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**MANAGEMENT’SASSESSMENT OF COMPLIANCE WITH APPLICABLE SERVICING CRITERIA**

**PURSUANT TO ITEM1122 OF REGULATION AB**

 

 

Managementof Berkeley Point Capital LLC d/b/a Newmark Knight Frank (“NKF”) is responsiblefor assessing compliance with the applicable servicing criteria set forth inItem 1122(d) of Regulation AB of the Securities and Exchange Commissionrelating to its role in the servicing of commercial mortgage-backed securitiestransactions conducted by NKF (the “Platform”) as of and for the year endedDecember 31, 2019 (the “Reporting Period”). Appendix A identifies theindividual asset-backed transactions and securities defined by management asconstituting the Platform.

 

NKF’smanagement has assessed NKF’s compliance with the applicable servicing criteriaduring the Reporting Period. In making this assessment, management used thecriteria set forth by the Securities and Exchange Commission (“SEC”) inparagraph (d) of Item 1122 of Regulation AB, excluding the criteria set forthin Appendix B, which management has determined are not applicable to theservicing activities it performs with respect to the Platform.

 

Withrespect to applicable servicing criteria identified in Appendix C, therewere no activities performed for the Reporting Period with respect to thePlatform, because there was no occurrence of events that would require NKF toperform such activities.

 

Withrespect to servicing criteria 1122(d)(1)(v), 1122(d)(2)(vi) and1122(d)(2)(vii), management has engaged Midland Loan Services, a division ofPNC Bank, National Association (“Midland”) to perform the activities requiredby these servicing criteria. NKF’s management has determined that Midland isnot a “servicer” as defined in Item 1101(j) of Regulation AB, and NKF’smanagement has elected to take responsibility for assessing compliance with theservicing criteria applicable to Midland as permitted by the SEC’s Complianceand Disclosure Interpretation (“C&DI”) 200.06, Vendors Engaged by Servicers(C&DI 200.06) (formerly SEC Regulation AB Manual of Publicly AvailableTelephone Interpretations, 17.06). Management has policies and procedures inplace designed to provide reasonable assurance that Midland’s activities complyin all material respects with the servicing criteria applicable to Midland. NKFhas not identified and is not aware of any material instances of noncomplianceby Midland with the applicable servicing criteria during the Reporting Period,with respect to the Platform taken as a whole, nor has it identified anymaterial deficiencies in its policies and procedures to monitor the complianceby Midland with the applicable servicing criteria during the Reporting Periodwith respect to the Platform taken as a whole. NKF is solely responsible fordetermining that it meets the SEC requirements to apply C&DI 200.06 forMidland and the related criteria.

 

Basedon such assessment, management believes that with respect to the ReportingPeriod, NKF has complied in all material respects with the servicing criteriaset forth in Item 1122(d) of Regulation AB of the SEC, including servicingcriteria 1122(d)(1)(v), 1122(d)(2)(vi) and 1122(d)(2)(vii) for which complianceis determined based on C&DI 200.06 as described above relating to its rolein the servicing of the Platform.

 

Ernstand Young LLP, an independent registered public accounting firm, has issued anattestation report with respect to management’s assessment of compliance withthe applicable servicing criteria with respect to the Reporting Period.

 

 

By:Berkeley Point Capital LLC,

      dba Newmark Knight Frank

 

 

/s/Ronald Steffenino

RonaldSteffenino

SeniorManaging Director

 

2/24/2020

Date

 

 

/s/Mike Rispoli

MikeRispoli

ChiefFinancial Officer

 

2/24/2020

Date

 

 

**Appendix A toManagement’s Assessment**

 

| COMM  2014-CCRE 17 Mortgage Trust Commercial Mortgage Pass-Through Certificates                                |
|----------------------------------------------------------------------------------------------------------------|
| COMM  2014-UBS4 Mortgage Trust Commercial Mortgage Pass-Through Certificates                                   |
| COMM  2014-CCRE19 Mortgage Trust Commercial Mortgage Pass-Through Certificates                                 |
| GS  Mortgage Securities Trust 2014-GC24 Commercial Mortgage Pass-Through  Certificates Series 2014-GC24        |
| COMM  2014-CCRE20 Mortgage Trust Commercial Mortgage Pass-Through Certificates                                 |
| Commercial  Mortgage Pass-Through Certificates Series 2014-FL2                                                 |
| COMM  2015-LC19 Mortgage Trust Commercial Mortgage Pass-Through Certificates                                   |
| GS  Mortgage Securities Trust 2015-GC28 Commercial Mortgage Pass-Through  Certificates Series 2015-GC28        |
| GS  Mortgage Securities Trust 2015-GC30 Commercial Mortgage Pass-Through  Certificates Series 2015-GC30        |
| Commercial  Mortgage Pass-Through Certificates Series 2015-CCRE23                                              |
| Commercial  Mortgage Pass-Through Certificates Series 2015-LC21                                                |
| COMM  2015-CCRE24 Mortgage Trust Commercial Mortgage Pass-Through Certificates                                 |
| COMM  2015-CCRE26 Mortgage Trust Commercial Mortgage Pass-Through Certificates                                 |
| COMM  2015 CCRE27 Mortgage Trust Commercial Mortgage Pass-Through Certificates                                 |
| GS  Mortgage Securities Trust 2015-GC34 Commercial Mortgage Pass-Through  Certificates Series 2015-GC34        |
| COMM  2015-LC23 Mortgage Trust Commercial Mortgage Pass-Through Certificates Series  2015-LC3                  |
| CFCRE  2016-C3 Mortgage Trust Commercial Mortgage Pass-Through Certificates, Series  2016-C3                   |
| CCRESG  Commercial Mortgage Trust 2016-HEAT Commercial Mortgage Pass-Through  Certificates, Series 2016-HEAT   |
| CFCRE  2016-C4 Mortgage Trust Commercial Mortgage Pass-through Certificates, Series  2016-C4                   |
| Citigroup  Commercial Mortgage Trust 2016-C1, Commercial Mortgage Pass-through  Certificates, Series 2016-C1   |
| SG  Commercial Mortgage Securities Trust 2016-C5 Commercial Mortgage Pass-Through  Certificates Series 2016-C5 |
| Citigroup  Commercial Mortgage Trust 2016-C3, Commercial Mortgage Pass-through  Certificates, Series 2016-C3   |
| CFCRE  2016-C6 Mortgage Trust Commercial Mortgage Pass-Through Certificates Series  2016-C6                    |
| CFCRE  2016-C7 Commercial Mortgage Pass-Through Certificates                                                   |
| CFCRE  2017-C8 Mortgage Trust Commercial Mortgage Pass-Through Certificates, Series  2017-C8                   |
| UBS  Commercial Mortgage Trust 2017-C4 Commercial Mortgage Pass-Through  Certificates Series 2017-C4           |
| UBS  Commercial Mortgage Trust 2017-C5 Commercial Mortgage Pass-Through  Certificates Series 2017-C5           |
| UBS  Commercial Mortgage Trust 2017-C6 Commercial Mortgage Pass-Through  Certificates Series 2017-C6           |
| Citigroup  Commercial Mortgage Trust 2017-C4 Commercial Mortgage Pass-Through  Certificates Series 2017-C4     |
| CCUBS  Commercial Mortgage Trust 2017-C1 Commercial Mortgage Pass-Through  Certificates Series 2017-C1         |
| UBS  Commercial Mortgage Trust 2018-C8 Commercial Mortgage Pass-Through  Certificates Series 2018-C8           |
| UBS  Commercial Mortgage Trust 2018-C9 Commercial Mortgage Pass-Through  Certificates, Series 2018-C9          |
| Benchmark  2018-B3 commercial Mortgage Pass-Through Certificates Series 2018-B3                                |
| UBS  Commercial Mortgage Trust 2018-C10 Commercial Mortgage Pass-through  Certificates, Series 2018-C10        |
| UBS  Commercial Mortgage Trust 2018-C12 Commercial Mortgage Pass-Through  Certificates, Series 2018-C12        |
| Morgan  Stanley Capital I Trust 2018-L1 Commercial Mortgage Pass-Through  Certificates, Series 2018-L1         |
| UBS  Commercial Mortgage Trust 2018-C14 Commercial Mortgage Pass-Through  Certificates Series 2018 C14         |
| Citigroup  Commercial Mortgage Trust 2018-C6 Commercial Mortgage Pass-Through  Certificates Series 2018-C6     |
| BBCMS  Mortgage Trust 2018 C2 Commercial Mortgage Pass-Through Certificates, Series  2018-C2                   |
| Morgan  Stanley Capital I Trust 2018 H4 Commercial Mortgage Pass-Through Series 2018  H4                       |
| Morgan  Stanley Capital I Trust 2019 L2 Commercial Mortgage Pass-Through Certificates  Series 2019-L2          |
| CF  2019 CF1 Mortgage Trust Commercial Mortgage Pass-Through Certificates Series  2019-CF1                     |

 

 

**Appendix B toManagement’s Assessment**

 

 

RegulationAB Item 1122(d) criteria determined to be not applicable:

 

·        1122(d)(1)(iii)

·        1122(d)(2)(ii)

·        1122(d)(2)(iii)

·        1122(d)(3)(i)

·        1122(d)(3)(ii)

·        1122(d)(3)(iv)

·        1122(d)(4)(ii)

·        1122(d)(4)(vii)

·        1122(d)(4)(xv)

 

 

**Appendix C toManagement’s Assessment**

 

 

RegulationAB Item 1122(d) criteria that NKF is under contract to perform the activities required,but for which there were no occurrences of events for the year ended December31, 2019 that required them to perform such activities:

 

·        1122(d)(4)(i)

·        1122(d)(4)(iii)

·        1122(d)(4)(vi)

·        1122(d)(4)(viii)

·        1122(d)(4)(xii)

·        1122(d)(4)(xiv)

 

 

2019BPC d/b/a NKF Management Assessment Letter