**UNITED STATESSECURITIES AND EXCHANGE COMMISSION**

**WASHINGTON,D.C. 20549**

**FORM 10‐K**

(Mark one)

**/X/ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIESEXCHANGE ACT OF 1934**

**    For the fiscal year endedDecember 31, 2022OR**

**//TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIESEXCHANGE ACT OF 1934**

**For the transition period from****            ****to****            **

 

 

 

**Commission file number:333-227446-04**

 

**Central Index Key Number of the issuing entity:****0001773339**

 

**Morgan Stanley Capital ITrust 2019-H6**

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

 

**Central Index Key Number of the depositor:0001547361**

 

**Morgan Stanley Capital I Inc.**

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

 

**Central Index Key Number of the sponsor:0001541557**

 

**Morgan Stanley MortgageCapital Holdings LLC**

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

 

**Central Index Key Number of the sponsor:0001624053**

 

**Argentic Real Estate FinanceLLC**

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

 

**Central Index Key Number of the sponsor:0001558761**

 

**Cantor Commercial Real EstateLending, L.P.**

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

** **

**Central Index Key Number of the sponsor:0001548405**

 

**Starwood Mortgage Capital LLC**

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

 ** **

 

| **New York**                                                        | **38-4117325**

**38-4117326**

**38-7221311** |
|---------------------------------------------------------------------|------------------------------------------------|
| **(State or other jurisdiction of incorporation or  organization)** | **(I.R.S. Employer Identification Numbers)**   |

 

**c/o Wells Fargo Bank, N.A.**

**9062 Old Annapolis Road**

** Columbia, MD**

**(Address of principal executive offices)**

 

**21045**

**(Zip Code)**

 

**Telephone number, including area code:**

**(410) 884‐2000**

Securitiesregistered pursuant to Section 12(b) of the Act:

 

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

 

 

Securitiesregistered pursuant to Section 12(g) of the Act:

 

  NONE.

 

Indicateby check mark if the registrant is a well-known seasoned issuer, as defined inRule 405 of the Securities Act.

 

  Yes___ No X

 

Indicateby check mark if the registrant is not required to file reports pursuant toSection 13 or Section 15(d) of the Act.

 

  Yes___ No X

 

Note- Checking the box above will not relieve any registrant required to filereports pursuant to Section 13 or 15(d) of the Exchange Act from theirobligations under those Sections.

 

Indicate by check mark whether the registrant (1) has filed all reportsrequired to be filed by Section 13 or 15(d) of the Securities Exchange Act of1934 during the preceding 12 months (or for such shorter period that theregistrant was required to file such reports), and (2) has been subject to suchfiling requirements for the past 90 days.

 

  YesX No ___

 

Indicateby check mark whether the registrant has submitted electronically everyInteractive Data File required to be submitted pursuant to Rule 405 ofRegulation S-T (Section 232.405 of this chapter) during the preceding 12 months(or for such shorter period that the registrant was required to submit suchfiles).

 

  Notapplicable.

  

Indicateby check mark whether the registrant is a large accelerated filer, anaccelerated filer, a non-accelerated filer, a smaller reporting company, oremerging growth company. See the definitions of "large acceleratedfiler", "accelerated filer," "smaller reportingcompany," and “emerging growth company” in Rule 12b-2 of the Exchange Act.

 

 Largeaccelerated filer ___ Accelerated filer ___ Non-accelerated filer X (Do not check if a smaller reporting company)Smaller reporting company ___

 

Emerginggrowth company ___

 

Ifan emerging growth company, indicate by check mark if the registrant haselected not to use the extended transition period for complying with any new orrevised financial accounting standards provided pursuant to Section 13(a) ofthe Ex­change Act.

 

  Notapplicable.

 

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

 

  Notapplicable.

 

If securities are registered pursuant to Section 12(b)of the Act, indicate by check mark whether the financial statements of the

registrantincluded in the filing reflect the correction of an error to previously issuedfinancial statements.

 

Not applicable.

 

Indicateby check mark whether any of those error corrections are restatements thatrequired a recovery analysis of incentive-based compensation received by any ofthe registrant’s executive officers during the relevant recovery periodpursuant to §240.10D-1(b).

 

Not applicable.

 

Indicateby check mark whether the registrant is a shell company (as defined in Rule12b-2 of the Act).

 

  Yes___ No X

 

Statethe aggregate market value of the voting and non-voting common equity held by non-affiliatescomputed by reference to the price at which the common equity was last sold, orthe average bid and asked price of such common equity, as of the last businessday of the registrant's most recently completed second fiscal quarter.

 

  Notapplicable.

 

Indicateby check mark whether the registrant has filed all documents and reportsrequired to be filed by Section 12, 13 or 15(d) of the Securities Exchange Actof 1934 subsequent to the distribution of securities under a plan confirmed bya court.

 

  Notapplicable.

 

Indicatethe number of shares outstanding of each of the registrant's classes of commonstock, as of the latest practicable date.

 

  Notapplicable.

 

DOCUMENTSINCORPORATED BY REFERENCE

 

Listhereunder the following documents if incorporated by reference and the Part ofthe Form 10-K (e.g., Part I, Part II, etc.) into which the document isincorporated: (1)Any annual report to security holders; (2) Any proxy orinformation statement; and (3)Any prospectus filed pursuant to Rule 424(b) or(c) under the Securities Act of 1933. The listed documents should be clearlydescribed for identification purposes (e.g., annual report to security holdersfor fiscal year ended December 24, 1980).

 

  Notapplicable.

 

**EXPLANATORY NOTES**

 

The MSC 2019-H6 mortgage pool includes thefollowing mortgage loans, each of which is serviced pursuant to a separatepooling and servicing agreement (each, an “Outside Pooling and ServicingAgreement”):

 

•   the 9201 West SunsetBoulevard mortgage loan and the Westin Atlanta Airport mortgage loan, which areserviced pursuant to the BANK 2019-BNK18 pooling and servicing agreementattached hereto as Exhibit 4.2;

 

•   the ILPT Hawaii Portfoliomortgage loan, which is serviced pursuant to the ILPT 2019-SURF trust andservicing agreement attached hereto as Exhibit 4.3;

 

•   the Tower 28 mortgage loan,which is serviced pursuant to the BANK 2019-BNK17 pooling and servicingagreement attached hereto as Exhibit 4.4;

 

•   The Block Northway mortgageloan, which is serviced pursuant to the BBCMS 2019-C3 pooling and servicingagreement attached hereto as Exhibit 4.5;

 

•   the 65 Broadway mortgage loanand the AC by Marriott San Jose mortgage loan, which are serviced pursuant tothe CF 2019-CF1 pooling and servicing agreement attached hereto as Exhibit 4.6;

  

•   the Shelbourne GlobalPortfolio II mortgage loan, which is serviced pursuant to the BBCMS 2018-C2pooling and servicing agreement attached hereto as Exhibit 4.7;

 

•   the 3 Columbus Circlemortgage loan, which is serviced pursuant to the Benchmark 2019-B10 pooling andservicing agreement attached hereto as Exhibit 4.8; and

 

•   the SoCal Retail Portfoliomortgage loan, which is serviced pursuant to the MSC 2019-H7 pooling andservicing agreement attached hereto as Exhibit 4.9.

 

Except as set forth below, each of theparties to each pooling and servicing agreement listed in the Exhibit Indexboth (1) participates in the servicing function for purposes of Item 1122 ofRegulation AB and (2) constitutes a servicer that meets the criteria in Item1108(a)(2)(i) through (iii) of Regulation AB for purposes of Item 1123 ofRegulation AB:

 

•   The trustee under a poolingand servicing agreement has a nominal role with respect to the mortgage poolsecuritized pursuant to such pooling and servicing agreement.  Thetrustee’s only servicing function is the contingent obligation to make certainadvances if the master servicer under such pooling and servicing agreementfails to do so, while all other servicing functions are performed by otherparties.  The trustee under each of the pooling and servicing agreementslisted in the Exhibit Index has confirmed to the registrant that it has notmade any such contingent advances during the reporting period, and consequently,each such trustee does not participate in the servicing function for purposesof Item 1122 of Regulation AB, nor does it perform the functions of a servicerfor purposes of the definition of “servicer” under Item 1101 of Regulation ABor for purposes of Item 1123 of Regulation AB.

 

•   The certificate administratorunder a pooling and servicing agreement performs various payment administrationfunctions solely for the securitization governed by such pooling and servicingagreement and the mortgage pool securitized pursuant to such pooling andservicing agreement and does not have any obligations with respect to any othertransaction.  Consequently, the certificate administrator under an OutsidePooling and Servicing Agreement does not participate in the servicing functionfor purposes of Item 1122 of Regulation AB, nor does it perform the functionsof a servicer for purposes of the definition of “servicer” under Item 1101 ofRegulation AB or for purposes of Item 1123 of Regulation AB.

 

•   The operating advisor under apooling and servicing agreement represents the interests of seniorcertificateholders in the transaction governed by such pooling and servicingagreement and is responsible for monitoring the performance of the specialservicer under such pooling and servicing agreement and producing certainreports to certificateholders relating to the resolution of the mortgage poolsecuritized pursuant to such pooling and servicing agreement.  Theoperating advisor under a pooling and servicing agreement does not have anyobligations with respect to any other transaction and is solely obligated toperform loan reporting functions with respect to the securitization governed bysuch pooling and servicing agreement.  Consequently, the operating advisorunder an Outside Pooling and Servicing Agreement neither participates in theservicing function for purposes of Item 1122 of Regulation AB nor performs thefunctions of a servicer for purposes of the definition of “servicer” under Item1101 of Regulation AB or for purposes of Item 1123 of Regulation AB.  Inaddition, while the operating advisor under a pooling and servicing agreementhas certain reporting obligations in respect of the related mortgage pool, ithas no obligation to collect or disburse funds in respect of the mortgage poolor to administer any of the underlying mortgage loans.  Consequently, theoperating advisor under a pooling and servicing agreement participates in theservicing function for purposes of Item 1122 of Regulation AB, but is notresponsible for the “management or collection of the pool assets or makingallocations or distributions to holders of the asset-backed securities” withinthe meaning of “servicer” under Item 1101 of Regulation AB and does not performthe functions of a servicer for purposes of Item 1123 of Regulation AB. 

 

•   The asset representations reviewer under a poolingand servicing agreement has a limited obligation to review certain delinquentmortgage loans after a specified delinquency threshold has been met and therequired percentage of certificateholders vote to direct a review of suchdelinquent mortgage loans, and has no obligation to collect or disburse fundsin respect of the mortgage pool, to administer any of the underlying mortgageloans or to perform any servicing function.  Consequently, the assetrepresentations reviewer under a pooling and servicing agreement does notparticipate in the servicing function for purposes of Item 1122 of RegulationAB, is not responsible for the “management or collection of the pool assets ormaking allocations or distributions to holders of the asset-backed securities”within the meaning of “servicer” under Item 1101 of Regulation AB and does notperform the functions of a servicer for purposes of Item 1123 of Regulation AB.

•   NCB, N.A. as NCB master servicer and NCB specialservicer under the BANK 2019-BNK18 pooling and servicing agreement, only hasobligations in respect of certain mortgage loans sold to the BANK 2019-BNK18securitization trust by NCB, N.A.  Situs Holdings, LLC, as NewportCorporate Center special servicer under the BANK 2019-BNK18 pooling andservicing agreement, only has obligations in respect of the Newport CorporateCenter mortgage loan securitized thereunder.  Each such party has no obligationswith respect to any mortgage loan included in the MSC 2019-H6 mortgage pool andtherefore in such capacity does not constitute a reporting “servicing functionparticipant” for purposes of Item 1122 of Regulation AB, as specified in theInstruction 3 to Item 1122, and does not constitute a reporting “servicer” forpurposes of Item 1123 of Regulation AB, as specified in the Instruction to Item1123.

•   KeyBankNational Association is the master servicer under theCF 2019-CF1 pooling and servicing agreement, pursuant to which the 65 Broadwaymortgage loan and the AC by Marriott San Jose mortgage loan are serviced, andthe master servicer under the Benchmark 2019-B10 pooling and servicingagreement, pursuant to which the 3 Columbus Circle mortgage loan isserviced.  Because KeyBank National Association is not the MSC 2019-H6 master servicer, is not affiliatedwith any sponsor and services only the 65 Broadway mortgage loan, the AC byMarriott San Jose mortgage loan and the 3 Columbus Circle mortgage loan, whichcollectively constitute more than 5% but less than 10% of the mortgage pool, KeyBankNational Association, as CF 2019-CF1 master servicerand Benchmark 2019-B10 master servicer, constitutes a reporting “servicingfunction participant” for purposes of Item 1122 of Regulation AB, as specifiedin the Instruction 3 to Item 1122, but does not constitute a reporting“servicer” for purposes of Item 1123 of Regulation AB, as specified in theInstruction to Item 1123.

•   KeyBankNational Association, as Irving Market Center specialservicer under the CF 2019-CF1 pooling and servicing agreement, only hasobligations in respect of the Irving Market Center mortgage loan securitizedthereunder.  KeyBank National Association, acting as Irving Market Centerspecial servicer under the CF 2019-CF1 pooling and servicing agreement, has noobligations with respect to any mortgage loan included in the MSC 2019-H6mortgage pool and therefore in such capacity does not constitute a reporting“servicing function participant” for purposes of Item 1122 of Regulation AB, asspecified in the Instruction 3 to Item 1122, and does not constitute areporting “servicer” for purposes of Item 1123 of Regulation AB, as specifiedin the Instruction to Item 1123. 

•   Citibank, N.A., as certificate administrator underthe CF 2019-CF1 pooling and servicing agreement, pursuant to which the 65Broadway mortgage loan and the AC by Marriott San Jose mortgage loan areserviced, engaged U.S. Bank National Association to perform the relatedcustodial services with respect to such mortgage loans, and U.S. Bank NationalAssociation performed all such custodial services pursuant to the relatedpooling and servicing agreement. Because U.S. Bank National Association is notthe MSC 2019-H6 custodian, is not affiliated with any sponsor and only servicedthe 65 Broadway mortgage loan and the AC by Marriott San Jose mortgage loan,which collectively constitute less than 5% of the mortgage pool, U.S. BankNational Association, as a CF 2019-CF1 servicing function participant, does notconstitute a reporting “servicing function participant” for purposes of Item1122 of Regulation AB, as specified in the Instruction 3 to Item 1122, and doesnot constitute a reporting “servicer” for purposes of Item 1123 of RegulationAB, as specified in the Instruction to Item 1123.

•   Argentic Services Company LP is the current specialservicer under the MSC 2019-H7 pooling and servicing agreement, under which theSoCal Retail Portfolio mortgage loan is serviced. On May 6, 2020, LNR Partners,LLC was replaced as special servicer under the MSC 2019-H7 pooling andservicing agreement and succeeded by Argentic Services Company LP. ArgenticServices Company LP is an affiliate of Argentic Real Estate Finance LLC, one ofthe sponsors of the MSC 2019-H6 securitization. 

 

•   CWCapital Asset Management LLC is the current special servicer under the CF 2019-CF1 poolingand servicing agreement with respect to the 65 Broadway mortgage loan. On June11, 2021, Trimont Real Estate Advisors, LLC was replaced as special servicerunder the CF 2019-CF1 pooling and servicing agreement with respect to the 65Broadway mortgage loan and was succeeded by CWCapital Asset Management LLC.Because CWCapital Asset Management LLC is not the MSC 2019-H6 special servicer,is not affiliated with any sponsor and serviced only the 65 Broadway mortgageloan, which constitutes less than 5% of the mortgage pool, CWCapital AssetManagement LLC, as CF 2019-CF1 special servicer with respect to the 65 Broadwaymortgage loan, does not constitute a reporting “servicing function participant”for purposes of Item 1122 of Regulation AB, as specified in the Instruction 3to Item 1122, and does not constitute a reporting “servicer” for purposes ofItem 1123 of Regulation AB, as specified in the Instruction to Item 1123.

 

In addition, each of the following partiesengaged the services of certain servicing function participants andsub-servicers for the reporting period, as set forth below:

 

•   Wells Fargo Bank, NationalAssociation, as master servicer under the BANK 2019-BNK18 pooling and servicingagreement, pursuant to which the 9201 West Sunset Boulevard mortgage loan andWestin Atlanta Airport mortgage loan are serviced, engaged the services ofCoreLogic Solutions, LLC as a servicing function participant in respect of the9201 West Sunset Boulevard mortgage loan and Westin Atlanta Airport mortgageloan for the reporting period.

 

•   Wells Fargo Bank, NationalAssociation, as master servicer under the BANK 2019-BNK17 pooling and servicingagreement, pursuant to which the Tower 28 mortgage loan is serviced, engagedthe services of CoreLogic Solutions, LLC as a servicing function participant inrespect of the Tower 28 mortgage loan for the reporting period.

 

•   Wells Fargo Bank, NationalAssociation, as master servicer under the BBCMS 2018-C2 pooling and servicingagreement, pursuant to which the Shelbourne Global Portfolio II mortgage loanis serviced, engaged the services of (i) Berkeley Point Capital LLC as asub-servicer in respect of the Shelbourne Global Portfolio II mortgage loan forthe reporting period and (ii) CoreLogic Solutions, LLC as a servicing functionparticipant in respect of the Shelbourne Global Portfolio II mortgage loan forthe reporting period.

 

•   KeyBank National Association,as master servicer under the Benchmark 2019-B10 pooling and servicingagreement, pursuant to which the 3 Columbus Circle mortgage loan is serviced,engaged the services of Midland LoanServices, a Division of PNC Bank, National Association asa sub-servicer in respect of the 3 Columbus Circle mortgage loan for thereporting period.

 

•   On November 1, 2021, pursuantto the second amended and restated servicing agreement attached hereto as Exhibit99.17, Computershare Trust Company, National Association was engaged to performall or virtually all of Wells Fargo Bank, National Association’s roles ascertificate administrator, custodian and trustee, as applicable, under (i) thepooling and servicing agreement and (ii) each Outside Pooling and ServicingAgreement.

 

 

| **PART I**   |                            |
|-------------------|---------------------------------|
|              |                            |
| **Item 1.**  | **Business.**                   |
|              | Omitted.                        |
| **Item 1A.** | **Risk Factors.**          |
|              | Omitted.                        |
| **Item 1B.** | **Unresolved Staff  Comments.** |
|              | None.                           |
| **Item 2.**  | **Properties.**                 |
|              | Omitted.                        |
| **Item 3.**  | **Legal Proceedings.**     |
|              | Omitted.                        |
| **Item 4.**  | **Mine Safety Disclosures.**    |
|              | Omitted.                        |
|              |                            |   |

 

| **PART II**  |                                                                                                                |
|-------------------|---------------------------------------------------------------------------------------------------------------------|
|              |                                                                                                                |
| **Item 5.**  | **Market for Registrant's  Common Equity, Related Stockholder Matters and Issuer Purchases of Equity  Securities.** |
|              | Omitted.                                                                                                            |
| **Item 6.**  | **[Reserved]**                                                                                                      |
|              |                                                                                                                |
| **Item 7.**  | **Management's Discussion  and Analysis of Financial Condition and Results of Operations.**                         |
|              | Omitted.                                                                                                            |
| **Item 7A.** | **Quantitative and  Qualitative Disclosures About Market Risk.**                                                    |
|              | Omitted.                                                                                                            |
| **Item 8.**  | **Financial Statements and Supplementary  Data.**                                                                   |
|              | Omitted.                                                                                                            |
| **Item 9.**  | **Changes in and  Disagreements With Accountants on Accounting and Financial Disclosure.**                          |
|              | Omitted.                                                                                                            |
| **Item 9A.** | **Controls and Procedures.**                                                                                        |
|              | Omitted.                                                                                                            |
| **Item 9B.** | **Other Information.**                                                                                         |
|              | None.                                                                                                               |
| **Item 9C.** | **Disclosure Regarding  Foreign Jurisdictions that Prevent Inspections.**                                           |
|              | None.                                                                                                               |
|              |                                                                                                                |   |
|              |                                                                                                                |   |   |

 

| **PART III** |                                                                                                 |
|-------------------|------------------------------------------------------------------------------------------------------|
|              |                                                                                                 |
| **Item 10.** | **Directors, Executive  Officers and Corporate Governance.**                                         |
|              | Omitted.                                                                                             |
| **Item 11.** | **Executive Compensation.**                                                                          |
|              | Omitted.                                                                                             |
| **Item 12.** | **Security Ownership of  Certain Beneficial Owners and Management and Related Stockholder Matters.** |
|              | Omitted.                                                                                             |
| **Item 13.** | **Certain Relationships and  Related Transactions, and Director Independence.**                      |
|              | Omitted.                                                                                             |
| **Item 14.** | **Principal Accountant Fees  and Services.**                                                         |
|              | Omitted.                                                                                             |
|              |                                                                                                 |   |

 

**ADDITIONALDISCLOSURE ITEMS FOR REGULATION AB**

 

**Item1112(b) of Regulation AB, Significant Obligor Financial Information.**

 

Notapplicable.

 

**Item1114(b)(2) of Regulation AB, Significant Enhancement Provider FinancialInformation.**

 

Noentity or group of affiliated entities provides any enhancement or othersupport for the certificates as described under Item 1114 (a) of Regulation AB.

 

**Item1115(b) of Regulation AB, Certain Derivatives Instruments (FinancialInformation).**

 

Noentity or group of affiliated entities provides any derivative instruments forthe certificates as described under Item 1115 of Regulation AB.

 

**Item1117 of Regulation AB, Legal Proceedings.**

 

Theregistrant knows of no legal proceeding pending against the sponsors,depositor, trustee, issuing entity, servicer contemplated by Item 1108(a)(3) ofRegulation AB, originator contemplated by Item 1110(b) of Regulation AB, or otherparty contemplated by Item 1100(d)(1) of Regulation AB, or of which anyproperty of the foregoing is the subject, that is material to security holders,other than as follows:

 

InDecember 2014, Phoenix Light SF Limited (Phoenix Light) and certain relatedentities filed a complaint in the United States District Court for the SouthernDistrict of New York alleging claims against Wells Fargo Bank, N.A., in itscapacity as trustee for a number of residential mortgage-backed securities(RMBS) trusts. Complaints raising similar allegations have been filed byCommerzbank AG in the Southern District of New York and by IKB Internationaland IKB Deutsche Industriebank in New York state court. In each case, theplaintiffs allege that Wells Fargo Bank, N.A., as trustee, caused losses toinvestors, and plaintiffs assert causes of action based upon, among otherthings, the trustee’s alleged failure to notify and enforce repurchaseobligations of mortgage loan sellers for purported breaches of representationsand warranties, notify investors of alleged events of default, and abide byappropriate standards of care following alleged events of default. In July2022, the district court dismissed Phoenix Light’s claims and certain of theclaims asserted by Commerzbank AG, and subsequently entered judgment in eachcase in favor of Wells Fargo Bank, N.A. In August 2022, Phoenix Light andCommerzbank AG appealed the district court’s decision to the United StatesCourt of Appeals for the Second Circuit. Wells Fargo Bank, N.A. previouslysettled two class actions filed by institutional investors and an action filedby the National Credit Union Administration with similar allegations. Inaddition, Park Royal I LLC and Park Royal II LLC have filed substantiallysimilar lawsuits in New York state court alleging Wells Fargo Bank, N.A., astrustee, failed to take appropriate actions upon learning of defective mortgageloan documentation.

 

**Item1119 of Regulation AB, Affiliations and Certain Relationships and RelatedTransactions.**

 

Theinformation regarding this Item has been provided previously in an annualreport on Form 10-K of the issuing entity or in the prospectus of the issuingentity filed in a 424(b)(2) filing dated June 19, 2019. 

 

**Item1122 of Regulation AB, Compliance with Applicable Servicing Criteria.**

 

Thereports on assessment of compliance with the servicing criteria forasset-backed securities and the related attestation reports on such assessmentsof compliance are attached hereto under Item 15.

Thereport on assessment of compliance with applicable servicing criteria furnishedpursuant to Item 1122 of Regulation AB by KeyBank National Associationdiscloses that a material instance of noncompliance occurred, as describedbelow:

 

KeyBankNational Association (KeyBank) has identified the following material instanceof noncompliance with servicing criteria 1122(d)(4)(ix) during the calendaryear ended December 31, 2022, with respect to the Platform. The materialinstance of noncompliance does not relate to KeyBank’s performance under anypooling and servicing agreement applicable to the securitization transactionthat is the subject of this Form 10-K. 

 

1)Servicing Criteria impacted 

 

1122(d)(4)(ix) –Adjustments to interest rates or ratesof return for pool assets with variable rates are computed based on the relatedpool asset documents. 

 

2)Material Instance of Noncompliance with Servicing Criteria

 

During compliance testing, it was discovered, that not allFlexARM loan mortgagors were offered loan rates within 45-60 days before therate change date, as required per the related pool asset documents. Per theNote, if the holder fails to offer a loan rate within 45-60 days of any changedate a margin of 2.25% is to be used. Given the notification was not made tothe borrowers, a 3% margin was incorrectly applied. The noncompliance in Item1122 (d)(4)(ix) is related to a servicing portfolio which is wholly owned bythe investor and is not held in a publicly traded security. 

 

3)Remediation

 

The following remediation procedures have beeninitiated by KeyBank: (i) the impacted mortgage loans are currently in theprocess of being identified, (ii) investor contact has been initiated, (iii)corrective actions are being considered and will be tracked and monitored bysenior management, (iv) procedures will be reviewed and revised, if necessary,to include new tracking and action steps to prevent this situation fromrecurring in the future, and (v) training will be provided to the relevantstaff members to prevent a recurrence.

 

**Item1123 of Regulation AB, Servicer Compliance Statement.**

 

Theservicer compliance statements are attached hereto under Item 15.

 

**PART IV**

 

**Item15. Exhibits, Financial Statement Schedules.**

 

(a) Exhibits.

 

(4.1)Pooling and Servicing Agreement, dated as of June 1,2019, between Morgan Stanley Capital I Inc., as depositor, Midland Loan Services,a Division of PNC Bank, National Association, as master servicer and specialservicer, Wells Fargo Bank, National Association, as certificate administratorand trustee, and Park Bridge Lender Services LLC, as operating advisor and asasset representations reviewer (filed as Exhibit 4.1 to the registrant'sCurrent Report on Form 8-K/A filed on February 24, 2020 under SEC File No.333-227446-04 and incorporated by reference herein).

 

(4.2)Pooling and Servicing Agreement, dated as of May 1,2019, between Banc of America Merrill Lynch Commercial Mortgage Inc., asdepositor, Wells Fargo Bank, National Association, as general master servicer,Rialto Capital Advisors, LLC, as general special servicer, National CooperativeBank, N.A., as NCB master servicer and as NCB Special Servicer, Situs Holdings,LLC, as Newport Corporate Center special servicer, Wells Fargo Bank, NationalAssociation, as certificate administrator, Wilmington Trust, NationalAssociation, as trustee, and Pentalpha Surveillance LLC, as operating advisorand as asset representations reviewer, relating to the BANK 2019-BNK18securitization transaction, pursuant to which the 9201 Sunset BoulevardMortgage Loan and the Westin Atlanta Airport Mortgage Loan are serviced (filedas Exhibit 4.2 to the registrant's Current Report on Form 8-K filed on June 19,2019 under SEC File No. 333-227446-04 and incorporated by reference herein).

 

(4.3)Trust and Servicing Agreement, dated as of March 7,2019, between Morgan Stanley Capital I Inc., as depositor, Midland LoanServices, a Division of PNC Bank, National Association, as servicer, RialtoCapital Advisors, LLC, as special servicer, Wells Fargo Bank, NationalAssociation, as certificate administrator and trustee, and Park Bridge LenderServices LLC, as operating advisor, relating to the ILPT 2019-SURFsecuritization transaction, pursuant to which the ILPT Hawaii PortfolioMortgage Loan is serviced (filed as Exhibit 4.3 to the registrant's CurrentReport on Form 8-K filed on June 19, 2019 under SEC File No. 333-227446-04 andincorporated by reference herein).

 

(4.4)Pooling and Servicing Agreement, dated as of April 1,2019, between Morgan Stanley Capital I Inc., as depositor, Wells Fargo Bank,National Association, as master servicer, Midland Loan Services, a Division ofPNC Bank, National Association, as special servicer, Wells Fargo Bank, NationalAssociation, as certificate administrator, Wilmington Trust, NationalAssociation, as trustee, and Pentalpha Surveillance LLC, as operating advisorand asset representations reviewer, relating to the BANK 2019-BNK17securitization transaction, pursuant to which the Tower 28 Mortgage Loan isserviced (filed as Exhibit 4.4 to the registrant's Current Report on Form 8-Kfiled on June 19, 2019 under SEC File No. 333-227446-04 and incorporated byreference herein).

 

(4.5)Pooling and Servicing Agreement, dated as of June 1,2019, between Barclays Commercial Mortgage Securities LLC, as depositor,Midland Loan Services, a Division of PNC Bank, National Association, as masterservicer and special servicer, Wells Fargo Bank, National Association, ascertificate administrator and trustee, and Pentalpha Surveillance LLC, asoperating advisor and asset representations reviewer, relating to the BBCMS2019-C3 securitization transaction, pursuant to which The Block NorthwayMortgage Loan is serviced (filed as Exhibit 4.5 to the registrant's CurrentReport on Form 8-K filed on June 19, 2019 under SEC File No. 333-227446-04 andincorporated by reference herein).

 

(4.6)Pooling and Servicing Agreement, dated as of April 1,2019, between CCRE Commercial Mortgage Securities, L.P., as depositor, KeyBankNational Association, as master servicer, LNR Partners, LLC, Trimont RealEstate Advisors, LLC and KeyBank National Association, each as a specialservicer as described therein, Citibank, N.A., as certificate administrator andtrustee, and Park Bridge Lender Services LLC, as operating advisor and assetrepresentations reviewer, relating to the CF 2019-CF1 securitization transaction,pursuant to which the 65 Broadway Mortgage Loan and the AC by Marriott San JoseMortgage Loan are serviced (filed as Exhibit 4.6 to the registrant's CurrentReport on Form 8-K filed on June 19, 2019 under SEC File No. 333-227446-04 andincorporated by reference herein).

 

(4.7)Pooling and Servicing Agreement, dated as of December1, 2018, between Barclays Commercial Mortgage Securities LLC, as depositor,Wells Fargo Bank, National Association, as master servicer, LNR Partners, LLC,as special servicer, Wells Fargo Bank, National Association, as certificateadministrator, Wilmington Trust, National Association, as trustee, and ParkBridge Lender Services LLC, as operating advisor and asset representationsreviewer, relating to the BBCMS 2018-C2 securitization transaction, pursuant towhich the Shelbourne Global Portfolio II Mortgage Loan is serviced (filed asExhibit 4.7 to the registrant's Current Report on Form 8-K filed on June 19,2019 under SEC File No. 333-227446-04 and incorporated by reference herein).

 

(4.8)Pooling and Servicing Agreement, dated as of April 1,2019, between Deutsche Mortgage & Asset Receiving Corporation, asdepositor, KeyBank National Association, as master servicer, LNR Partners, LLC,as special servicer, Wells Fargo Bank, National Association, as certificateadministrator, paying agent and custodian, Wells Fargo Bank, NationalAssociation, as trustee, and Pentalpha Surveillance LLC, as operating advisorand asset representations reviewer, relating to the Benchmark 2019-B10securitization transaction, pursuant to which the 3 Columbus Circle MortgageLoan is serviced (filed as Exhibit 4.8 to the registrant's Current Report onForm 8-K filed on June 19, 2019 under SEC File No. 333-227446-04 andincorporated by reference herein).

 

(4.9)Pooling and Servicing Agreement, dated as of July 1,2019, between Morgan Stanley Capital I Inc., as depositor, Midland LoanServices, a Division of PNC Bank, National Association, as master servicer, LNRPartners, LLC, as special servicer, Wells Fargo Bank, National Association, ascertificate administrator and trustee, and Pentalpha Surveillance LLC, asoperating advisor and as asset representations reviewer, relating to the MSC2019-H7 securitization transaction, pursuant to which the SoCal RetailPortfolio Mortgage Loan is serviced (filed as Exhibit 4.9 to the registrant'sCurrent Report on Form 8-K filed on July 31, 2019 under SEC File No.333-227446-04 and incorporated by reference herein).

 

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

 

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

 

33.1 Wells Fargo Bank, National Association, as CertificateAdministrator

 

33.2 Computershare Trust Company, National Association, asServicing Function Participant for the Certificate Administrator

 

33.3 Wells Fargo Bank, National Association, as Custodian

 

33.4 Computershare Trust Company, National Association, asServicing Function Participant for the Custodian

 

33.5 Midland Loan Services, a Division of PNCBank, National Association, as Master Servicer

 

33.6 Midland Loan Services, a Division of PNCBank, National Association, as Special Servicer (see Exhibit 33.5)

 

33.7 Park Bridge Lender Services LLC, as OperatingAdvisor

 

33.8 Wells Fargo Bank, National Association, as MasterServicer under the BANK 2019-BNK18 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: 9201 West SunsetBoulevard (from 1/1/22 to 12/31/22) and Westin Atlanta Airport (from 1/1/22 to12/31/22)

 

33.9 CoreLogic Solutions, LLC, as ServicingFunction Participant under the BANK 2019-BNK18 securitization, pursuant towhich the following mortgage loans were serviced by such party: 9201 WestSunset Boulevard (from 1/1/22 to 12/31/22) and Westin Atlanta Airport (from1/1/22 to 12/31/22)

 

33.10 Midland Loan Services, a Division of PNCBank, National Association, as Master Servicer under the MSC 2019-H7securitization, pursuant to which the following mortgage loans were serviced bysuch party: SoCal Retail Portfolio (from 1/1/22 to 12/31/22) (see exhibit 33.5)

 

33.11 Midland Loan Services, a Division of PNCBank, National Association, as Master Servicer under the ILPT 2019-SURFsecuritization, pursuant to which the following mortgage loans were serviced bysuch party: ILPT Hawaii Portfolio (from 1/1/22 to 12/31/22) (see exhibit 33.5)

 

33.12 Wells Fargo Bank, National Association, asMaster Servicer under the BANK 2019-BNK17 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Tower 28 (from 1/1/22 to12/31/22) (see exhibit 33.8)

 

33.13 CoreLogic Solutions, LLC, as ServicingFunction Participant under the BANK 2019-BNK17 securitization, pursuant to whichthe following mortgage loans were serviced by such party: Tower 28 (from 1/1/22to 12/31/22) (see exhibit 33.9)

 

33.14 Midland Loan Services, a Division of PNCBank, National Association, as Master Servicer under the BBCMS 2019-C3securitization, pursuant to which the following mortgage loans were serviced bysuch party: The Block Northway (from 1/1/22 to 12/31/22) (see exhibit 33.5)

 

33.15 KeyBank National Association, as Master Servicerunder the CF 2019-CF1 securitization, pursuant to which the following mortgageloans were serviced by such party: 65 Broadway (from 1/1/22 to 12/31/22) and ACby Marriott San Jose (from 1/1/22 to 12/31/22)

 

33.16 Wells Fargo Bank, National Association, asMaster Servicer under the BBCMS 2018-C2 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Shelbourne GlobalPortfolio II (from 1/1/22 to 12/31/22) (see exhibit 33.8)

 

33.17 CoreLogic Solutions, LLC, as ServicingFunction Participant under the BBCMS 2018-C2 securitization, pursuant to whichthe following mortgage loans were serviced by such party: Shelbourne GlobalPortfolio II (from 1/1/22 to 12/31/22) (see exhibit 33.9)

 

33.18 Berkeley Point Capital LLC, as Sub-Servicerunder the BBCMS 2018-C2 securitization, pursuant to which the followingmortgage loans were serviced by such party: Shelbourne Global Portfolio II(from 1/1/22 to 12/31/22)

 

33.19 KeyBank National Association, as MasterServicer under the Benchmark 2019-B10 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: 3 Columbus Circle (from1/1/22 to 12/31/22) (see exhibit 33.15)

 

33.20Midland Loan Services, a Division of PNC Bank,National Association, as Sub-Servicer under the Benchmark 2019-B10securitization, pursuant to which the following mortgage loans were serviced bysuch party: 3 Columbus Circle (from 1/1/22 to 12/31/22) (see exhibit 33.5)

 

33.21 Rialto Capital Advisors, LLC, as SpecialServicer under the BANK 2019-BNK18 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: 9201 West SunsetBoulevard (from 1/1/22 to 12/31/22) and Westin Atlanta Airport (from 1/1/22 to12/31/22)

 

33.22 Argentic Services Company LP, as SpecialServicer under the MSC 2019-H7 securitization, pursuant to which the followingmortgage loans were serviced by such party: SoCal Retail Portfolio (from 1/1/22to 12/31/22)

 

33.23 Rialto Capital Advisors, LLC, as SpecialServicer under the ILPT 2019-SURF securitization, pursuant to which thefollowing mortgage loans were serviced by such party: ILPT Hawaii Portfolio(from 1/1/22 to 12/31/22) (see exhibit 33.21)

 

33.24 Midland Loan Services, a Division of PNCBank, National Association, as Special Servicer under the BANK 2019-BNK17securitization, pursuant to which the following mortgage loans were serviced bysuch party: Tower 28 (from 1/1/22 to 12/31/22) (see exhibit 33.5)

 

33.25 Midland Loan Services, a Division of PNCBank, National Association, as Special Servicer under the BBCMS 2019-C3securitization, pursuant to which the following mortgage loans were serviced bysuch party: The Block Northway (from 1/1/22 to 12/31/22) (see exhibit 33.5)

 

33.26 LNR Partners, LLC, as Special Servicer underthe CF 2019-CF1 securitization, pursuant to which the following mortgage loanswere serviced by such party: AC by Marriott San Jose (from 1/1/22 to 12/31/22)

 

33.27 LNR Partners, LLC, as Special Servicer underthe BBCMS 2018-C2 securitization, pursuant to which the following mortgageloans were serviced by such party: Shelbourne Global Portfolio II (from 1/1/22to 12/31/22) (see exhibit 33.26)

 

33.28 LNR Partners, LLC, as Special Servicer underthe Benchmark 2019-B10 securitization, pursuant to which the following mortgageloans were serviced by such party: 3 Columbus Circle (from 1/1/22 to 12/31/22)(see exhibit 33.26)

 

33.29 Wells Fargo Bank, National Association, asCustodian under the BANK 2019-BNK18 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: 9201 West SunsetBoulevard (from 1/1/22 to 12/31/22) and Westin Atlanta Airport (from 1/1/22 to12/31/22) (see exhibit 33.3)

 

33.30 Computershare Trust Company, National Association,as Servicing Function Participant under the BANK 2019-BNK18 securitization,pursuant to which the following mortgage loans were serviced by such party:9201 West Sunset Boulevard (from 1/1/22 to 12/31/22) and Westin Atlanta Airport(from 1/1/22 to 12/31/22) (see exhibit 33.4)

 

33.31 Wells Fargo Bank, National Association, asCustodian under the MSC 2019-H7 securitization, pursuant to which the followingmortgage loans were serviced by such party: SoCal Retail Portfolio (from 1/1/22to 12/31/22) (see exhibit 33.3)

 

33.32 Computershare Trust Company, NationalAssociation, as Servicing Function Participant under the MSC 2019-H7securitization, pursuant to which the following mortgage loans were serviced bysuch party: SoCal Retail Portfolio (from 1/1/22 to 12/31/22) (see exhibit 33.4)

 

33.33 Wells Fargo Bank, National Association, asCustodian under the ILPT 2019-SURF securitization, pursuant to which thefollowing mortgage loans were serviced by such party: ILPT Hawaii Portfolio(from 1/1/22 to 12/31/22) (see exhibit 33.3)

 

33.34 Computershare Trust Company, NationalAssociation, as Servicing Function Participant under the ILPT 2019-SURFsecuritization, pursuant to which the following mortgage loans were serviced bysuch party: ILPT Hawaii Portfolio (from 1/1/22 to 12/31/22) (see exhibit 33.4)

 

33.35 Wells Fargo Bank, National Association, asCustodian under the BANK 2019-BNK17 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Tower 28 (from 1/1/22 to12/31/22) (see exhibit 33.3)

 

33.36 Computershare Trust Company, NationalAssociation, as Servicing Function Participant under the BANK 2019-BNK17securitization, pursuant to which the following mortgage loans were serviced bysuch party: Tower 28 (from 1/1/22 to 12/31/22) (see exhibit 33.4)

 

33.37 Wells Fargo Bank, National Association, asCustodian under the BBCMS 2019-C3 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: The Block Northway (from1/1/22 to 12/31/22) (see exhibit 33.3)

 

33.38 Computershare Trust Company, NationalAssociation, as Servicing Function Participant under the BBCMS 2019-C3securitization, pursuant to which the following mortgage loans were serviced bysuch party: The Block Northway (from 1/1/22 to 12/31/22) (see exhibit 33.4)

 

33.39 Wells Fargo Bank, National Association, asCustodian under the BBCMS 2018-C2 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Shelbourne GlobalPortfolio II (from 1/1/22 to 12/31/22) (see exhibit 33.3)

 

33.40 Computershare Trust Company, NationalAssociation, as Servicing Function Participant under the BBCMS 2018-C2securitization, pursuant to which the following mortgage loans were serviced bysuch party: Shelbourne Global Portfolio II (from 1/1/22 to 12/31/22) (seeexhibit 33.4)

 

33.41  Wells Fargo Bank, National Association, as Custodianunder the Benchmark 2019-B10 securitization, pursuant to which the followingmortgage loans were serviced by such party: 3 Columbus Circle (from 1/1/22 to12/31/22) (see exhibit 33.3)

 

33.42  Computershare Trust Company, National Association, asServicing Function Participant under the Benchmark 2019-B10 securitization,pursuant to which the following mortgage loans were serviced by such party: 3Columbus Circle (from 1/1/22 to 12/31/22) (see exhibit 33.4)

 

 (34).Attestation reports on assessment of compliance with servicing criteria forasset-backed securities.

 

34.1 Wells Fargo Bank, National Association, as CertificateAdministrator

 

34.2 Computershare Trust Company, National Association, asServicing Function Participant for the Certificate Administrator

 

34.3 Wells Fargo Bank, National Association, as Custodian

 

34.4 Computershare Trust Company, National Association, asServicing Function Participant for the Custodian

 

34.5 Midland Loan Services, a Division of PNCBank, National Association, as Master Servicer

 

34.6 Midland Loan Services, a Division of PNCBank, National Association, as Special Servicer (see Exhibit 34.5)

 

34.7 Park Bridge Lender Services LLC, as OperatingAdvisor

 

34.8 Wells Fargo Bank, National Association, as MasterServicer under the BANK 2019-BNK18 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: 9201 West SunsetBoulevard (from 1/1/22 to 12/31/22) and Westin Atlanta Airport (from 1/1/22 to12/31/22)

 

34.9 CoreLogic Solutions, LLC, as ServicingFunction Participant under the BANK 2019-BNK18 securitization, pursuant towhich the following mortgage loans were serviced by such party: 9201 WestSunset Boulevard (from 1/1/22 to 12/31/22) and Westin Atlanta Airport (from1/1/22 to 12/31/22)

 

34.10 Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer under the MSC 2019-H7 securitization,pursuant to which the following mortgage loans were serviced by such party:SoCal Retail Portfolio (from 1/1/22 to 12/31/22) (see exhibit 34.5)

 

34.11 Midland Loan Services, a Division of PNCBank, National Association, as Master Servicer under the ILPT 2019-SURFsecuritization, pursuant to which the following mortgage loans were serviced bysuch party: ILPT Hawaii Portfolio (from 1/1/22 to 12/31/22) (see exhibit 34.5)

 

34.12 Wells Fargo Bank, National Association, asMaster Servicer under the BANK 2019-BNK17 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Tower 28 (from 1/1/22 to12/31/22) (see exhibit 34.8)

 

34.13 CoreLogic Solutions, LLC, as ServicingFunction Participant under the BANK 2019-BNK17 securitization, pursuant towhich the following mortgage loans were serviced by such party: Tower 28 (from1/1/22 to 12/31/22) (see exhibit 34.9)

 

34.14 Midland Loan Services, a Division of PNCBank, National Association, as Master Servicer under the BBCMS 2019-C3securitization, pursuant to which the following mortgage loans were serviced bysuch party: The Block Northway (from 1/1/22 to 12/31/22) (see exhibit 34.5)

 

34.15 KeyBank National Association, as Master Servicerunder the CF 2019-CF1 securitization, pursuant to which the following mortgageloans were serviced by such party: 65 Broadway (from 1/1/22 to 12/31/22) and ACby Marriott San Jose (from 1/1/22 to 12/31/22)

 

34.16 Wells Fargo Bank, National Association, asMaster Servicer under the BBCMS 2018-C2 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Shelbourne GlobalPortfolio II (from 1/1/22 to 12/31/22) (see exhibit 34.8)

 

34.17 CoreLogic Solutions, LLC, as ServicingFunction Participant under the BBCMS 2018-C2 securitization, pursuant to whichthe following mortgage loans were serviced by such party: Shelbourne GlobalPortfolio II (from 1/1/22 to 12/31/22) (see exhibit 34.9)

 

34.18 Berkeley Point Capital LLC, as Sub-Servicerunder the BBCMS 2018-C2 securitization, pursuant to which the followingmortgage loans were serviced by such party: Shelbourne Global Portfolio II(from 1/1/22 to 12/31/22)

 

34.19 KeyBank National Association, as MasterServicer under the Benchmark 2019-B10 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: 3 Columbus Circle (from1/1/22 to 12/31/22) (see exhibit 34.15)

 

34.20Midland Loan Services, a Division of PNC Bank,National Association, as Sub-Servicer under the Benchmark 2019-B10securitization, pursuant to which the following mortgage loans were serviced bysuch party: 3 Columbus Circle (from 1/1/22 to 12/31/22) (see exhibit 34.5)

 

34.21 Rialto Capital Advisors, LLC, as SpecialServicer under the BANK 2019-BNK18 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: 9201 West SunsetBoulevard (from 1/1/22 to 12/31/22) and Westin Atlanta Airport (from 1/1/22 to12/31/22)

 

34.22 Argentic Services Company LP, as SpecialServicer under the MSC 2019-H7 securitization, pursuant to which the followingmortgage loans were serviced by such party: SoCal Retail Portfolio (from 1/1/22to 12/31/22)

 

34.23 Rialto Capital Advisors, LLC, as SpecialServicer under the ILPT 2019-SURF securitization, pursuant to which thefollowing mortgage loans were serviced by such party: ILPT Hawaii Portfolio(from 1/1/22 to 12/31/22) (see exhibit 34.21)

 

34.24 Midland Loan Services, a Division of PNCBank, National Association, as Special Servicer under the BANK 2019-BNK17securitization, pursuant to which the following mortgage loans were serviced bysuch party: Tower 28 (from 1/1/22 to 12/31/22) (see exhibit 34.5)

 

34.25 Midland Loan Services, a Division of PNCBank, National Association, as Special Servicer under the BBCMS 2019-C3securitization, pursuant to which the following mortgage loans were serviced bysuch party: The Block Northway (from 1/1/22 to 12/31/22) (see exhibit 34.5)

 

34.26 LNR Partners, LLC, as Special Servicer underthe CF 2019-CF1 securitization, pursuant to which the following mortgage loanswere serviced by such party: AC by Marriott San Jose (from 1/1/22 to 12/31/22)

 

34.27 LNR Partners, LLC, as Special Servicer underthe BBCMS 2018-C2 securitization, pursuant to which the following mortgageloans were serviced by such party: Shelbourne Global Portfolio II (from 1/1/22to 12/31/22) (see exhibit 34.26)

 

34.28 LNR Partners, LLC, as Special Servicer underthe Benchmark 2019-B10 securitization, pursuant to which the following mortgageloans were serviced by such party: 3 Columbus Circle (from 1/1/22 to 12/31/22)(see exhibit 34.26)

 

34.29 Wells Fargo Bank, National Association, asCustodian under the BANK 2019-BNK18 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: 9201 West SunsetBoulevard (from 1/1/22 to 12/31/22) and Westin Atlanta Airport (from 1/1/22 to12/31/22) (see exhibit 34.3)

 

34.30 Computershare Trust Company, National Association,as Servicing Function Participant under the BANK 2019-BNK18 securitization,pursuant to which the following mortgage loans were serviced by such party:9201 West Sunset Boulevard (from 1/1/22 to 12/31/22) and Westin Atlanta Airport(from 1/1/22 to 12/31/22) (see exhibit 34.4)

 

34.31 Wells Fargo Bank, National Association, asCustodian under the MSC 2019-H7 securitization, pursuant to which the followingmortgage loans were serviced by such party: SoCal Retail Portfolio (from 1/1/22to 12/31/22) (see exhibit 34.3)

 

34.32 Computershare Trust Company, NationalAssociation, as Servicing Function Participant under the MSC 2019-H7securitization, pursuant to which the following mortgage loans were serviced bysuch party: SoCal Retail Portfolio (from 1/1/22 to 12/31/22) (see exhibit 34.4)

 

34.33 Wells Fargo Bank, National Association, asCustodian under the ILPT 2019-SURF securitization, pursuant to which thefollowing mortgage loans were serviced by such party: ILPT Hawaii Portfolio(from 1/1/22 to 12/31/22) (see exhibit 34.3)

 

34.34 Computershare Trust Company, NationalAssociation, as Servicing Function Participant under the ILPT 2019-SURFsecuritization, pursuant to which the following mortgage loans were serviced bysuch party: ILPT Hawaii Portfolio (from 1/1/22 to 12/31/22) (see exhibit 34.4)

 

34.35 Wells Fargo Bank, National Association, asCustodian under the BANK 2019-BNK17 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Tower 28 (from 1/1/22 to12/31/22) (see exhibit 34.3)

 

34.36 Computershare Trust Company, NationalAssociation, as Servicing Function Participant under the BANK 2019-BNK17securitization, pursuant to which the following mortgage loans were serviced bysuch party: Tower 28 (from 1/1/22 to 12/31/22) (see exhibit 34.4)

 

34.37 Wells Fargo Bank, National Association, asCustodian under the BBCMS 2019-C3 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: The Block Northway (from1/1/22 to 12/31/22) (see exhibit 34.3)

 

34.38 Computershare Trust Company, NationalAssociation, as Servicing Function Participant under the BBCMS 2019-C3securitization, pursuant to which the following mortgage loans were serviced bysuch party: The Block Northway (from 1/1/22 to 12/31/22) (see exhibit 34.4)

 

34.39 Wells Fargo Bank, National Association, asCustodian under the BBCMS 2018-C2 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Shelbourne GlobalPortfolio II (from 1/1/22 to 12/31/22) (see exhibit 34.3)

 

34.40 Computershare Trust Company, NationalAssociation, as Servicing Function Participant under the BBCMS 2018-C2securitization, pursuant to which the following mortgage loans were serviced bysuch party: Shelbourne Global Portfolio II (from 1/1/22 to 12/31/22) (seeexhibit 34.4)

 

34.41  Wells Fargo Bank, National Association, as Custodianunder the Benchmark 2019-B10 securitization, pursuant to which the followingmortgage loans were serviced by such party: 3 Columbus Circle (from 1/1/22 to12/31/22) (see exhibit 34.3)

 

34.42  Computershare Trust Company, National Association, asServicing Function Participant under the Benchmark 2019-B10 securitization,pursuant to which the following mortgage loans were serviced by such party: 3Columbus Circle (from 1/1/22 to 12/31/22) (see exhibit 34.4)

 

(35).Servicer compliance statement.

 

35.1 Wells Fargo Bank, National Association, as CertificateAdministrator

 

35.2 Computershare Trust Company, National Association, asServicing Function Participant for the Certificate Administrator

 

35.3 Wells Fargo Bank, National Association, as Custodian

 

35.4 Computershare Trust Company, National Association, as ServicingFunction Participant for the Custodian

 

35.5 Midland Loan Services, a Division of PNCBank, National Association, as Master Servicer

 

35.6 Midland Loan Services, a Division of PNCBank, National Association, as Special Servicer (see Exhibit 35.5)

 

35.7 Wells Fargo Bank, National Association, asMaster Servicer under the BANK 2019-BNK18 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: 9201 West SunsetBoulevard (from 1/1/22 to 12/31/22) and Westin Atlanta Airport (from 1/1/22 to12/31/22)

 

35.8 Midland Loan Services, a Division of PNCBank, National Association, as Master Servicer under the MSC 2019-H7securitization, pursuant to which the following mortgage loans were serviced bysuch party: SoCal Retail Portfolio (from 1/1/22 to 12/31/22) (see exhibit 35.5)

 

35.9 Midland Loan Services, a Division of PNCBank, National Association, as Master Servicer under the ILPT 2019-SURFsecuritization, pursuant to which the following mortgage loans were serviced bysuch party: ILPT Hawaii Portfolio (from 1/1/22 to 12/31/22) (see exhibit 35.5)

 

35.10 Wells Fargo Bank, National Association, asMaster Servicer under the BANK 2019-BNK17 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Tower 28 (from 1/1/22 to12/31/22) (see exhibit 35.7)

 

35.11 Midland Loan Services, a Division of PNCBank, National Association, as Master Servicer under the BBCMS 2019-C3securitization, pursuant to which the following mortgage loans were serviced bysuch party: The Block Northway (from 1/1/22 to 12/31/22) (see exhibit 35.5)

 

35.12 Wells Fargo Bank, National Association, asMaster Servicer under the BBCMS 2018-C2 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Shelbourne GlobalPortfolio II (from 1/1/22 to 12/31/22) (see exhibit 35.7)

 

35.13 Berkeley Point Capital LLC, as Sub-Servicerunder the BBCMS 2018-C2 securitization, pursuant to which the followingmortgage loans were serviced by such party: Shelbourne Global Portfolio II(from 1/1/22 to 12/31/22)

 

35.14 Midland Loan Services, a Division of PNC Bank,National Association, as Sub-Servicer under the Benchmark 2019-B10securitization, pursuant to which the following mortgage loans were serviced bysuch party: 3 Columbus Circle (from 1/1/22 to 12/31/22) (see exhibit 35.5)

 

35.15 Rialto Capital Advisors, LLC, as SpecialServicer under the BANK 2019-BNK18 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: 9201 West SunsetBoulevard (from 1/1/22 to 12/31/22) and Westin Atlanta Airport (from 1/1/22 to12/31/22)

 

35.16Argentic Services Company LP, as Special Servicerunder the MSC 2019-H7 securitization, pursuant to which the following mortgageloans were serviced by such party: SoCal Retail Portfolio (from 1/1/22 to12/31/22)

 

35.17 Rialto Capital Advisors, LLC, as SpecialServicer under the ILPT 2019-SURF securitization, pursuant to which thefollowing mortgage loans were serviced by such party: ILPT Hawaii Portfolio(from 1/1/22 to 12/31/22) (see exhibit 35.15)

 

35.18 Midland Loan Services, a Division of PNCBank, National Association, as Special Servicer under the BANK 2019-BNK17securitization, pursuant to which the following mortgage loans were serviced bysuch party: Tower 28 (from 1/1/22 to 12/31/22) (see exhibit 35.5)

 

35.19 Midland Loan Services, a Division of PNCBank, National Association, as Special Servicer under the BBCMS 2019-C3securitization, pursuant to which the following mortgage loans were serviced bysuch party: The Block Northway (from 1/1/22 to 12/31/22) (see exhibit 35.5)

  

35.20 LNR Partners, LLC, as Special Servicer underthe CF 2019-CF1 securitization, pursuant to which the following mortgage loanswere serviced by such party: AC by Marriott San Jose (from 1/1/22 to 12/31/22)

 

35.21 LNR Partners, LLC, as Special Servicer underthe BBCMS 2018-C2 securitization, pursuant to which the following mortgageloans were serviced by such party: Shelbourne Global Portfolio II (from 1/1/22to 12/31/22) (see exhibit 35.20)

 

35.22 LNR Partners, LLC, as Special Servicer underthe Benchmark 2019-B10 securitization, pursuant to which the following mortgageloans were serviced by such party: 3 Columbus Circle (from 1/1/22 to 12/31/22)(see exhibit 35.20)

 

35.23 Wells Fargo Bank, National Association, asCustodian under the BANK 2019-BNK18 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: 9201 West SunsetBoulevard (from 1/1/22 to 12/31/22) and Westin Atlanta Airport (from 1/1/22 to12/31/22) (see exhibit 35.3)

 

35.24 Computershare Trust Company, NationalAssociation, as Servicing Function Participant under the BANK 2019-BNK18securitization, pursuant to which the following mortgage loans were serviced bysuch party: 9201 West Sunset Boulevard (from 1/1/22 to 12/31/22) and WestinAtlanta Airport (from 1/1/22 to 12/31/22) (see exhibit 35.4)

 

35.25 Wells Fargo Bank, National Association, as Custodianunder the MSC 2019-H7 securitization, pursuant to which the following mortgageloans were serviced by such party: SoCal Retail Portfolio (from 1/1/22 to12/31/22) (see exhibit 35.3)

 

35.26 Computershare Trust Company, NationalAssociation, as Servicing Function Participant under the MSC 2019-H7securitization, pursuant to which the following mortgage loans were serviced bysuch party: SoCal Retail Portfolio (from 1/1/22 to 12/31/22) (see exhibit 35.4)

 

35.27 Wells Fargo Bank, National Association, asCustodian under the ILPT 2019-SURF securitization, pursuant to which thefollowing mortgage loans were serviced by such party: ILPT Hawaii Portfolio(from 1/1/22 to 12/31/22) (see exhibit 35.3)

 

35.28 Computershare Trust Company, NationalAssociation, as Servicing Function Participant under the ILPT 2019-SURFsecuritization, pursuant to which the following mortgage loans were serviced bysuch party: ILPT Hawaii Portfolio (from 1/1/22 to 12/31/22) (see exhibit 35.4)

 

35.29 Wells Fargo Bank, National Association, asCustodian under the BANK 2019-BNK17 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Tower 28 (from 1/1/22 to12/31/22) (see exhibit 35.3)

 

35.30 Computershare Trust Company, NationalAssociation, as Servicing Function Participant under the BANK 2019-BNK17securitization, pursuant to which the following mortgage loans were serviced bysuch party: Tower 28 (from 1/1/22 to 12/31/22) (see exhibit 35.4)

 

35.31 Wells Fargo Bank, National Association, asCustodian under the BBCMS 2019-C3 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: The Block Northway (from1/1/22 to 12/31/22) (see exhibit 35.3)

 

35.32 Computershare Trust Company, NationalAssociation, as Servicing Function Participant under the BBCMS 2019-C3securitization, pursuant to which the following mortgage loans were serviced bysuch party: The Block Northway (from 1/1/22 to 12/31/22) (see exhibit 35.4)

 

35.33 Wells Fargo Bank, National Association, asCustodian under the BBCMS 2018-C2 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Shelbourne GlobalPortfolio II (from 1/1/22 to 12/31/22) (see exhibit 35.3)

 

35.34 Computershare Trust Company, NationalAssociation, as Servicing Function Participant under the BBCMS 2018-C2securitization, pursuant to which the following mortgage loans were serviced bysuch party: Shelbourne Global Portfolio II (from 1/1/22 to 12/31/22) (seeexhibit 35.4)

 

35.35  Wells Fargo Bank, National Association, as Custodianunder the Benchmark 2019-B10 securitization, pursuant to which the followingmortgage loans were serviced by such party: 3 Columbus Circle (from 1/1/22 to12/31/22) (see exhibit 35.3)

 

35.36  Computershare Trust Company, National Association, asServicing Function Participant under the Benchmark 2019-B10 securitization,pursuant to which the following mortgage loans were serviced by such party: 3Columbus Circle (from 1/1/22 to 12/31/22) (see exhibit 35.4)

 

(99.1)Mortgage Loan Purchase Agreement, dated June 5, 2019,between Morgan Stanley Capital I Inc. and Morgan Stanley Mortgage CapitalHoldings LLC (filed as Exhibit 99.1 to the registrant's Current Report on Form8-K filed on June 19, 2019 under SEC File No. 333-227446-04 and incorporated byreference herein).

 

(99.2) Mortgage Loan Purchase Agreement, dated June 5, 2019,between Morgan Stanley Capital I Inc. and Argentic Real Estate Finance LLC(filed as Exhibit 99.2 to the registrant's Current Report on Form 8-K filed onJune 19, 2019 under SEC File No. 333-227446-04 and incorporated by referenceherein).

 

(99.3)Mortgage Loan Purchase Agreement, dated June 5, 2019,between Morgan Stanley Capital I Inc. and Cantor Commercial Real EstateLending, L.P. (filed as Exhibit 99.3 to the registrant's Current Report on Form8-K filed on June 19, 2019 under SEC File No. 333-227446-04 and incorporated byreference herein).

 

(99.4) Mortgage Loan Purchase Agreement, dated June 5, 2019,between Morgan Stanley Capital I Inc. and Starwood Mortgage Capital LLC (filedas Exhibit 99.4 to the registrant's Current Report on Form 8-K filed on June19, 2019 under SEC File No. 333-227446-04 and incorporated by reference herein).

 

(99.5)Agreement between Note Holders, dated as of May 31,2019, by and among Morgan Stanley Bank, N.A., as initial note A-1 holder, andMorgan Stanley Bank, N.A., as initial note A-2 holder, relating to the 9201Sunset Boulevard loan combination (filed as Exhibit 99.5 to the registrant'sCurrent Report on Form 8-K filed on June 19, 2019 under SEC File No. 333-227446-04and incorporated by reference herein).

 

(99.6)Agreement between Note Holders, dated as of June 19,2019, by and among Argentic Real Estate Finance LLC, as initial A-1 holder,Argentic Real Estate Finance LLC, as initial A-2 holder, Argentic Real EstateFinance LLC, as initial A-3 holder, Argentic Real Estate Finance LLC, asinitial A-4 holder, Argentic Real Estate Finance LLC, as initial A-5 holder,Argentic Real Estate Finance LLC, as initial A-6 holder, Argentic Real EstateFinance LLC, as initial A-7 holder and Argentic Real Estate Finance LLC, asinitial A-8 holder, relating to the SoCal Retail Portfolio loan combination(filed as Exhibit 99.6 to the registrant's Current Report on Form 8-K filed onJune 19, 2019 under SEC File No. 333-227446-04 and incorporated by referenceherein).

 

(99.7)Agreement between Note Holders, dated as of March 7,2019, by and among Morgan Stanley Bank, N.A., as initial note A-1 holder,initial note A-5-1 holder, initial note A-5-2 holder, initial note A-5-3 holderand initial note A-5-4 holder, Citi Real Estate Funding Inc., as initial noteA-2 holder, initial note A-6-1 holder and initial note A-6-2 holder, UBS AG,New York Branch, as initial note A-3 holder, initial note A-7-1 holder, initialnote A-7-2 holder, initial note A-9 holder, initial note A-10 holder andinitial note A-11 holder, JPMorgan Chase Bank, National Association, as initialnote A-4 holder, initial note A-8-1 holder and initial note A-8-2 holder,relating to the ILPT Hawaii Portfolio loan combination (filed as Exhibit 99.7to the registrant's Current Report on Form 8-K filed on June 19, 2019 under SECFile No. 333-227446-04 and incorporated by reference herein).

 

(99.8)Intercreditor Agreement, dated as of March 25, 2019, byand between Morgan Stanley Bank, N.A., as initial A-1 holder, Morgan StanleyBank, N.A., as initial A-2 holder, and Morgan Stanley Mortgage Capital HoldingsLLC, as initial note B holder, relating to the Tower 28 loan combination (filedas Exhibit 99.8 to the registrant's Current Report on Form 8-K filed on June19, 2019 under SEC File No. 333-227446-04 and incorporated by referenceherein).

 

(99.9)Agreement Between Note Holders, dated as of June 19,2019, by and between Morgan Stanley Bank, N.A., as initial A-1 holder, MorganStanley Bank, N.A., as initial A-2 holder, relating to the FedEx Niles loancombination (filed as Exhibit 99.9 to the registrant's Current Report on Form8-K filed on June 19, 2019 under SEC File No. 333-227446-04 and incorporated byreference herein).

 

(99.10)Agreement Between Note Holders, dated as of March 14,2019, by and between UBS AG, by and through its branch office at 1285 Avenue ofthe Americas, New York, New York, as initial note A-1 holder, initial note A-3holder, initial note A-6 holder and initial note A-7-1 holder, Morgan StanleyMortgage Capital Holdings LLC, as initial note A-2 holder, initial note A-4holder, initial note A-5 holder, initial note A-7-2 holder and initial note A-8holder, relating to The Block Northway loan combination (filed as Exhibit 99.10to the registrant's Current Report on Form 8-K filed on June 19, 2019 under SECFile No. 333-227446-04 and incorporated by reference herein).

 

(99.11) Agreement Between Note Holders, dated as of April 5,2019, by and between Cantor Commercial Real Estate Lending, L.P., as initialnote A-1 holder, Cantor Commercial Real Estate Lending, L.P., as initial noteA-2 holder, and Cantor Commercial Real Estate Lending, L.P., as initialsubordinate noteholder, relating to the 65 Broadway loan combination (filed asExhibit 99.11 to the registrant's Current Report on Form 8-K filed on June 19,2019 under SEC File No. 333-227446-04 and incorporated by reference herein).

 

(99.12)Co-Lender Agreement, dated as of April 30, 2019, by andbetween Cantor Commercial Real Estate Lending, L.P., as initial note A-1holder, and Cantor Commercial Real Estate Lending, L.P., as note A-2 holder,relating to the AC by Marriott San Jose loan combination (filed as Exhibit99.12 to the registrant's Current Report on Form 8-K filed on June 19, 2019 underSEC File No. 333-227446-04 and incorporated by reference herein).

 

(99.13)Agreement Between Note Holders, dated as of May 31,2019, by and between Morgan Stanley Bank, N.A., as initial note A-1-A holder,and Morgan Stanley Bank, N.A., as initial note A-1-B holder, and Morgan StanleyBank, N.A., as initial note A-3 holder, relating to the Westin Atlanta loancombination (filed as Exhibit 99.13 to the registrant's Current Report on Form8-K/A filed on February 24, 2020 under SEC File No. 333-227446-04 andincorporated by reference herein).

 

(99.14)Co-Lender Agreement, dated as of December 20, 2018, byand between Cantor Commercial Real Estate Lending, L.P., as initial note A-1holder, Cantor Commercial Real Estate Lending, L.P., as initial note A-2holder, Cantor Commercial Real Estate Lending, L.P., as initial note A-3holder, Cantor Commercial Real Estate Lending, L.P., as initial note A-4holder, Cantor Commercial Real Estate Lending, L.P., as initial note A-5holder, and Cantor Commercial Real Estate Lending, L.P., as initial note A-6holder, relating to the Shelbourne Global Portfolio II loan combination (filedas Exhibit 99.14 to the registrant's Current Report on Form 8-K filed on June 19,2019 under SEC File No. 333-227446-04 and incorporated by reference herein).

 

(99.15)Agreement Between Note Holders, dated as of March 13, 2019,by and between JPMorgan Chase Bank, National Association, as initial note A-1-1holder, initial note A-1-2 holder, initial note A-1-3 holder, initial noteA-1-4 holder, initial note A-1-5 holder, initial note A-1-6 holder, initialnote A-1-7 holder and initial note A-1-8 holder, Deutsche Bank AG, actingthrough its New York branch, as note A-2-1 holder, note A-2-2 holder, noteA-2-3 holder, note A-2-4 holder and note A-2-5 holder, JPMorgan Chase Bank,National Association, as initial note B-1 holder, and Deutsche Bank AG, actingthrough its New York branch, as note B-2 holder, relating to the 3 ColumbusCircle loan combination (filed as Exhibit 99.15 to the registrant's CurrentReport on Form 8-K filed on June 19, 2019 under SEC File No. 333-227446-04 andincorporated by reference herein).

 

(99.16)Sub-Servicing Agreement, dated as of December 1, 2018,between Wells Fargo Bank, National Association, as master servicer, andBerkeley Point Capital LLC, d/b/a Newmark Knight Frank, as sub-servicer (filedas Exhibit 99.16 to the registrant's Current Report on Form 8-K filed on June19, 2019 under SEC File No. 333-227446-04 and incorporated by reference herein).

 

(99.17)Second Amended and Restated Servicing Agreement,effective as of October 31, 2021, between Wells Fargo Bank, N.A., Wells FargoDelaware Trust Company, N.A., Computershare Trust Company, N.A., ComputershareDelaware Trust Company and Computershare Limited (filed as Exhibit 99.1 to theregistrant's Current Report on Form 8-K filed on November 5, 2021 under SECFile No. 333-227446-04 and incorporated by reference herein).

 

(b)See (a) above.

 

(c) NotApplicable.

 

**SIGNATURES**

 

Pursuantto the requirements of Section 13 or 15(d) of the Securities Exchange Act of1934, the registrant has duly caused this report to be signed on its behalf bythe undersigned, thereunto duly authorized.

 

MorganStanley Capital I Inc.

(Depositor)

 

By:/s/ Jane Lam

JaneLam, President

(seniorofficer in charge of securitization of the depositor)

 

Date: March 28, 2023