Exhibit 33.9

 

 

Trimont Real Estate Advisors, LLC

 

Management's Report on Assessment of Compliance with SEC Regulation AB Servicing Criteria

 

 

 

Trimont Real Estate Advisors, LLC ("the Asserting Party") is responsible for assessing compliance as of and for the year ended December 31, 2019 ("the Reporting Period") with the applicable servicing criteria set forth in Item 1122(d) of the Securities and Exchange Commission's Regulation AB as set forth in Exhibit A hereto (the "Applicable Servicing Criteria"). The transactions covered by this report are only those transactions processed by the Asserting Party in capacity as special servicer for the asset backed securities transactions listed in Exhibit B hereto (the "Platform").

 

The Asserting Party has used the servicing criteria set forth in Item 1122(d) of the Securities and Exchange Commission's Regulation AB to assess its compliance with the Applicable Servicing Criteria for the Reporting Period and has concluded that the Asserting Party has complied, in all material respects, with the Applicable Servicing Criteria as of and for the year ended December 31, 2019 with respect to the Platform.

 

Grant Thornton, LLP, an independent registered public accounting firm, has issued an attestation report on the assessment of compliance with the Applicable Servicing Criteria as of and for the year ended December 31, 2019 as set forth in this assertion.

 

 

Trimont Real Estate Advisors, LLC February 25, 2020

 

|                         |
|-------------------------|
| /s/ Glen Peters         |
| Glen Peters             |
| Chief Financial Officer |
|                    |

 

 

 

AMSTERDAM I ATLANTA I DALLAS I KANSAS CITY I LONDON I LOS ANGELES I NEW YORK I SYDNEY

 
 

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Exhibit A

 

| Regulation AB Criteria             | JPMCC 2018-MINN                                    | COMM 2012-CCRE2                                                                                                                                                                                                                                                  | GSMS 2018-TWR | AHT 2018 Keys | Bancorp 2018-CRE3 | Bancorp 2018-CRE4 | GSMS 2018-GS10 | JPMC 2018-MBR MZ | CSMC 2017-PFHP | CPLV TRUST 2017-VICI | MSC 2017-ASHF |
|------------------------------------|----------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------|---------------|-------------------|-------------------|----------------|------------------|----------------|----------------------|---------------|
| Section                            | Description                                        | Criteria                                                                                                                                                                                                                                                         |          |          |              |              |           |             |           |                 |          |   |   |
| General Servicing Considerations   |
| (d)(1)(i)                          | Policies and Procedures                            | Policies and procedures are instituted to monitor any performance or other triggers and events of default in accordance with the transaction agreement.                                                                                                          | X             | X             | X                 | X                 | X              | X                | X              | X                    | X             | X | X |
| (d)(1)(ii)                         | Policies and Procedures (vendors)                  | If any material servicing activities are outsourced to third parties, policies and procedures are instituted to monitor the third party's performance and compliance with such servicing activities.                                                             | X7            | X7            | X7                | X7                | X7             | X7               | X7             | X7                   | X7            | X7 | X7 |
| (d)(1)(iii)                        | Back-up Servicer                                   | Any requirements in the transaction agreements to maintain a back-up servicer for the pool assets are maintained.                                                                                                                                                | N/A           | N/A           | N/A               | N/A               | N/A            | N/A              | N/A            | N/A                  | N/A           | N/A | N/A |
| (d)(1)(iv)                         | Fidelity Bond                                      | A fidelity bond and errors and omissions policy is in effect on the party participating in the servicing function throughout the reporting period in the amount of coverage required by and otherwise in accordance with the terms of the transaction agreement. | X             | X             | X                 | X                 | X              | X                | X              | X                    | X             | X | X |
| (d)(1)(v)                          | Accuracy of Information                            | Aggregation of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information.                                                                                                                          | X4            | X4            | X4                | X4                | X4             | X4               | X4             | X4                   | X4            | X4 | X4 |
| Cash Collection and Administration |
| (d)(2)(i)                          | 2 Days to deposit Payments into Custodial Accounts | Payments on pool assets are deposited into the appropriate custodial bank accounts and related bank clearing accounts no more than two business days of receipt, or such other number of days specified in the transaction agreements.                           | X1            | X1            | X1                | X1                | X1             | X1               | X1             | X1                   | X1            | X1 | X1 |
| (d)(2)(ii)                         | Wire Transfers                                     | Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.                                                                                                                                            | N/A           | N/A           | N/A               | N/A               | N/A            | N/A              | N/A            | N/A                  | N/A           | N/A | N/A |
| (d)(2)(iii)                        | Advances                                           | Advances of funds or guarantees regarding collections, cash flows or distributions, and any interest or other fees charged for such advances, are made, reviewed and approved as specified in the transaction agreements.                                        | X2            | X1            | X2                | X2                | X2             | X2               | X1             | X2                   | X2            | X2 | X2 |
| (d)(2)(iv)                         | Commingling                                        | The related accounts for the transaction, such as cash reserve accounts or accounts established as a form of over collateralization, are separately maintained (e.g., with respect to commingling of cash) as set forth in the transaction agreements.           | X1            | X1            | X1                | X1                | X1             | X1               | X1             | X1                   | X1            | X1 | X1 |

 

 

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Exhibit A

 

| Regulation AB Criteria            | JPMCC 2018-MINN               | COMM 2012-CCRE2                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | GSMS 2018-TWR | AHT 2018 Keys | Bancorp 2018-CRE3 | Bancorp 2018-CRE4 | GSMS 2018-GS10 | JPMC 2018-MBR MZ | CSMC 2017-PFHP | CPLV TRUST 2017-VICI | MSC 2017-ASHF |
|-----------------------------------|-------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------|---------------|-------------------|-------------------|----------------|------------------|----------------|----------------------|---------------|
| Section                           | Description                   | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |          |          |              |              |           |             |           |                 |          |   |   |
| (d)(2)(v)                         | Federally Insured Institution | Each custodial account is maintained at a federally insured depository institution as set forth in the transaction agreements. For purposes of this criterion, "federally insured depository institution" with respect to a foreign financial institution means a foreign financial institution that meets the requirements of §240.13k-1(b)(1) of this chapter. I.3 Each custodial account shall be maintained at a federally insured depository institution in trust for the applicable investor.                                                                                                                                                                                                      | X1            | X1            | X1                | X1                | X1             | X1               | X1             | X1                   | X1            | X1 | X1 |
| (d)(2)(vi)                        | Unissued Checks               | Unissued checks are safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | X1            | X1            | X1                | X1                | X1             | X1               | X1             | X1                   | X1            | X1 | X1 |
| (d)(2)(vii)                       | Reconciliations               | Reconciliations are prepared on a monthly basis for all asset-backed securities related bank accounts, including custodial accounts and related bank clearing accounts. These reconciliations: (a) are mathematically accurate; (b) are prepared within 30 calendar days after the bank statement cutoff date, or such other number of days specified in the transaction agreements; (c) are reviewed and approved by someone other than the person who prepared the reconciliation; and (d) contain explanations for reconciling items. These reconciling items are resolved within 90 calendar days of their original identification, or such other number of days specified in the transaction agreements. | X1            | X1            | X1                | X1                | X1             | X1               | X1             | X1                   | X1            | X1 | X1 |
| Investor Remittance and Reporting |
| (d)(3)(i)                         | Reports to the Investor       | Reports to investors, including those to be filed with the Commission, are maintained in accordance with the transaction agreements and applicable Commission requirements. Specifically, such reports:

(a) are prepared in accordance with timeframes and other terms set forth in the transaction agreements; (b) provide information calculated in accordance with the terms specified in the transaction agreements; (c) are filed with the Commission as required by its rules and regulations; and (d) agree with investors' or the trustee's records as to the total unpaid principal balance and number of pool assets serviced by the servicer.                                                     | N/A           | N/A           | N/A               | N/A               | N/A            | N/A              | N/A            | N/A                  | N/A           | N/A | N/A |
| (d)(3)(ii)                        | Investor Remittance           | Amounts due to investors are allocated and remitted in accordance with timeframes, distribution priority and other terms set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | N/A           | N/A           | N/A               | N/A               | N/A            | N/A              | N/A            | N/A                  | N/A           | N/A | N/A |
| (d)(3)(iii)                       | Investor's Records            | Disbursements made to an investor are posted within two business days to the servicer's investor records, or such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | N/A           | N/A           | N/A               | N/A               | N/A            | N/A              | N/A            | N/A                  | N/A           | N/A | N/A |

 

 

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Exhibit A

| Regulation AB Criteria    | JPMCC 2018-MINN                    | COMM 2012-CCRE2                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | GSMS 2018-TWR | AHT 2018 Keys | Bancorp 2018-CRE3 | Bancorp 2018-CRE4 | GSMS 2018-GS10 | JPMC 2018-MBR MZ | CSMC 2017-PFHP | CPLV TRUST 2017-VICI | MSC 2017-ASHF |
|---------------------------|------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------|---------------|-------------------|-------------------|----------------|------------------|----------------|----------------------|---------------|
| Section                   | Description                        | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |          |          |              |              |           |             |           |                 |          |   |   |
| (d)(3)(iv)                | Remittance and Bank Statements     | Amounts remitted to investors per the investor reports agree with cancelled checks, or other form of payment, or custodial bank statements.                                                                                                                                                                                                                                                                                                                                                                    | N/A           | N/A           | N/A               | N/A               | N/A            | N/A              | N/A            | N/A                  | N/A           | N/A | N/A |
| Pool Asset Administration |
| (d)(4)(i)                 | Collateral/Security on Pool Assets | Collateral or security on pool assets is maintained as required by the transaction agreements or related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                 | X1            | X1            | X1                | X1                | X1             | X1               | X1             | X1                   | X1            | X1 | X1 |
| (d)(4)(ii)                | Safeguard Pool Assets              | Pool assets and related documents are safeguarded as required by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                   | N/A           | N/A           | N/A               | N/A               | N/A            | N/A              | N/A            | N/A                  | N/A           | N/A | N/A |
| (d)(4)(iii)               | Changes to the Pool Assets         | Any additions, removals or substitutions to the asset pool are made, reviewed and approved in accordance with any conditions or requirements in the transaction agreements.                                                                                                                                                                                                                                                                                                                                    | X1            | X1            | X1                | X1                | X1             | X1               | X1             | X1                   | X1            | X1 | X1 |
| (d)(4)(iv)                | Obligor's Payment Record           | Payments on pool assets, including any payoffs, made in accordance with the related pool asset documents are posted to the applicable servicer's obligor records maintained no more than two business days after receipt, or such other number of days specified in the transaction agreements, and allocated to principal, interest or other items (e.g. escrow) in accordance with the related pool asset documents.                                                                                         | N/A           | N/A           | N/A               | N/A               | N/A            | N/A              | N/A            | N/A                  | N/A           | N/A | N/A |
| (d)(4)(v)                 | Pool Asset Records Match UPB       | The servicers records regarding the pool assets agree with the servicer's records with respect to an obligor's unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                       | N/A           | N/A           | N/A               | N/A               | N/A            | N/A              | N/A            | N/A                  | N/A           | N/A | N/A |
| (d)(4)(vi)                | Loan Modifications                 | Changes with respect to the terms or status of an obligor's pool asset (e.g. loan modifications or re-agings) are made, reviewed and approved by authorized personnel in accordance with the transaction agreements and related pool asset documents.                                                                                                                                                                                                                                                          | X1            | X1            | X1                | X1                | X1             | X1               | X1             | X1                   | X1            | X1 | X1 |
| (d)(4)(vii)               | Loss Mitigation Actions            | Loss mitigation or recovery actions (e.g., forbearance plans, modifications and deeds in lieu of foreclosure, foreclosures and repossessions, as applicable) are initiated, conducted and concluded in accordance with the timeframes or other requirements established by the transaction agreement.                                                                                                                                                                                                          | X1            | X1            | X1                | X1                | X1             | X1               | X1             | X1                   | X1            | X1 | X1 |
| (d)(4)(viii)              | Collection Efforts Documented      | Records documenting collection efforts are maintained during the period a pool asset is delinquent in accordance with the transaction agreements. Such records are maintained on at least a monthly basis, or such other period specified in the transaction agreements, and describe the entity's activities in monitoring delinquent pool assets including, for example, phone calls, letters and payment rescheduling plans in cases where delinquency is deemed temporary (e.g., illness or unemployment). | X1            | X1            | X1                | X1                | X1             | X1               | X1             | X1                   | X1            | X1 | X1 |

 

 

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Exhibit A

| Regulation AB Criteria | JPMCC 2018-MINN                                     | COMM 2012-CCRE2                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | GSMS 2018-TWR | AHT 2018 Keys | Bancorp 2018-CRE3 | Bancorp 2018-CRE4 | GSMS 2018-GS10 | JPMC 2018-MBR MZ | CSMC 2017-PFHP | CPLV TRUST 2017-VICI | MSC 2017-ASHF |
|------------------------|-----------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------|---------------|-------------------|-------------------|----------------|------------------|----------------|----------------------|---------------|
| Section                | Description                                         | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |          |          |              |              |           |             |           |                 |          |   |   |
| (d)(4)(ix)             | ARMs                                                | Adjustments to interest rates or rates of return for pool assets with variable rates are computed based on the related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                              | N/A           | N/A           | N/A               | N/A               | N/A            | N/A              | N/A            | N/A                  | N/A           | N/A | N/A |
| (d)(4)(x)              | Escrow Funds                                        | Regarding any funds held in trust for an obligor such funds are (a) analyzed, in accordance with the obligor's pool asset documents, on at least an annual basis, or such other period specified in the transaction agreements; (b) interest on such funds is paid, or credited, to obligors in accordance with applicable pool asset documents and state laws; and (c)returned to the obligor within 30 calendar days of full repayment of the related pool asset, or such other number of days specified in the transaction agreements. | N/A           | N/A           | N/A               | N/A               | N/A            | N/A              | N/A            | N/A                  | N/A           | N/A | N/A |
| (d)(4)(xi)             | Timely Payments                                     | Payments made on behalf of an obligor (such as tax or insurance payments) are made on or before the related penalty or expiration dates, as indicated on the appropriate bills or notices for such payments, provided that such support has been received by the servicer at least 30 calendar days prior to these dates, or such other number of days specified in the transaction agreements.                                                                                                                                           | N/A           | N/A           | N/A               | N/A               | N/A            | N/A              | N/A            | N/A                  | N/A           | N/A | N/A |
| (d)(4)(xii)            | Late Payment Penalties                              | Any late payment penalties in connection with any payment to be made on behalf of an obligor are paid from the Servicer's funds and not charged to the obligor, unless the late payment was due to the obligor's error or omission.                                                                                                                                                                                                                                                                                                       | N/A           | N/A           | N/A               | N/A               | N/A            | N/A              | N/A            | N/A                  | N/A           | N/A | N/A |
| (d)(4)(xiii)           | Obligor's Records                                   | Disbursements made on behalf of an obligor are posted within two business days to the obligor's records maintained by the servicer, or such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                 | N/A           | N/A           | N/A               | N/A               | N/A            | N/A              | N/A            | N/A                  | N/A           | N/A | N/A |
| (d)(4)(xiv)            | Delinquencies, Charge-offs, and Other Uncollectible | Delinquencies, Charge-offs, and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                         | N/A           | N/A           | N/A               | N/A               | N/A            | N/A              | N/A            | N/A                  | N/A           | N/A | N/A |
| (d)(4)(xv)             | Any External Enhancement                            | Any external enhancement or other support, identified in Item 1114(a)(1) through (3) or Item 1115 of this Regulation AB, is maintained as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                        | N/A           | N/A           | N/A               | N/A               | N/A            | N/A              | N/A            | N/A                  | N/A           | N/A | N/A |

 

 

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Exhibit A

| Regulation AB Criteria             | VSD 2017-PLT1                                      | RPT 2017-ROSS                                                                                                                                                                                                                                                    | Bancorp 2017-CRE2 | CGMS 2017 MDDR | COLD 2017-ICE3 | 2016-225L | BANCORP 2016-CRE1 | GSMS 2016-GS3 | CGBAM 2015-SMRT MZ | Lone Star 2015 LSP-MZ | WFCG 2015-BXRP |
|------------------------------------|----------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------|----------------|----------------|-----------|-------------------|---------------|--------------------|-----------------------|----------------|
| Section                            | Description                                        | Criteria                                                                                                                                                                                                                                                         |              |           |           |      |              |          |               |                  |           |   |   |
| General Servicing Considerations   |
| (d)(1)(i)                          | Policies and Procedures                            | Policies and procedures are instituted to monitor any performance or other triggers and events of default in accordance with the transaction agreement.                                                                                                          | X                 | X              | X              | X         | X                 | X             | X                  | X                     | X              | X | X |
| (d)(1)(ii)                         | Policies and Procedures (vendors)                  | If any material servicing activities are outsourced to third parties, policies and procedures are instituted to monitor the third party's performance and compliance with such servicing activities.                                                             | X7                | X7             | X7             | X7        | X7                | X7            | X7                 | X7                    | X7             | X7 | X7 |
| (d)(1)(iii)                        | Back-up Servicer                                   | Any requirements in the transaction agreements to maintain a back-up servicer for the pool assets are maintained.                                                                                                                                                | N/A               | N/A            | N/A            | N/A       | N/A               | N/A           | N/A                | N/A                   | N/A            | N/A | N/A |
| (d)(1)(iv)                         | Fidelity Bond                                      | A fidelity bond and errors and omissions policy is in effect on the party participating in the servicing function throughout the reporting period in the amount of coverage required by and otherwise in accordance with the terms of the transaction agreement. | X                 | X              | X              | X         | X                 | X             | X                  | X                     | X              | X | X |
| (d)(1)(v)                          | Accuracy of Information                            | Aggregation of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information.                                                                                                                          | X10               | X4             | X4             | X4        | X4                | X4            | X4                 | X4                    | X4             | X4 | X4 |
| Cash Collection and Administration |
| (d)(2)(i)                          | 2 Days to deposit Payments into Custodial Accounts | Payments on pool assets are deposited into the appropriate custodial bank accounts and related bank clearing accounts no more than two business days of receipt, or such other number of days specified in the transaction agreements.                           | X2                | X1             | X1             | X1        | X1                | X1            | X3                 | X1                    | X1             | X1 | X1 |
| (d)(2)(ii)                         | Wire Transfers                                     | Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.                                                                                                                                            | N/A               | N/A            | N/A            | N/A       | N/A               | N/A           | N/A                | N/A                   | N/A            | N/A | N/A |
| (d)(2)(iii)                        | Advances                                           | Advances of funds or guarantees regarding collections, cash flows or distributions, and any interest or other fees charged for such advances, are made, reviewed and approved as specified in the transaction agreements.                                        | X2                | X2             | X2             | X2        | X2                | X2            | X2                 | X1                    | X2             | X2 | X2 |
| (d)(2)(iv)                         | Commingling                                        | The related accounts for the transaction, such as cash reserve accounts or accounts established as a form of over collateralization, are separately maintained (e.g., with respect to commingling of cash) as set forth in the transaction agreements.           | X2                | X1             | X1             | X1        | X1                | X1            | X5                 | X1                    | X1             | X1 | X1 |

 

 

----

 

Exhibit A

| Regulation AB Criteria            | VSD 2017-PLT1                 | RPT 2017-ROSS                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | Bancorp 2017-CRE2 | CGMS 2017 MDDR | COLD 2017-ICE3 | 2016-225L | BANCORP 2016-CRE1 | GSMS 2016-GS3 | CGBAM 2015-SMRT MZ | Lone Star 2015 LSP-MZ | WFCG 2015-BXRP |
|-----------------------------------|-------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------|----------------|----------------|-----------|-------------------|---------------|--------------------|-----------------------|----------------|
| Section                           | Description                   | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |              |           |           |      |              |          |               |                  |           |   |   |
| (d)(2)(v)                         | Federally Insured Institution | Each custodial account is maintained at a federally insured depository institution as set forth in the transaction agreements. For purposes of this criterion, "federally insured depository institution" with respect to a foreign financial institution means a foreign financial institution that meets the requirements of §240.13k-1(b)(1) of this chapter. I.3 Each custodial account shall be maintained at a federally insured depository institution in trust for the applicable investor.                                                                                                                                                                                                      | X2                | X1             | X1             | X1        | X1                | X1            | X5                 | X1                    | X1             | X1 | X1 |
| (d)(2)(vi)                        | Unissued Checks               | Unissued checks are safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | X2                | X1             | X1             | X1        | X1                | X1            | X                  | X1                    | X1             | X1 | X1 |
| (d)(2)(vii)                       | Reconciliations               | Reconciliations are prepared on a monthly basis for all asset-backed securities related bank accounts, including custodial accounts and related bank clearing accounts. These reconciliations: (a) are mathematically accurate; (b) are prepared within 30 calendar days after the bank statement cutoff date, or such other number of days specified in the transaction agreements; (c) are reviewed and approved by someone other than the person who prepared the reconciliation; and (d) contain explanations for reconciling items. These reconciling items are resolved within 90 calendar days of their original identification, or such other number of days specified in the transaction agreements. | X2                | X1             | X1             | X1        | X1                | X1            | X5                 | X1                    | X1             | X1 | X1 |
| Investor Remittance and Reporting |
| (d)(3)(i)                         | Reports to the Investor       | Reports to investors, including those to be filed with the Commission, are maintained in accordance with the transaction agreements and applicable Commission requirements. Specifically, such reports:

(a) are prepared in accordance with timeframes and other terms set forth in the transaction agreements; (b) provide information calculated in accordance with the terms specified in the transaction agreements; (c) are filed with the Commission as required by its rules and regulations; and (d) agree with investors' or the trustee's records as to the total unpaid principal balance and number of pool assets serviced by the servicer.                                                     | N/A               | N/A            | N/A            | N/A       | N/A               | N/A           | N/A                | N/A                   | N/A            | N/A | N/A |
| (d)(3)(ii)                        | Investor Remittance           | Amounts due to investors are allocated and remitted in accordance with timeframes, distribution priority and other terms set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | N/A               | N/A            | N/A            | N/A       | N/A               | N/A           | N/A                | N/A                   | N/A            | N/A | N/A |
| (d)(3)(iii)                       | Investor's Records            | Disbursements made to an investor are posted within two business days to the servicer's investor records, or such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | N/A               | N/A            | N/A            | N/A       | N/A               | N/A           | N/A                | N/A                   | N/A            | N/A | N/A |

 

 

----

 

Exhibit A

| Regulation AB Criteria    | VSD 2017-PLT1                      | RPT 2017-ROSS                                                                                                                                                                                                                                                                                                                                                                                                          | Bancorp 2017-CRE2 | CGMS 2017 MDDR | COLD 2017-ICE3 | 2016-225L | BANCORP 2016-CRE1 | GSMS 2016-GS3 | CGBAM 2015-SMRT MZ | Lone Star 2015 LSP-MZ | WFCG 2015-BXRP |
|---------------------------|------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------|----------------|----------------|-----------|-------------------|---------------|--------------------|-----------------------|----------------|
| Section                   | Description                        | Criteria                                                                                                                                                                                                                                                                                                                                                                                                               |              |           |           |      |              |          |               |                  |           |   |   |
| (d)(3)(iv)                | Remittance and Bank Statements     | Amounts remitted to investors per the investor reports agree with cancelled checks, or other form of payment, or custodial bank statements.                                                                                                                                                                                                                                                                            | N/A               | N/A            | N/A            | N/A       | N/A               | N/A           | N/A                | N/A                   | N/A            | N/A | N/A |
| Pool Asset Administration |
| (d)(4)(i)                 | Collateral/Security on Pool Assets | Collateral or security on pool assets is maintained as required by the transaction agreements or related pool asset documents.                                                                                                                                                                                                                                                                                         | X2                | X1             | X1             | X1        | X1                | X1            | X6                 | X1                    | X1             | X1 | X1 |
| (d)(4)(ii)                | Safeguard Pool Assets              | Pool assets and related documents are safeguarded as required by the transaction agreements.                                                                                                                                                                                                                                                                                                                           | N/A               | N/A            | N/A            | N/A       | N/A               | N/A           | N/A                | N/A                   | N/A            | N/A | N/A |
| (d)(4)(iii)               | Changes to the Pool Assets         | Any additions, removals or substitutions to the asset pool are made, reviewed and approved in accordance with any conditions or requirements in the transaction agreements.                                                                                                                                                                                                                                            | X2                | X1             | X1             | X1        | X1                | X1            | X8                 | X1                    | X1             | X1 | X1 |
| (d)(4)(iv)                | Obligor's Payment Record           | Payments on pool assets, including any payoffs, made in accordance with the related pool asset documents are posted to the applicable servicer's obligor records maintained no more than two business days after receipt, or such other number of days specified in the transaction agreements, and allocated to principal, interest or other items (e.g. escrow) in accordance with the related pool asset documents. | N/A               | N/A            | N/A            | N/A       | N/A               | N/A           | N/A                | N/A                   | N/A            | N/A | N/A |
| (d)(4)(v)                 | Pool Asset Records Match UPB       | The servicers records regarding the pool assets agree with the servicer's records with respect to an obligor's unpaid principal balance.                                                                                                                                                                                                                                                                               | N/A               | N/A            | N/A            | N/A       | N/A               | N/A           | N/A                | N/A                   | N/A            | N/A | N/A |
| (d)(4)(vi)                | Loan Modifications                 | Changes with respect to the terms or status of an obligor's pool asset (e.g. loan modifications or re-agings) are made, reviewed and approved by authorized personnel in accordance with the transaction agreements and related pool asset documents.                                                                                                                                                                  | X9                | X1             | X1             | X1        | X1                | X1            | X                  | X1                    | X1             | X1 | X1 |
| (d)(4)(vii)               | Loss Mitigation Actions            | Loss mitigation or recovery actions (e.g., forbearance plans, modifications and deeds in lieu of foreclosure, foreclosures and repossessions, as applicable) are initiated, conducted and concluded in accordance with the timeframes or other requirements established by the transaction agreement.                                                                                                                  | X                 | X1             | X1             | X1        | X1                | X1            | X                  | X1                    | X1             | X1 | X1 |

 

 

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Exhibit A

| Regulation AB Criteria | VSD 2017-PLT1                                                | RPT 2017-ROSS                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | Bancorp 2017-CRE2 | CGMS 2017 MDDR | COLD 2017-ICE3 | 2016-225L | BANCORP 2016-CRE1 | GSMS 2016-GS3 | CGBAM 2015-SMRT MZ | Lone Star 2015 LSP-MZ | WFCG 2015-BXRP |
|------------------------|--------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------|----------------|----------------|-----------|-------------------|---------------|--------------------|-----------------------|----------------|
| Section                | Description                                                  | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |              |           |           |      |              |          |               |                  |           |   |   |
| (d)(4)(viii)           | Collection Efforts Documented                                | Records documenting collection efforts are maintained during the period a pool asset is delinquent in accordance with the transaction agreements. Such records are maintained on at least a monthly basis, or such other period specified in the transaction agreements, and describe the entity's activities in monitoring delinquent pool assets including, for example, phone calls, letters and payment rescheduling plans in cases where delinquency is deemed temporary (e.g., illness or unemployment).                            | X                 | X1             | X1             | X1        | X1                | X1            | X                  | X1                    | X1             | X1 | X1 |
| (d)(4)(ix)             | ARMs                                                         | Adjustments to interest rates or rates of return for pool assets with variable rates are computed based on the related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                              | N/A               | N/A            | N/A            | N/A       | N/A               | N/A           | N/A                | N/A                   | N/A            | N/A | N/A |
| (d)(4)(x)              | Escrow Funds                                                 | Regarding any funds held in trust for an obligor such funds are (a) analyzed, in accordance with the obligor's pool asset documents, on at least an annual basis, or such other period specified in the transaction agreements; (b) interest on such funds is paid, or credited, to obligors in accordance with applicable pool asset documents and state laws; and (c)returned to the obligor within 30 calendar days of full repayment of the related pool asset, or such other number of days specified in the transaction agreements. | N/A               | N/A            | N/A            | N/A       | N/A               | N/A           | N/A                | N/A                   | N/A            | N/A | N/A |
| (d)(4)(xi)             | Timely Payments                                              | Payments made on behalf of an obligor (such as tax or insurance payments) are made on or before the related penalty or expiration dates, as indicated on the appropriate bills or notices for such payments, provided that such support has been received by the servicer at least 30 calendar days prior to these dates, or such other number of days specified in the transaction agreements.                                                                                                                                           | N/A               | N/A            | N/A            | N/A       | N/A               | N/A           | N/A                | N/A                   | N/A            | N/A | N/A |
| (d)(4)(xii)            | Late Payment Penalties                                       | Any late payment penalties in connection with any payment to be made on behalf of an obligor are paid from the Servicer's funds and not charged to the obligor, unless the late payment was due to the obligor's error or omission.                                                                                                                                                                                                                                                                                                       | N/A               | N/A            | N/A            | N/A       | N/A               | N/A           | N/A                | N/A                   | N/A            | N/A | N/A |
| (d)(4)(xiii)           | Obligor's Records                                            | Disbursements made on behalf of an obligor are posted within two business days to the obligor's records maintained by the servicer, or such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                 | N/A               | N/A            | N/A            | N/A       | N/A               | N/A           | N/A                | N/A                   | N/A            | N/A | N/A |
| (d)(4)(xiv)            | Delinquencies, Charge-offs, and Other Uncollectible Accounts | Delinquencies, Charge-offs, and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                         | N/A               | N/A            | N/A            | N/A       | N/A               | N/A           | N/A                | N/A                   | N/A            | N/A | N/A |
| (d)(4)(xv)             | Any External Enhancement                                     | Any external enhancement or other support, identified in Item 1114(a)(1) through (3) or Item 1115 of this Regulation AB, is maintained as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                        | N/A               | N/A            | N/A            | N/A       | N/A               | N/A           | N/A                | N/A                   | N/A            | N/A | N/A |

 

 

----

 

Exhibit A

| Regulation AB Criteria             | CF TRUST 19 BOSS                                   | BANCORP 2019-CRES                                                                                                                                                                                                                                                | BBCMS 2019-CLP | BBCMS 2019-Core | BCMARK 2019-B12 | BX 2019-MMP | CAMB 2019-LIFE | CF2019-CFI | MTRO 2019-TECH | NOHT 2019-HNLA | NYT 2019-NYT |
|------------------------------------|----------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------|-----------------|-----------------|-------------|----------------|------------|----------------|----------------|--------------|
| Section                            | Description                                        | Criteria                                                                                                                                                                                                                                                         |           |            |            |        |           |       |           |           |         |   |   |
| General Servicing Considerations   |
| (d)(1)(i)                          | Policies and Procedures                            | Policies and procedures are instituted to monitor any performance or other triggers and events of default in accordance with the transaction agreement.                                                                                                          | X              | X               | X               | X           | X              | X          | X              | X              | X            | X | X |
| (d)(1)(ii)                         | Policies and Procedures (vendors)                  | If any material servicing activities are outsourced to third parties, policies and procedures are instituted to monitor the third party's performance and compliance with such servicing activities.                                                             | X7             | X7              | X7              | X7          | X7             | X7         | X7             | X7             | X7           | X7 | X7 |
| (d)(1)(iii)                        | Back-up Servicer                                   | Any requirements in the transaction agreements to maintain a back-up servicer for the pool assets are maintained.                                                                                                                                                | N/A            | N/A             | N/A             | N/A         | N/A            | N/A        | N/A            | N/A            | N/A          | N/A | N/A |
| (d)(1)(iv)                         | Fidelity Bond                                      | A fidelity bond and errors and omissions policy is in effect on the party participating in the servicing function throughout the reporting period in the amount of coverage required by and otherwise in accordance with the terms of the transaction agreement. | X              | X               | X               | X           | X              | X          | X              | X              | X            | X | X |
| (d)(1)(v)                          | Accuracy of Information                            | Aggregation of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information.                                                                                                                          | X4             | X4              | X4              | X4          | X4             | X4         | X4             | X4             | X4           | X4 | X4 |
| Cash Collection and Administration |
| (d)(2)(i)                          | 2 Days to deposit Payments into Custodial Accounts | Payments on pool assets are deposited into the appropriate custodial bank accounts and related bank clearing accounts no more than two business days of receipt, or such other number of days specified in the transaction agreements.                           | X1             | X1              | X1              | X1          | X1             | X1         | X1             | X1             | X1           | X1 | X1 |
| (d)(2)(ii)                         | Wire Transfers                                     | Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.                                                                                                                                            | N/A            | N/A             | N/A             | N/A         | N/A            | N/A        | N/A            | N/A            | N/A          | N/A | N/A |
| (d)(2)(iii)                        | Advances                                           | Advances of funds or guarantees regarding collections, cash flows or distributions, and any interest or other fees charged for such advances, are made, reviewed and approved as specified in the transaction agreements.                                        | X1             | X2              | X2              | X2          | X2             | X2         | X2             | X1             | X2           | X2 | X2 |
| (d)(2)(iv)                         | Commingling                                        | The related accounts for the transaction, such as cash reserve accounts or accounts established as a form of over collateralization, are separately maintained (e.g., with respect to commingling of cash) as set forth in the transaction agreements.           | X1             | X1              | X1              | X1          | X1             | X1         | X1             | X1             | X1           | X1 | X1 |

 

 

----

 

Exhibit A

| Regulation AB Criteria            | CF TRUST 19 BOSS              | BANCORP 2019-CRES                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | BBCMS 2019-CLP | BBCMS 2019-Core | BCMARK 2019-B12 | BX 2019-MMP | CAMB 2019-LIFE | CF2019-CFI | MTRO 2019-TECH | NOHT 2019-HNLA | NYT 2019-NYT |
|-----------------------------------|-------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------|-----------------|-----------------|-------------|----------------|------------|----------------|----------------|--------------|
| Section                           | Description                   | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |           |            |            |        |           |       |           |           |         |   |   |
| (d)(2)(v)                         | Federally Insured Institution | Each custodial account is maintained at a federally insured depository institution as set forth in the transaction agreements. For purposes of this criterion, "federally insured depository institution" with respect to a foreign financial institution means a foreign financial institution that meets the requirements of §240.13k-1(b)(1) of this chapter. I.3 Each custodial account shall be maintained at a federally insured depository institution in trust for the applicable investor.                                                                                                                                                                                                      | X1             | X1              | X1              | X1          | X1             | X1         | X1             | X1             | X1           | X1 | X1 |
| (d)(2)(vi)                        | Unissued Checks               | Unissued checks are safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | X1             | X1              | X1              | X1          | X1             | X1         | X1             | X1             | X1           | X1 | X1 |
| (d)(2)(vii)                       | Reconciliations               | Reconciliations are prepared on a monthly basis for all asset-backed securities related bank accounts, including custodial accounts and related bank clearing accounts. These reconciliations: (a) are mathematically accurate; (b) are prepared within 30 calendar days after the bank statement cutoff date, or such other number of days specified in the transaction agreements; (c) are reviewed and approved by someone other than the person who prepared the reconciliation; and (d) contain explanations for reconciling items. These reconciling items are resolved within 90 calendar days of their original identification, or such other number of days specified in the transaction agreements. | X1             | X1              | X1              | X1          | X1             | X1         | X1             | X1             | X1           | X1 | X1 |
| Investor Remittance and Reporting |
| (d)(3)(i)                         | Reports to the Investor       | Reports to investors, including those to be filed with the Commission, are maintained in accordance with the transaction agreements and applicable Commission requirements. Specifically, such reports:

(a) are prepared in accordance with timeframes and other terms set forth in the transaction agreements; (b) provide information calculated in accordance with the terms specified in the transaction agreements; (c) are filed with the Commission as required by its rules and regulations; and (d) agree with investors' or the trustee's records as to the total unpaid principal balance and number of pool assets serviced by the servicer.                                                     | N/A            | N/A             | N/A             | N/A         | N/A            | N/A        | N/A            | N/A            | N/A          | N/A | N/A |
| (d)(3)(ii)                        | Investor Remittance           | Amounts due to investors are allocated and remitted in accordance with timeframes, distribution priority and other terms set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | N/A            | N/A             | N/A             | N/A         | N/A            | N/A        | N/A            | N/A            | N/A          | N/A | N/A |
| (d)(3)(iii)                       | Investor's Records            | Disbursements made to an investor are posted within two business days to the servicer's investor records, or such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | N/A            | N/A             | N/A             | N/A         | N/A            | N/A        | N/A            | N/A            | N/A          | N/A | N/A |

 

 

----

 

Exhibit A

| Regulation AB Criteria    | CF TRUST 19 BOSS                   | BANCORP 2019-CRES                                                                                                                                                                                                                                                                                                                                                                                                      | BBCMS 2019-CLP | BBCMS 2019-Core | BCMARK 2019-B12 | BX 2019-MMP | CAMB 2019-LIFE | CF2019-CFI | MTRO 2019-TECH | NOHT 2019-HNLA | NYT 2019-NYT |
|---------------------------|------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------|-----------------|-----------------|-------------|----------------|------------|----------------|----------------|--------------|
| Section                   | Description                        | Criteria                                                                                                                                                                                                                                                                                                                                                                                                               |           |            |            |        |           |       |           |           |         |   |   |
| (d)(3)(iv)                | Remittance and Bank Statements     | Amounts remitted to investors per the investor reports agree with cancelled checks, or other form of payment, or custodial bank statements.                                                                                                                                                                                                                                                                            | N/A            | N/A             | N/A             | N/A         | N/A            | N/A        | N/A            | N/A            | N/A          | N/A | N/A |
| Pool Asset Administration |
| (d)(4)(i)                 | Collateral/Security on Pool Assets | Collateral or security on pool assets is maintained as required by the transaction agreements or related pool asset documents.                                                                                                                                                                                                                                                                                         | X1             | X1              | X1              | X1          | X1             | X1         | X1             | X1             | X1           | X1 | X1 |
| (d)(4)(ii)                | Safeguard Pool Assets              | Pool assets and related documents are safeguarded as required by the transaction agreements.                                                                                                                                                                                                                                                                                                                           | N/A            | N/A             | N/A             | N/A         | N/A            | N/A        | N/A            | N/A            | N/A          | N/A | N/A |
| (d)(4)(iii)               | Changes to the Pool Assets         | Any additions, removals or substitutions to the asset pool are made, reviewed and approved in accordance with any conditions or requirements in the transaction agreements.                                                                                                                                                                                                                                            | X1             | X1              | X1              | X1          | X1             | X1         | X1             | X1             | X1           | X1 | X1 |
| (d)(4)(iv)                | Obligor's Payment Record           | Payments on pool assets, including any payoffs, made in accordance with the related pool asset documents are posted to the applicable servicer's obligor records maintained no more than two business days after receipt, or such other number of days specified in the transaction agreements, and allocated to principal, interest or other items (e.g. escrow) in accordance with the related pool asset documents. | N/A            | N/A             | N/A             | N/A         | N/A            | N/A        | N/A            | N/A            | N/A          | N/A | N/A |
| (d)(4)(v)                 | Pool Asset Records Match UPB       | The servicers records regarding the pool assets agree with the servicer's records with respect to an obligor's unpaid principal balance.                                                                                                                                                                                                                                                                               | N/A            | N/A             | N/A             | N/A         | N/A            | N/A        | N/A            | N/A            | N/A          | N/A | N/A |
| (d)(4)(vi)                | Loan Modifications                 | Changes with respect to the terms or status of an obligor's pool asset (e.g. loan modifications or re-agings) are made, reviewed and approved by authorized personnel in accordance with the transaction agreements and related pool asset documents.                                                                                                                                                                  | X1             | X1              | X1              | X1          | X1             | X1         | X1             | X1             | X1           | X1 | X1 |
| (d)(4)(vii)               | Loss Mitigation Actions            | Loss mitigation or recovery actions (e.g., forbearance plans, modifications and deeds in lieu of foreclosure, foreclosures and repossessions, as applicable) are initiated, conducted and concluded in accordance with the timeframes or other requirements established by the transaction agreement.                                                                                                                  | X1             | X1              | X1              | X1          | X1             | X1         | X1             | X1             | X1           | X1 | X1 |

 

 

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Exhibit A

| Regulation AB Criteria | CF TRUST 19 BOSS                                             | BANCORP 2019-CRES                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | BBCMS 2019-CLP | BBCMS 2019-Core | BCMARK 2019-B12 | BX 2019-MMP | CAMB 2019-LIFE | CF2019-CFI | MTRO 2019-TECH | NOHT 2019-HNLA | NYT 2019-NYT |
|------------------------|--------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------|-----------------|-----------------|-------------|----------------|------------|----------------|----------------|--------------|
| Section                | Description                                                  | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |           |            |            |        |           |       |           |           |         |   |   |
| (d)(4)(viii)           | Collection Efforts Documented                                | Records documenting collection efforts are maintained during the period a pool asset is delinquent in accordance with the transaction agreements. Such records are maintained on at least a monthly basis, or such other period specified in the transaction agreements, and describe the entity's activities in monitoring delinquent pool assets including, for example, phone calls, letters and payment rescheduling plans in cases where delinquency is deemed temporary (e.g., illness or unemployment).                            | X1             | X1              | X1              | X1          | X1             | X1         | X1             | X1             | X1           | X1 | X1 |
| (d)(4)(ix)             | ARMs                                                         | Adjustments to interest rates or rates of return for pool assets with variable rates are computed based on the related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                              | N/A            | N/A             | N/A             | N/A         | N/A            | N/A        | N/A            | N/A            | N/A          | N/A | N/A |
| (d)(4)(x)              | Escrow Funds                                                 | Regarding any funds held in trust for an obligor such funds are (a) analyzed, in accordance with the obligor's pool asset documents, on at least an annual basis, or such other period specified in the transaction agreements; (b) interest on such funds is paid, or credited, to obligors in accordance with applicable pool asset documents and state laws; and (c)returned to the obligor within 30 calendar days of full repayment of the related pool asset, or such other number of days specified in the transaction agreements. | N/A            | N/A             | N/A             | N/A         | N/A            | N/A        | N/A            | N/A            | N/A          | N/A | N/A |
| (d)(4)(xi)             | Timely Payments                                              | Payments made on behalf of an obligor (such as tax or insurance payments) are made on or before the related penalty or expiration dates, as indicated on the appropriate bills or notices for such payments, provided that such support has been received by the servicer at least 30 calendar days prior to these dates, or such other number of days specified in the transaction agreements.                                                                                                                                           | N/A            | N/A             | N/A             | N/A         | N/A            | N/A        | N/A            | N/A            | N/A          | N/A | N/A |
| (d)(4)(xii)            | Late Payment Penalties                                       | Any late payment penalties in connection with any payment to be made on behalf of an obligor are paid from the Servicer's funds and not charged to the obligor, unless the late payment was due to the obligor's error or omission.                                                                                                                                                                                                                                                                                                       | N/A            | N/A             | N/A             | N/A         | N/A            | N/A        | N/A            | N/A            | N/A          | N/A | N/A |
| (d)(4)(xiii)           | Obligor's Records                                            | Disbursements made on behalf of an obligor are posted within two business days to the obligor's records maintained by the servicer, or such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                 | N/A            | N/A             | N/A             | N/A         | N/A            | N/A        | N/A            | N/A            | N/A          | N/A | N/A |
| (d)(4)(xiv)            | Delinquencies, Charge-offs, and Other Uncollectible Accounts | Delinquencies, Charge-offs, and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                         | N/A            | N/A             | N/A             | N/A         | N/A            | N/A        | N/A            | N/A            | N/A          | N/A | N/A |
| (d)(4)(xv)             | Any External Enhancement                                     | Any external enhancement or other support, identified in Item 1114(a)(1) through (3) or Item 1115 of this Regulation AB, is maintained as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                        | N/A            | N/A             | N/A             | N/A         | N/A            | N/A        | N/A            | N/A            | N/A          | N/A | N/A |

 

 

 

----

 

Key

 

|                                                                                                                                                                                                       |                                                                                                                                                                                                                                                                         |
|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| X1                                                                                                                                                                                                    | This criteria is applicable for the securitization; however, there were no loans serviced under this securitization during the reporting period.                                                                                                                        |
| X2                                                                                                                                                                                                    | With respect to Applicable Servicing Criteria, the securitization was not in scope based on the transaction agreement.                                                                                                                                                  |
| X3                                                                                                                                                                                                    | With respect to item 1122(d)(2)(i), this criteria is applicable for the securitization; however, there was no cash collected for loans under the securitization during the reporting period.                                                                            |
| X4                                                                                                                                                                                                    | With respect to item 1122(d)(1)(v), this criteria is applicable for the securitization; however, there was no aggregation of information related to reporting to external parties.                                                                                      |
| X5                                                                                                                                                                                                    | With respect to item 1122(d)(2)(iv), 1122(d)(2)(v) and 1122(d)(2)(vii), the criteria is applicable for the securitization; however, there were no custodial bank accounts maintained under the securitization during the reporting period.                              |
| X6                                                                                                                                                                                                    | With respect to item 1122(d)(4)(i), the criteria is applicable for the securitization; however, as special servicer, Trimont was not responsible for maintaining collateral or security on pool assets under the securitization during the reporting period.            |
| X7                                                                                                                                                                                                    | With respect to item 1122(d)(1)(ii), this criteria is applicable for the securitization; however, there were no material servicing activities outsourced to third parties under this securitization during the reporting period.                                        |
| X8                                                                                                                                                                                                    | With respect to item 1122(d)(4)(iii), the criteria is applicable for the securitization; however, there were no additions, removals, or substitutions to the pool assets under the securitization during the reporting period.                                          |
| X9                                                                                                                                                                                                    | With respect to item 1122(d)(4)(vi), the criteria is applicable for the securitization; however, there were no changes to the terms or status of an obligor's pool assets under the securitization during the reporting period.                                         |
| X10                                                                                                                                                                                                   | With respect to item 1122(d)(1)(v), this criteria is applicable for the securitization; however, is only applicable in Trimont's role as primary servicer. As such, there was no aggregation of information related to reporting to external parties for this platform. |
| With respect to Applicable Servicing Criteria cells in Exhibit A that are denoted with an "N/A", per review of the respective servicing agreement, the criteria was not in scope for the transaction. |

 

 

----

 

Exhibit B

| Name                  | Transaction                                                                                                                                                             | Period of Service                   |
|-----------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------|
| CGBAM 2015-SMRT MZ    | Special Servicer for Commercial Mortgage Pass-Through Certificates Series 2014-TISH pursuant to the Pooling and Servicing Agreement dated April 28, 2015                | January 1, 2019 - December 31, 2019 |
| Lone Star 2015 LSP-MZ | Special Servicer for Commercial Mortgage Pass-Through Certificates Series Lone Star 2015 LSP-MZ pursuant to the Pooling and Servicing Agreement dated November 13, 2015 | January 1, 2019 - December 31, 2019 |
| WFCG 2015-BXRP        | Special Servicer for Commercial Mortgage Pass-Through Certificates Series WFCG 2015-BXRP pursuant to the Pooling and Servicing Agreement dated April 1, 2015            | January 1, 2019 - December 31, 2019 |
| 2016-225L             | Special Servicer for Commercial Mortgage Pass-Through Certificates Series 2016-225L pursuant to the Pooling and Servicing Agreement dated February 6, 2016              | January 1, 2019 - December 31, 2019 |
| BANCORP 2016-CRE1     | Special Servicer for Commercial Mortgage Pass-Through Certificates Series BANCORP 2016-CRE1 pursuant to the Pooling and Servicing Agreement dated December 6, 2016      | January 1, 2019 - December 31, 2019 |
| GSMS 2016-GS3         | Special Servicer for Commercial Mortgage Pass-Through Certificates Series GSMS 2016-GS3 pursuant to the Pooling and Servicing Agreement dated September 1, 2016         | January 1, 2019 - December 31, 2019 |
| Bancorp 2017-CRE2     | Special Servicer for Commercial Mortgage Pass-Through Certificates Series Bancorp 2017-CRE2 pursuant to the Pooling and Servicing Agreement dated August 30, 2017       | January 1, 2019 - December 31, 2019 |
| CGMS 2017 MDDR        | Special Servicer for Commercial Mortgage Pass-Through Certificates Series CGMS 2017 MDDR pursuant to the Pooling and Servicing Agreement dated July 6, 2017             | January 1, 2019 - December 31, 2019 |
| COLD 2017-ICE3        | Special Servicer for Commercial Mortgage Pass-Through Certificates Series COLD 2017-ICE3 pursuant to the Pooling and Servicing Agreement dated April 28, 2017           | January 1, 2019 - December 31, 2019 |
| RPT 2017-ROSS         | Special Servicer for Commercial Mortgage Pass-Through Certificates Series RPT 2017-ROSS pursuant to the Pooling and Servicing Agreement dated June 30, 2017             | January 1, 2019 - December 31, 2019 |
| CPLV TRUST 2017-VICI  | Special Servicer for Commercial Mortgage Pass-Through Certificates Series CPLV 2017-VICI pursuant to the Pooling and Servicing Agreement dated November 30, 2017        | January 1, 2019 - December 31, 2019 |
| MSC 2017-ASHF         | Special Servicer for Commercial Mortgage Pass-Through Certificates Series MSC 2017-ASHF pursuant to the Pooling and Servicing Agreement dated December 9, 2017          | January 1, 2019 - December 31, 2019 |
| CSMC 2017-PFHP        | Special Servicer for Commercial Mortgage Pass-Through Certificates Series CSMC 2017-PFHP pursuant to the Pooling and Servicing Agreement dated December 19, 2017        | January 1, 2019 - December 31, 2019 |
| VSD 2017-PLT1         | Special Servicer for Commercial Mortgage Pass-Through Certificates Series VSD 2017-PLT1 pursuant to the Pooling and Servicing Agreement dated March 10, 2017            | January 1, 2019 - January 24, 2019  |

 

 

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Exhibit B

| Name              | Transaction                                                                                                                                                          | Period of Service                     |
|-------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------|
| JPMC 2018-MBR MZ  | Special Servicer for Commercial Mortgage Pass-Through Certificates Series JPMC 2018-MBR MZ pursuant to the Pooling and Servicing Agreement dated August 22, 2018     | January 1, 2019 - December 31, 2019   |
| GSMS 2018-GS10    | Special Servicer for Commercial Mortgage Pass-Through Certificates Series GSMS 2018-GS10 pursuant to the Pooling and Servicing Agreement dated July 1, 2018          | January 1, 2019 - December 31, 2019   |
| Bancorp 2018-CRE4 | Special Servicer for Commercial Mortgage Pass-Through Certificates Series Bancorp 2018-CRE4 pursuant to the Pooling and Servicing Agreement dated September 27, 2018 | January 1, 2019 - December 31, 2019   |
| Bancorp 2018-CRE3 | Special Servicer for Commercial Mortgage Pass-Through Certificates Series Bancorp 2018-CRE3 pursuant to the Pooling and Servicing Agreement dated March 29, 2018     | January 1, 2019 - December 31, 2019   |
| AHT 2018 Keys     | Special Servicer for Commercial Mortgage Pass-Through Certificates Series AHT 2018 Keys pursuant to the Pooling and Servicing Agreement dated July 16, 2018          | January 1, 2019 - December 31, 2019   |
| GSMS 2018-TWR     | Special Servicer for Commercial Mortgage Pass-Through Certificates Series GSMS 2018-TWR pursuant to the Pooling and Servicing Agreement dated July 31, 2018          | January 1, 2019 - December 31, 2019   |
| COMM 2012-CCRE2   | Special Servicer for Commercial Mortgage Pass-Through Certificates Series COMM 2012-CCRE2 pursuant to the Pooling and Servicing Agreement dated August 1, 2018       | January 1, 2019 - December 31, 2019   |
| JPMCC 2018-MINN   | Special Servicer for Commercial Mortgage Pass-Through Certificates Series JPMCC 2018-MINN pursuant to the Pooling and Servicing Agreement dated December 7, 2018     | January 1, 2019 - December 31, 2019   |
| CF TRUST 19 BOSS  | Special Servicer for Commercial Mortgage Pass-Through Certificates Series CF-TRUST 19 BOSS pursuant to the Pooling and Servicing Agreement dated November 26, 2019   | November 26, 2019 - December 31, 2019 |
| BANCORP 2019-CRES | Special Servicer for Commercial Mortgage Pass-Through Certificates Series BANCORP 2019-CRES pursuant to the Pooling and Servicing Agreement dated March 28, 2019     | March 28, 2019 - December 31, 2019    |
| BBCMS 2019-CLP    | Special Servicer for Commercial Mortgage Pass-Through Certificates Series BBCMS 2019-CLP pursuant to the Pooling and Servicing Agreement dated February 27, 2019     | February 27, 2019 - December 31, 2019 |
| BBCMS 2019-Core   | Special Servicer for Commercial Mortgage Pass-Through Certificates Series BBCMS 2019-Core pursuant to the Pooling and Servicing Agreement dated March 15, 2019       | March 15, 2019 - December 31, 2019    |
| BCMARK 2019-B12   | Special Servicer for Commercial Mortgage Pass-Through Certificates Series BCMARK 2019-B12 pursuant to the Pooling and Servicing Agreement dated August 1, 2019       | August 1, 2019 - December 31, 2019    |
| BX 2019-MMP       | Special Servicer for Commercial Mortgage Pass-Through Certificates Series BX 2019-MMP pursuant to the Pooling and Servicing Agreement dated August 29, 2019          | August 29, 2019 - December 31, 2019   |
| CAMB 2019-LIFE    | Special Servicer for Commercial Mortgage Pass-Through Certificates Series CAMB 2019-LIFE pursuant to the Pooling and Servicing Agreement dated January 9, 2019       | January 9, 2019 - December 31, 2019   |
| CF 2019- CFI      | Special Servicer for Commercial Mortgage Pass-Through Certificates Series CF 2019-CFI pursuant to the Pooling and Servicing Agreement dated April 1, 2019            | April 1, 2019 - December 31, 2019     |
| MTRO 2019-TECH    | Special Servicer for Commercial Mortgage Pass-Through Certificates Series MTRO 2019-TECH pursuant to the Pooling and Servicing Agreement dated February 9, 2019      | February 9, 2019 - December 31, 2019  |

 

 

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Exhibit B

| Name           | Transaction                                                                                                                                                   | Period of Service                     |
|----------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------|
| NOHT 2019-HNLA | Special Servicer for Commercial Mortgage Pass-Through Certificates Series NOHT 2019-HNLA pursuant to the Pooling and Servicing Agreement dated May 15, 2019   | May 15, 2019 - December 31, 2019      |
| NYT 2019-NYT   | Special Servicer for Commercial Mortgage Pass-Through Certificates Series NYT 2019-NYT pursuant to the Pooling and Servicing Agreement dated January 30, 2019 | January 30,, 2019 - December 31, 2019 |