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**GRANTTHORNTON LLP**

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**REPORTOF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM**

 

 

 

 

Boardof Directors

BerkadiaCommercial Mortgage, LLC

 

Wehave examined management’s assertion, included in the accompanying Management’sReport on Assessment of Compliance with SEC Regulation AB Servicing Criteria(“Management’s Report”), that Berkadia Commercial Mortgage, LLC (the “Company”)complied with the servicing criteria set forth in Item 1122(d) of the U.S.Securities and Exchange Commission’s Regulation AB for the Master Servicing ofCommercial Mortgage Loans within Public Securitizations (the “Master ServicingPlatform” or the “Platform”) as of and for the year ended December 31, 2022,excluding criteria 1122(d)(1)(iii), 1122(d)(3)(i)(C), 1122(d)(4)(ii),1122(d)(4)(vii), and 1122(d)(4)(xv), which management has determined are notapplicable to the activities performed by the Company with respect to thePlatform. The Platform consists of the publicly issues asset-backedtransactions and securities for which the Company is named the master servicerof commercial mortgage loans. Management is responsible for the Company’scompliance with the applicable servicing criteria. Our responsibility is toexpress an opinion on management’s assertion about the Company’s compliancewith the applicable servicing criteria for the Platform based on ourexamination.

 

Ourexamination was conducted in accordance with the standards of the PublicCompany Accounting Oversight Board (United States) and in accordance withattestation standards established by the American Institute of Certified PublicAccountants, and, accordingly, included examining, on a test basis, evidenceabout the Company’s compliance with the applicable servicing criteria for thePlatform and performing such other procedures as we considered necessary in thecircumstances. Our examination included testing selected asset-backedtransactions and securities constituting the Platform and evaluating whetherthe Company performed servicing activities related to those transactions andsecurities in compliance with the applicable servicing criteria for the period coveredby this report. Accordingly, our testing may not have included servicingactivities related to each asset-backed transaction or security constitutingthe Platform. Further, our examination was not designed to detect materialnoncompliance that may have occurred prior to the period covered by this reportand that may have affected the Company’s servicing activities during the periodcovered by this report. We believe that our examination provides a reasonablebasis for our opinion. Our examination does not provide a legal determinationon the Company’s compliance with the applicable servicing criteria.

 

Weare required to be independent and to meet our other ethical responsibilitiesin accordance with relevant ethical requirements relating to the engagement.

 

Asdescribed in Management’s Report, the Company engaged various vendors toperform servicing activities with respect to criteria 1122(d)(2)(i),1122(d)(2)(iii), 1122(d)(4)(i), and 1122(d)(4)(xi) through 1122(d)(4)(xiii). TheCompany determined that each vendor is not considered a “servicer,” as thatterm is defined in Item 1101(j) of Regulation AB, and therefore, the Company isassuming responsibility for compliance with such servicing criteria applicableto each vendor’s servicing activities. In accordance with Regulation AB and itsrelated interpretations, the requirement for management to assess compliancewith the servicing criteria applicable to a vendor’s activities is satisfied ifthe Company has instituted policies and procedures to monitor whether suchvendor’s activities comply in all material respects with suchcriteria.Compliance with the applicable servicing criteria is achieved if thosepolicies and procedures are designed to provide reasonable assurance that suchvendor’s activities comply with such criteria and those policies and proceduresare operating effectively for the period covered by Management’s Report. Ourexamination does not provide a legal determination of whether a vendor is or isnot considered a servicer, and therefore, on whether the Company, in itsManagement Report, is eligible to elect to take responsibility for assessingcompliance with the servicing criteria applicable to each vendor’s servicingactivities.

 

Inour opinion, management’s assertion that Berkadia Commercial Mortgage LLCcomplied with the aforementioned applicable servicing criteria as of and forthe year ended December 31, 2022 for the Master Servicing Platform is fairlystated, in all material respects.

 

 

/s/Grant Thornton LLP

 

Philadelphia,Pennsylvania

February15, 2023

 

 

 

 

 

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