (see Exhibit 33.5) 

33.32      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

33.33      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Wolverine Portfolio MortgageLoan (see Exhibit 33.1)

33.34      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Wolverine Portfolio MortgageLoan (see Exhibit 33.1)

33.35      Wells Fargo Bank, National Association, as Trustee of the Wolverine PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.36      Wells Fargo Bank, National Association, asCustodian of the Wolverine Portfolio Mortgage Loan (see Exhibit 33.4)

33.37      Pentalpha Surveillance LLC, as Operating Advisor ofthe Wolverine Portfolio Mortgage Loan (see Exhibit 33.5)           

33.38      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

33.39      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Kings Mountain Center MortgageLoan (see Exhibit 33.1)

33.40      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Kings Mountain Center MortgageLoan (see Exhibit 33.1)

33.41      Wells Fargo Bank, National Association, as Trustee of the Kings Mountain CenterMortgage Loan (Omitted. See Explanatory Notes.)

33.42      Wells Fargo Bank, National Association, as Custodianof the Kings Mountain Center Mortgage Loan (see Exhibit 33.4)

33.43      Pentalpha Surveillance LLC, as Operating Advisor ofthe Kings Mountain Center Mortgage Loan (see Exhibit 33.5)     

33.44      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

33.45      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Patuxent Crossing MortgageLoan (see Exhibit 33.1)

33.46      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Patuxent Crossing MortgageLoan (see Exhibit 33.1)

33.47      Wells Fargo Bank, National Association, as Trustee of the Patuxent CrossingMortgage Loan (Omitted. See Explanatory Notes.)

33.48      Wells Fargo Bank, National Association, asCustodian of the Patuxent Crossing Mortgage Loan (see Exhibit 33.4)

33.49      Pentalpha Surveillance LLC, as Operating Advisor ofthe Patuxent Crossing Mortgage Loan (see Exhibit 33.5)              

33.50      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

33.51      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of The Block Northway Mortgage Loan(see Exhibit 33.1)

33.52      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of The Block Northway Mortgage Loan(see Exhibit 33.1)

33.53      Wells Fargo Bank, National Association, as Trustee of The Block NorthwayMortgage Loan (Omitted. See Explanatory Notes.)

33.54      Wells Fargo Bank, National Association, asCustodian of The Block Northway Mortgage Loan (see Exhibit 33.4)

33.55      Pentalpha Surveillance LLC, as Operating Advisor ofThe Block Northway Mortgage Loan (see Exhibit 33.5)               

33.56      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

33.57      Wells Fargo Bank, National Association, as PrimaryServicer of the Christiana Mall Mortgage Loan

33.58      Wells Fargo Bank, National Association, as SpecialServicer of the Christiana Mall Mortgage Loan (see Exhibit 33.57)

33.59      Wilmington Trust, National Association, as Trustee of the Christiana MallMortgage Loan (Omitted. See Explanatory Notes.)

33.60      Wells Fargo Bank, National Association, asCustodian of the Christiana Mall Mortgage Loan (see Exhibit 33.4)

33.61      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Christiana Mall Mortgage Loan               

33.62      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

33.63      Wells Fargo Bank, National Association, as PrimaryServicer of the 787 Eleventh Avenue Mortgage Loan (see Exhibit 33.57)

33.64      AEGON USA Realty Advisors, LLC, as Special Servicer of the 787 Eleventh AvenueMortgage Loan prior to March 30, 2021 (Omitted. See Explanatory Notes.)

33.65      Situs Holdings, LLC, as Special Servicer of the787 Eleventh Avenue Mortgage Loan on and after March 30, 2021

33.66      Wilmington Trust, National Association, as Trustee of the 787 Eleventh AvenueMortgage Loan (Omitted. See Explanatory Notes.)

33.67      Wells Fargo Bank, National Association, asCustodian of the 787 Eleventh Avenue Mortgage Loan (see Exhibit 33.4)

33.68      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 787 Eleventh Avenue Mortgage Loan (see Exhibit 33.61)

33.69      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

33.70      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the ExchangeRight Net LeasedPortfolio 24 Mortgage Loan (see Exhibit 33.1)

33.71      3650 REIT Loan Servicing LLC, as Special Servicer of the ExchangeRight NetLeased Portfolio 24 Mortgage Loan (Omitted. See Explanatory Notes.)

33.72      Wells Fargo Bank, National Association, as Trustee of the ExchangeRight NetLeased Portfolio 24 Mortgage Loan (Omitted. See Explanatory Notes.)

33.73      Wells Fargo Bank, National Association, asCustodian of the ExchangeRight Net Leased Portfolio 24 Mortgage Loan (seeExhibit 33.4)

33.74      Park Bridge Lender Services LLC, as OperatingAdvisor of the ExchangeRight Net Leased Portfolio 24 Mortgage Loan

33.75      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

33.76      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the ILPT Hawaii Portfolio MortgageLoan (see Exhibit 33.1)

33.77      Rialto Capital Advisors, LLC, as Special Servicer of the ILPT Hawaii PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.78      Wells Fargo Bank, National Association, as Trustee of the ILPT Hawaii PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.79      Wells Fargo Bank, National Association, asCustodian of the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 33.4)

33.80      Park Bridge Lender Services LLC, as OperatingAdvisor of the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 33.74)           

33.81      Computershare Trust Company, National Association, asServicing Function Participant for the Custodian on and after November 1, 2021(see Exhibit 33.8)

33.82      KeyBank National Association, as Primary Servicerof the NEMA San Francisco Mortgage Loan (see Exhibit 33.6)

33.83      Situs Holdings, LLC, as Special Servicer of theNEMA San Francisco Mortgage Loan (see Exhibit 33.65)

33.84      Wells Fargo Bank, National Association, as Trustee of the NEMA San FranciscoMortgage Loan (Omitted. See Explanatory Notes.)

33.85      Wells Fargo Bank, National Association, asCustodian of the NEMA San Francisco Mortgage Loan (see Exhibit 33.4)  

33.86      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

33.87      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of The Colonnade Office ComplexMortgage Loan (see Exhibit 33.1)

33.88      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of The Colonnade Office ComplexMortgage Loan (see Exhibit 33.1)

33.89      Wells Fargo Bank, National Association, as Trustee of The Colonnade OfficeComplex Mortgage Loan (Omitted. See Explanatory Notes.)

33.90      Wells Fargo Bank, National Association, asCustodian of The Colonnade Office Complex Mortgage Loan (see Exhibit 33.4)

33.91      Park Bridge Lender Services LLC, as OperatingAdvisor of The Colonnade Office Complex Mortgage Loan (see Exhibit 33.74)  

33.92      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

33.93      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Southern Motion IndustrialPortfolio Mortgage Loan (see Exhibit 33.1)

33.94      Midland Loan Services, a Division of PNC Bank, NationalAssociation, as Special Servicer of the Southern Motion Industrial PortfolioMortgage Loan (see Exhibit 33.1)

33.95      Wells Fargo Bank, National Association, as Trustee of the Southern MotionIndustrial Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.96      Wells Fargo Bank, National Association, asCustodian of the Southern Motion Industrial Portfolio Mortgage Loan (seeExhibit 33.4)

33.97      Park Bridge Lender Services LLC, as OperatingAdvisor of the Southern Motion Industrial Portfolio Mortgage Loan (see Exhibit33.74)               

33.98      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

33.99      Wells Fargo Bank, National Association, as PrimaryServicer of the Goodyear Portfolio Mortgage Loan (see Exhibit 33.57)

33.100    Rialto Capital Advisors, LLC, as Special Servicer of the Goodyear PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.101    Wilmington Trust, National Association, as Trustee of the Goodyear PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.102    Wells Fargo Bank, National Association, asCustodian of the Goodyear Portfolio Mortgage Loan (see Exhibit 33.4)

33.103    Park Bridge Lender Services LLC, as OperatingAdvisor of the Goodyear Portfolio Mortgage Loan (see Exhibit 33.74)

33.104    CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Goodyear Portfolio Mortgage Loan (see Exhibit 33.61)

33.105    Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

33.106    Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Heartland Dental MedicalOffice Portfolio Mortgage Loan (see Exhibit 33.1)

33.107    Rialto Capital Advisors, LLC, as Special Servicer of the Heartland DentalMedical Office Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.108    Wilmington Trust, National Association, as Trustee of the Heartland DentalMedical Office Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.109    Wells Fargo Bank, National Association, asCustodian of the Heartland Dental Medical Office Portfolio Mortgage Loan (seeExhibit 33.4)

33.110    Park Bridge Lender Services LLC, as OperatingAdvisor of the Heartland Dental Medical Office Portfolio Mortgage Loan (seeExhibit 33.74)

33.111    Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

33.112    Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the GNL Industrial PortfolioMortgage Loan (see Exhibit 33.1)

33.113    LNR Partners, LLC, as Special Servicer of the GNLIndustrial Portfolio Mortgage Loan

33.114    Wells Fargo Bank, National Association, as Trustee of the GNL IndustrialPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.115    Wells Fargo Bank, National Association, asCustodian of the GNL Industrial Portfolio Mortgage Loan (see Exhibit 33.4)

33.116    Pentalpha Surveillance LLC, as Operating Advisor ofthe GNL Industrial Portfolio Mortgage Loan (see Exhibit 33.5)   

33.117    Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

33.118    Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the ExchangeRight Net LeasedPortfolio 26 Mortgage Loan (see Exhibit 33.1)

33.119    LNR Partners, LLC, as Special Servicer of theExchangeRight Net Leased Portfolio 26 Mortgage Loan (see Exhibit 33.113)

33.120    Wells Fargo Bank, National Association, as Trustee of the ExchangeRight NetLeased Portfolio 26 Mortgage Loan (Omitted. See Explanatory Notes.)

33.121    Wells Fargo Bank, National Association, asCustodian of the ExchangeRight Net Leased Portfolio 26 Mortgage Loan (seeExhibit 33.4)

33.122    Pentalpha Surveillance LLC, as Operating Advisor ofthe ExchangeRight Net Leased Portfolio 26 Mortgage Loan (see Exhibit 33.5)               

33.123    Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

34           Attestationreports on assessment of compliance with servicing criteria for asset-backedsecurities.

34.1        Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer

34.2        Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer (see Exhibit 34.1)

34.3        Wells Fargo Bank, National Association, as Trusteeand Certificate Administrator

34.4        Wells Fargo Bank, National Association, asCustodian

34.5        Pentalpha Surveillance LLC, as Operating Advisor

34.6        KeyBank National Association, as Primary Servicer            

34.7        Computershare Trust Company, National Association,as Servicing Function Participant for the Trustee and Certificate Administratoron and after November 1, 2021

34.8        Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021

34.9        KeyBank National Association, as Primary Servicerof the SSTII Self Storage Portfolio II Mortgage Loan (see Exhibit 34.6)

34.10      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the SSTII Self Storage PortfolioII Mortgage Loan (see Exhibit 34.1)

34.11      Wells Fargo Bank, National Association, as Trustee of the SSTII Self StoragePortfolio II Mortgage Loan (Omitted. See Explanatory Notes.)

34.12      Wells Fargo Bank, National Association, asCustodian of the SSTII Self Storage Portfolio II Mortgage Loan (see Exhibit34.4)

34.13      Pentalpha Surveillance LLC, as Operating Advisor ofthe SSTII Self Storage Portfolio II Mortgage Loan (see Exhibit 34.5)          

34.14      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

34.15      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Vanguard Portfolio MortgageLoan (see Exhibit 34.1)

34.16      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Vanguard Portfolio MortgageLoan (see Exhibit 34.1)

34.17      Wells Fargo Bank, National Association, as Trustee of the Vanguard PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.18      Wells Fargo Bank, National Association, asCustodian of the Vanguard Portfolio Mortgage Loan (see Exhibit 34.4)

34.19      Pentalpha Surveillance LLC, as Operating Advisor ofthe Vanguard Portfolio Mortgage Loan (see Exhibit 34.5)            

34.20      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

34.21      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the SWVP Portfolio Mortgage Loan(see Exhibit 34.1)

34.22      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the SWVP Portfolio Mortgage Loan(see Exhibit 34.1)

34.23      Wells Fargo Bank, National Association, as Trustee of the SWVP PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.24      Wells Fargo Bank, National Association, asCustodian of the SWVP Portfolio Mortgage Loan (see Exhibit 34.4)

34.25      Pentalpha Surveillance LLC, as Operating Advisor ofthe SWVP Portfolio Mortgage Loan (see Exhibit 34.5)  

34.26      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

34.27      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Inland Devon Self StoragePortfolio Mortgage Loan (see Exhibit 34.1)

34.28      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Inland Devon Self StoragePortfolio Mortgage Loan (see Exhibit 34.1)

34.29      Wells Fargo Bank, National Association, as Trustee of the Inland Devon SelfStorage Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.30      Wells Fargo Bank, National Association, asCustodian of the Inland Devon Self Storage Portfolio Mortgage Loan (see Exhibit34.4)

34.31      Pentalpha Surveillance LLC, as Operating Advisor ofthe Inland Devon Self Storage Portfolio Mortgage Loan (see Exhibit 34.5) 

34.32      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

34.33      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Wolverine Portfolio MortgageLoan (see Exhibit 34.1)

34.34      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Wolverine Portfolio MortgageLoan (see Exhibit 34.1)

34.35      Wells Fargo Bank, National Association, as Trustee of the Wolverine PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.36      Wells Fargo Bank, National Association, asCustodian of the Wolverine Portfolio Mortgage Loan (see Exhibit 34.4)

34.37      Pentalpha Surveillance LLC, as Operating Advisor ofthe Wolverine Portfolio Mortgage Loan (see Exhibit 34.5)           

34.38      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

34.39      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Kings Mountain Center MortgageLoan (see Exhibit 34.1)

34.40      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Kings Mountain Center MortgageLoan (see Exhibit 34.1)

34.41      Wells Fargo Bank, National Association, as Trustee of the Kings Mountain CenterMortgage Loan (Omitted. See Explanatory Notes.)

34.42      Wells Fargo Bank, National Association, asCustodian of the Kings Mountain Center Mortgage Loan (see Exhibit 34.4)

34.43      Pentalpha Surveillance LLC, as Operating Advisor ofthe Kings Mountain Center Mortgage Loan (see Exhibit 34.5)     

34.44      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

34.45      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Patuxent Crossing MortgageLoan (see Exhibit 34.1)

34.46      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Patuxent Crossing MortgageLoan (see Exhibit 34.1)

34.47      Wells Fargo Bank, National Association, as Trustee of the Patuxent CrossingMortgage Loan (Omitted. See Explanatory Notes.)

34.48      Wells Fargo Bank, National Association, asCustodian of the Patuxent Crossing Mortgage Loan (see Exhibit 34.4)

34.49      Pentalpha Surveillance LLC, as Operating Advisor ofthe Patuxent Crossing Mortgage Loan (see Exhibit 34.5)              

34.50      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

34.51      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of The Block Northway Mortgage Loan(see Exhibit 34.1)

34.52      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of The Block Northway Mortgage Loan(see Exhibit 34.1)

34.53      Wells Fargo Bank, National Association, as Trustee of The Block NorthwayMortgage Loan (Omitted. See Explanatory Notes.)

34.54      Wells Fargo Bank, National Association, asCustodian of The Block Northway Mortgage Loan (see Exhibit 34.4)

34.55      Pentalpha Surveillance LLC, as Operating Advisor ofThe Block Northway Mortgage Loan (see Exhibit 34.5)               

34.56      Computershare Trust Company, National Association, asServicing Function Participant for the Custodian on and after November 1, 2021(see Exhibit 34.8)

34.57      Wells Fargo Bank, National Association, as PrimaryServicer of the Christiana Mall Mortgage Loan

34.58      Wells Fargo Bank, National Association, as SpecialServicer of the Christiana Mall Mortgage Loan (see Exhibit 34.57)

34.59      Wilmington Trust, National Association, as Trustee of the Christiana MallMortgage Loan (Omitted. See Explanatory Notes.)

34.60      Wells Fargo Bank, National Association, asCustodian of the Christiana Mall Mortgage Loan (see Exhibit 34.4)

34.61      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Christiana Mall Mortgage Loan               

34.62      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

34.63      Wells Fargo Bank, National Association, as PrimaryServicer of the 787 Eleventh Avenue Mortgage Loan (see Exhibit 34.57)

34.64      AEGON USA Realty Advisors, LLC, as Special Servicer of the 787 Eleventh AvenueMortgage Loan prior to March 30, 2021 (Omitted. See Explanatory Notes.)

34.65      Situs Holdings, LLC, as Special Servicer of the787 Eleventh Avenue Mortgage Loan on and after March 30, 2021

34.66      Wilmington Trust, National Association, as Trustee of the 787 Eleventh AvenueMortgage Loan (Omitted. See Explanatory Notes.)

34.67      Wells Fargo Bank, National Association, asCustodian of the 787 Eleventh Avenue Mortgage Loan (see Exhibit 34.4)

34.68      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 787 Eleventh Avenue Mortgage Loan (see Exhibit 34.61)

34.69      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

34.70      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the ExchangeRight Net LeasedPortfolio 24 Mortgage Loan (see Exhibit 34.1)

34.71      3650 REIT Loan Servicing LLC, as Special Servicer of the ExchangeRight NetLeased Portfolio 24 Mortgage Loan (Omitted. See Explanatory Notes.)

34.72      Wells Fargo Bank, National Association, as Trustee of the ExchangeRight NetLeased Portfolio 24 Mortgage Loan (Omitted. See Explanatory Notes.)

34.73      Wells Fargo Bank, National Association, asCustodian of the ExchangeRight Net Leased Portfolio 24 Mortgage Loan (seeExhibit 34.4)

34.74      Park Bridge Lender Services LLC, as OperatingAdvisor of the ExchangeRight Net Leased Portfolio 24 Mortgage Loan

34.75      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

34.76      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the ILPT Hawaii Portfolio MortgageLoan (see Exhibit 34.1)

34.77      Rialto Capital Advisors, LLC, as Special Servicer of the ILPT Hawaii PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.78      Wells Fargo Bank, National Association, as Trustee of the ILPT Hawaii PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.79      Wells Fargo Bank, National Association, asCustodian of the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 34.4)

34.80      Park Bridge Lender Services LLC, as OperatingAdvisor of the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 34.74)           

34.81      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

34.82      KeyBank National Association, as Primary Servicerof the NEMA San Francisco Mortgage Loan (see Exhibit 34.6)

34.83      Situs Holdings, LLC, as Special Servicer of the NEMASan Francisco Mortgage Loan (see Exhibit 34.65)

34.84      Wells Fargo Bank, National Association, as Trustee of the NEMA San FranciscoMortgage Loan (Omitted. See Explanatory Notes.)

34.85      Wells Fargo Bank, National Association, asCustodian of the NEMA San Francisco Mortgage Loan (see Exhibit 34.4)  

34.86      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

34.87      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of The Colonnade Office ComplexMortgage Loan (see Exhibit 34.1)

34.88      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of The Colonnade Office ComplexMortgage Loan (see Exhibit 34.1)

34.89      Wells Fargo Bank, National Association, as Trustee of The Colonnade OfficeComplex Mortgage Loan (Omitted. See Explanatory Notes.)

34.90      Wells Fargo Bank, National Association, asCustodian of The Colonnade Office Complex Mortgage Loan (see Exhibit 34.4)

34.91      Park Bridge Lender Services LLC, as OperatingAdvisor of The Colonnade Office Complex Mortgage Loan (see Exhibit 34.74)  

34.92      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

34.93      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Southern Motion IndustrialPortfolio Mortgage Loan (see Exhibit 34.1)

34.94      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Southern Motion IndustrialPortfolio Mortgage Loan (see Exhibit 34.1)

34.95      Wells Fargo Bank, National Association, as Trustee of the Southern MotionIndustrial Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.96      Wells Fargo Bank, National Association, as Custodianof the Southern Motion Industrial Portfolio Mortgage Loan (see Exhibit 34.4)

34.97      Park Bridge Lender Services LLC, as OperatingAdvisor of the Southern Motion Industrial Portfolio Mortgage Loan (see Exhibit34.74)               

34.98      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

34.99      Wells Fargo Bank, National Association, as PrimaryServicer of the Goodyear Portfolio Mortgage Loan (see Exhibit 34.57)

34.100    Rialto Capital Advisors, LLC, as Special Servicer of the Goodyear PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.101    Wilmington Trust, National Association, as Trustee of the Goodyear PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.102    Wells Fargo Bank, National Association, asCustodian of the Goodyear Portfolio Mortgage Loan (see Exhibit 34.4)

34.103    Park Bridge Lender Services LLC, as OperatingAdvisor of the Goodyear Portfolio Mortgage Loan (see Exhibit 34.74)

34.104    CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Goodyear Portfolio Mortgage Loan (see Exhibit 34.61)

34.105    Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

34.106    Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Heartland Dental MedicalOffice Portfolio Mortgage Loan (see Exhibit 34.1)

34.107    Rialto Capital Advisors, LLC, as Special Servicer of the Heartland DentalMedical Office Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.108    Wilmington Trust, National Association, as Trustee of the Heartland DentalMedical Office Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.109    Wells Fargo Bank, National Association, asCustodian of the Heartland Dental Medical Office Portfolio Mortgage Loan (seeExhibit 34.4)

34.110    Park Bridge Lender Services LLC, as OperatingAdvisor of the Heartland Dental Medical Office Portfolio Mortgage Loan (seeExhibit 34.74)

34.111    Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

34.112    Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the GNL Industrial PortfolioMortgage Loan (see Exhibit 34.1)

34.113    LNR Partners, LLC, as Special Servicer of the GNLIndustrial Portfolio Mortgage Loan

34.114    Wells Fargo Bank, National Association, as Trustee of the GNL IndustrialPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.115    Wells Fargo Bank, National Association, asCustodian of the GNL Industrial Portfolio Mortgage Loan (see Exhibit 34.4)

34.116    Pentalpha Surveillance LLC, as Operating Advisor ofthe GNL Industrial Portfolio Mortgage Loan (see Exhibit 34.5)   

34.117    Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

34.118    Midland Loan Services, a Division of PNC Bank, NationalAssociation, as Primary Servicer of the ExchangeRight Net Leased Portfolio 26Mortgage Loan (see Exhibit 34.1)

34.119    LNR Partners, LLC, as Special Servicer of theExchangeRight Net Leased Portfolio 26 Mortgage Loan (see Exhibit 34.113)

34.120    Wells Fargo Bank, National Association, as Trustee of the ExchangeRight NetLeased Portfolio 26 Mortgage Loan (Omitted. See Explanatory Notes.)

34.121    Wells Fargo Bank, National Association, asCustodian of the ExchangeRight Net Leased Portfolio 26 Mortgage Loan (seeExhibit 34.4)

34.122    Pentalpha Surveillance LLC, as Operating Advisor ofthe ExchangeRight Net Leased Portfolio 26 Mortgage Loan (see Exhibit 34.5)               

34.123    Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

35           Servicer compliance statements.

35.1        Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer

35.2        Midland Loan Services, a Division of PNC Bank, NationalAssociation, as Special Servicer (see Exhibit 35.1)

35.3        Wells Fargo Bank, National Association, asCertificate Administrator

35.4        KeyBank National Association, as Primary Servicer

35.5        Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator on andafter November 1, 2021

35.6        KeyBank National Association, as Primary Servicerof the SSTII Self Storage Portfolio II Mortgage Loan (see Exhibit 35.4)

35.7        Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the SSTII Self Storage PortfolioII Mortgage Loan (see Exhibit 35.1)

35.8        Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Vanguard Portfolio Mortgage Loan(see Exhibit 35.1)

35.9        Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Vanguard Portfolio MortgageLoan (see Exhibit 35.1)

35.10      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the SWVP Portfolio Mortgage Loan(see Exhibit 35.1)

35.11      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the SWVP Portfolio Mortgage Loan(see Exhibit 35.1)

35.12      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Inland Devon Self Storage PortfolioMortgage Loan (see Exhibit 35.1)

35.13      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Inland Devon Self StoragePortfolio Mortgage Loan (see Exhibit 35.1)

35.14      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Wolverine Portfolio MortgageLoan (see Exhibit 35.1)

35.15      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Wolverine Portfolio MortgageLoan (see Exhibit 35.1)

35.16      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Kings Mountain Center MortgageLoan (see Exhibit 35.1)

35.17      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Kings Mountain Center MortgageLoan (see Exhibit 35.1)

35.18      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Patuxent Crossing MortgageLoan (see Exhibit 35.1)

35.19      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Patuxent Crossing MortgageLoan (see Exhibit 35.1)

35.20      Midland Loan Services, a Division of PNC Bank, NationalAssociation, as Primary Servicer of The Block Northway Mortgage Loan (seeExhibit 35.1)

35.21      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of The Block Northway Mortgage Loan(see Exhibit 35.1)

35.22      Wells Fargo Bank, National Association, as PrimaryServicer of the Christiana Mall Mortgage Loan

35.23      Wells Fargo Bank, National Association, as SpecialServicer of the Christiana Mall Mortgage Loan (see Exhibit 35.22)

35.24      Wells Fargo Bank, National Association, as PrimaryServicer of the 787 Eleventh Avenue Mortgage Loan (see Exhibit 35.22)

35.25      AEGON USA Realty Advisors, LLC, as Special Servicer of the 787 Eleventh AvenueMortgage Loan prior to March 30, 2021 (Omitted. See Explanatory Notes.)

35.26      Situs Holdings, LLC, as Special Servicer of the 787 Eleventh Avenue MortgageLoan on and after March 30, 2021 (Omitted. See Explanatory Notes.)

35.27      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the ExchangeRight Net LeasedPortfolio 24 Mortgage Loan (see Exhibit 35.1)

35.28      3650 REIT Loan Servicing LLC, as Special Servicer of the ExchangeRight NetLeased Portfolio 24 Mortgage Loan (Omitted. See Explanatory Notes.)

35.29      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the ILPT Hawaii Portfolio MortgageLoan (see Exhibit 35.1)

35.30      Rialto Capital Advisors, LLC, as Special Servicer of the ILPT Hawaii PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

35.31      KeyBank National Association, as Primary Servicerof the NEMA San Francisco Mortgage Loan (see Exhibit 35.4)

35.32      Situs Holdings, LLC, as Special Servicer of the NEMA San Francisco MortgageLoan (Omitted. See Explanatory Notes.)

35.33      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of The Colonnade Office ComplexMortgage Loan (see Exhibit 35.1)

35.34      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of The Colonnade Office ComplexMortgage Loan (see Exhibit 35.1)

35.35      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Southern Motion IndustrialPortfolio Mortgage Loan (see Exhibit 35.1)

35.36      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Southern Motion IndustrialPortfolio Mortgage Loan (see Exhibit 35.1)

35.37      Wells Fargo Bank, National Association, as PrimaryServicer of the Goodyear Portfolio Mortgage Loan (see Exhibit 35.22)

35.38      Rialto Capital Advisors, LLC, as Special Servicer of the Goodyear PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

35.39      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Heartland Dental MedicalOffice Portfolio Mortgage Loan (see Exhibit 35.1)

35.40      Rialto Capital Advisors, LLC, as Special Servicer of the Heartland DentalMedical Office Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

35.41      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the GNL Industrial PortfolioMortgage Loan (see Exhibit 35.1)

35.42      LNR Partners, LLC, as Special Servicer of the GNL Industrial Portfolio MortgageLoan (Omitted. See Explanatory Notes.)

35.43      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the ExchangeRight Net Leased Portfolio26 Mortgage Loan (see Exhibit 35.1)

35.44      LNR Partners, LLC, as Special Servicer of the ExchangeRight Net LeasedPortfolio 26 Mortgage Loan (Omitted. See Explanatory Notes.)

99.1        MortgageLoan Purchase Agreement, dated as of May 17, 2019, between Barclays CommercialMortgage Securities LLC, Barclays Capital Real Estate Inc. and Barclays CapitalHoldings Inc. (filed as Exhibit 99.1 to the registrant’s Current Report on Form8-K filed on June 11, 2019 under Commission File No. 333-226850-02 andincorporated by reference herein)

99.2        MortgageLoan Purchase Agreement, dated as of May 17, 2019, between Barclays CommercialMortgage Securities LLC and Societe Generale Financial Corporation (filed asExhibit 99.2 to the registrant’s Current Report on Form 8-K filed on June 11,2019 under Commission File No. 333-226850-02 and incorporated by referenceherein)

99.3        MortgageLoan Purchase Agreement, dated as of May 17, 2019, between Barclays CommercialMortgage Securities LLC and KeyBank National Association (filed as Exhibit 99.3to the registrant’s Current Report on Form 8-K filed on June 11, 2019 underCommission File No. 333-226850-02 and incorporated by reference herein)

99.4        MortgageLoan Purchase Agreement, dated as of May 17, 2019, between Barclays CommercialMortgage Securities LLC and UBS AG, by and through its branch office at 1285Avenue of the Americas (filed as Exhibit 99.4 to the registrant’s CurrentReport on Form 8-K filed on June 11, 2019 under Commission File No.333-226850-02 and incorporated by reference herein)

99.5        MortgageLoan Purchase Agreement, dated as of May 17, 2019, between Barclays CommercialMortgage Securities LLC and Natixis Real Estate Capital LLC (filed as Exhibit99.5 to the registrant’s Current Report on Form 8-K filed on June 11, 2019under Commission File No. 333-226850-02 and incorporated by reference herein)

99.6        MortgageLoan Purchase Agreement, dated as of May 17, 2019, between Barclays CommercialMortgage Securities LLC and Rialto Mortgage Finance, LLC (filed as Exhibit 99.6to the registrant’s Current Report on Form 8-K filed on June 11, 2019 underCommission File No. 333-226850-02 and incorporated by reference herein)

(b)   The exhibits required to be filed by theRegistrant pursuant to Item 601 of Regulation S-K are listed above.

(c)    Not Applicable.

 

**SIGNATURES**

Pursuant to the requirements of Section 13 or 15(d) of theSecurities Exchange Act of 1934, the registrant has duly caused this report tobe signed on its behalf by the undersigned, thereunto duly authorized.

Barclays Commercial MortgageSecurities LLC(Depositor)

/s/ DanielVinson

DanielVinson, Chief Executive Officer

(senior officer in charge ofsecuritization of the depositor)

Date: March 15, 2022