**UNITED STATESSECURITIES AND EXCHANGE COMMISSION**

**Washington, D.C. 20549**

**FORM 10-K**

(Mark One)

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

**For the fiscal year ended December 31, 2019or**

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

**For the transition period from _____ to _____Commission file number of the issuing entity: 333-226123-03**

**Central Index Key Number of the issuing entity:0001775756**

**Benchmark 2019-B11 Mortgage Trust**

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

** **

**Central Index Key Number of the depositor: 0001013611**

**J.P. Morgan Chase CommercialMortgage Securities Corp.**

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

** **

**Central Index Key Number of the sponsor: 0000835271**

**JPMorgan Chase Bank, NationalAssociation**

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

** **

**Central Index Key Number of the sponsor: 0001541294**

**German American Capital Corporation**

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

** **

**Central Index Key Number of the sponsor: 0001701238**

**Citi Real Estate Funding Inc.**

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

** **

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

**the issuing entity)** | **38-4117359**

**38-4117360**

**38-7221329**

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

**Identification Number)** |
|------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------|

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

**as Certificate Administrator**

**9062 Old Annapolis Road**

**Columbia, MD**

**(Address of principalexecutive offices of the issuing entity)**

**21045**

**(Zip Code)**

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

**(212) 834-5467**

 

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

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

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

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

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

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

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

Not applicable.

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

Not applicable.

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

Large acceleratedfiler        o                                                                                                       Acceleratedfiler                                     o

Non-acceleratedfiler          ⌧  (Do not check ifa smaller reporting company)                          Smaller reporting company                    o

                                                                                                                                                       Emerging growthcompany                    o

If an emerging growth company, indicate by check mark if theregistrant has elected not to use the extended transition period for complying withany new or revised financial accounting standards provided pursuant to Section13(a) of the Exchange Act.  o

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

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

Not applicable.

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

Not applicable.

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

Not applicable.

**DOCUMENTS INCORPORATED BY REFERENCE**

** **

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

Not applicable.

 

** **

**EXPLANATORY NOTES**

The Green Hills Corporate Center MortgageLoan, the Western Digital R&D Campus Mortgage Loan and the Greenleaf atHowell Mortgage Loan, which constituted approximately 4.5%, 3.5% and 2.4%,respectively, of the asset pool of the issuing entity as of its cut-off date,are each an asset of the issuing entity and are each part of a loan combinationthat includes the Green Hills Corporate Center Mortgage Loan, the WesternDigital R&D Campus Mortgage Loan or the Greenleaf at Howell Mortgage Loanwhich are assets of the issuing entity and one other *pari passu* loan,which is not an asset of the issuing entity. These loan combinations, includingthe Green Hills Corporate Center Mortgage Loan, the Western Digital R&DCampus Mortgage Loan and the Greenleaf at Howell Mortgage Loan, are beingserviced and administered pursuant to the Pooling and Servicing Agreement,which is incorporated by reference as Exhibit 4.1 to this Annual Report on Form10-K. 

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the 101 California Mortgage Loan, whichconstituted approximately 4.5% of the asset pool of the issuing entity as ofits cut-off date.  The 101 California Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the 101California Mortgage Loan and seven other *pari passu* loans and twosubordinate companion loans, which are not assets of the issuing entity. A *paripassu* portion of the loan combination was securitized in the CALI MortgageTrust 2019-101C transaction (the “CALI 2019-101C Transaction”). Thisloan combination, including the 101 California Mortgage Loan, is being servicedand administered pursuant to the trust and servicing agreement for the CALI2019-101C Transaction, which is incorporated by reference as Exhibit 4.2 tothis Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the ILPT Hawaii Portfolio Mortgage Loan, whichconstituted approximately 7.1% of the asset pool of the issuing entity as ofits cut-off date.  The ILPT Hawaii Portfolio Mortgage Loan is an asset ofthe issuing entity and is part of a loan combination that includes the ILPTHawaii Portfolio Mortgage Loan and fifteen other *pari passu* loans, whichare not assets of the issuing entity. A *pari passu* portion of the loancombination was securitized in the ILPT Trust 2019-SURF transaction (the “ILPT2019-SURF Transaction”). This loan combination, including the ILPT HawaiiPortfolio Mortgage Loan, is being serviced and administered pursuant to thetrust and servicing agreement for the ILPT 2019-SURF Transaction, which is incorporatedby reference as Exhibit 4.3 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the 3 Columbus Circle Mortgage Loan, which constitutedapproximately 9.1% of the asset pool of the issuing entity as of its cut-offdate.  The 3 Columbus Circle Mortgage Loan is an asset of the issuingentity and is part of a loan combination that includes the 3 Columbus CircleMortgage Loan and thirteen other *pari passu* loans and two subordinatecompanion loans, which are not assets of the issuing entity. A *pari passu*portion of the loan combination was securitized in the Benchmark 2019-B10Mortgage Trust transaction, Commission File Number 333-226943-02 (the “BMARK2019-B10 Transaction”). This loan combination, including the 3 ColumbusCircle Mortgage Loan, is being serviced and administered pursuant to thepooling and servicing agreement for the BMARK 2019-B10 Transaction, which isincorporated by reference as Exhibit 4.4 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Heartland Dental Medical Office PortfolioMortgage Loan, which constituted approximately 1.8% of the asset pool of theissuing entity as of its cut-off date.  The Heartland Dental MedicalOffice Portfolio Mortgage Loan is an asset of the issuing entity and is part ofa loan combination that includes the Heartland Dental Medical Office PortfolioMortgage Loan and ten other *pari passu* loans, which are not assets ofthe issuing entity. A *pari passu* portion of the loan combination wassecuritized in the Wells Fargo Commercial Mortgage Trust 2019-C50 transaction,Commission File Number 333-226486-05 (the “WFCM 2019-C50 Transaction”).This loan combination, including the Heartland Dental Medical Office PortfolioMortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the WFCM 2019-C50 Transaction, which is incorporated byreference as Exhibit 4.5 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the 59 Maiden Lane Mortgage Loan, the ArborHotel Portfolio Mortgage Loan, the Moffett Towers II - Building V Mortgage Loanand the Lakeside Apartments Mortgage Loan, which constituted approximately6.8%, 4.5%, 3.9% and 3.2%, respectively, of the asset pool of the issuingentity as of its cut-off date.  The 59 Maiden Lane Mortgage Loan, theArbor Hotel Portfolio Mortgage Loan, the Moffett Towers II - Building VMortgage Loan and the Lakeside Apartments Mortgage Loan are each an asset ofthe issuing entity and are each part of a loan combination that includes (a)with respect to the 59 Maiden Lane Mortgage Loan and two other *pari passu*loans, which are not assets of the issuing entity, (b) with respect to theArbor Hotel Portfolio Mortgage Loan and one other *pari passu* loan, whichis not an asset of the issuing entity, (c) with respect to the Moffett TowersII - Building V Mortgage Loan and three other *pari passu* loans and foursubordinate companion loans, which are not assets of the issuing entity or (d)with respect to the Lakeside Apartments Mortgage Loan and one other *paripassu* loan, which is not an asset of the issuing entity. A *pari passu*portion of each loan combination was securitized in the GS Mortgage SecuritiesTrust 2019-GC39 transaction, Commission File Number 333-226082-02 (the “GSMS2019-GC39 Transaction”). These loan combinations, including the 59 MaidenLane Mortgage Loan, the Arbor Hotel Portfolio Mortgage Loan, the Moffett TowersII - Building V Mortgage Loan and the Lakeside Apartments Mortgage Loan, arebeing serviced and administered pursuant to the pooling and servicing agreementfor the GSMS 2019-GC39 Transaction, which is incorporated by reference asExhibit 4.6 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Newport Corporate Center Mortgage Loan andthe Central Tower Office Mortgage Loan, which constituted approximately 3.7%and 3.1%, respectively, of the asset pool of the issuing entity as of itscut-off date.  The Newport Corporate Center Mortgage Loan and the CentralTower Office Mortgage Loan are each an asset of the issuing entity and are eachpart of a loan combination that includes (a) with respect to the Newport CorporateCenter Mortgage Loan and three other *pari passu* loans and tensubordinate companion loans, which are not assets of the issuing entity or (b)with respect to the Central Tower Office Mortgage Loan and one other *paripassu* loan, which is not an asset of the issuing entity. A *pari passu*portion of each loan combination was securitized in the BANK 2019-BNK18transaction, Commission File Number 333-228375-01 (the “BANK 2019-BNK18Transaction”). These loan combinations, including the Newport CorporateCenter Mortgage Loan and the Central Tower Office Mortgage Loan, are beingserviced and administered pursuant to the pooling and servicing agreement forthe BANK 2019-BNK18 Transaction, which is incorporated by reference as Exhibit4.7 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the SWVP Portfolio Mortgage Loan, whichconstituted approximately 4.5% of the asset pool of the issuing entity as ofits cut-off date.  The SWVP Portfolio Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the SWVPPortfolio Mortgage Loan and eight other *pari passu* loans, which are notassets of the issuing entity. A *pari passu* portion of the loancombination was securitized in the BBCMS Mortgage Trust 2019-C3 transaction,Commission File Number 333-226850-02 (the “BBCMS 2019-C3 Transaction”).This loan combination, including the SWVP Portfolio Mortgage Loan, is beingserviced and administered pursuant to the pooling and servicing agreement forthe BBCMS 2019-C3 Transaction, which is incorporated by reference as Exhibit4.8 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the 57 East 11th Street Mortgage Loan, whichconstituted approximately 1.8% of the asset pool of the issuing entity as ofits cut-off date.  The 57 East 11th Street Mortgage Loan is an asset ofthe issuing entity and is part of a loan combination that includes the 57 East11th Street Mortgage Loan and two other *pari passu* loans, which are notassets of the issuing entity. This loan combination, including the 57 East 11thStreet Mortgage Loan, was serviced under the pooling and servicing agreementfor the GSMS 2019-GC39 transaction prior to the closing of the securitizationof a *pari passu* portion of the 57 East 11th Street loan combination inthe GS Mortgage Securities Trust 2019-GC40 transaction, Commission File Number333-226082-03 (the “GSMS 2019-GC40 Transaction”).  After theclosing of the GSMS 2019-GC40 Transaction on July 11, 2019, this loancombination, including the 57 East 11th Street Mortgage Loan was, and willcontinue to be, serviced and administered pursuant to the pooling and servicingagreement with respect to the GSMS 2019-GC40 Transaction, which is incorporatedby reference as Exhibit 4.9 to this Annual Report on Form 10-K.

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

Midland Loan Services, a Divisionof PNC Bank, National Association is the master servicer of the mortgage loansserviced under the Pooling and Servicing Agreement, the primary servicer andspecial servicer of the SWVP Portfolio Mortgage Loan, the 101 CaliforniaMortgage Loan and the 57 East 11th Street Mortgage Loan and the primaryservicer of the 3 Columbus Circle Mortgage Loan, the ILPT Hawaii PortfolioMortgage Loan, the 59 Maiden Lane Mortgage Loan, the Arbor Hotel PortfolioMortgage Loan, the Moffett Towers II - Building V Mortgage Loan and theHeartland Dental Medical Office Portfolio Mortgage Loan. As a result, MidlandLoan Services, a Division of PNC Bank, National Association is a “servicer” asdefined in Item 1108(a)(2)(iii) of Regulation AB, in the capacities describedabove, because it is servicing mortgage loans that constituted 10% or more ofthe assets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria, accountants’ attestation reportsand servicer compliance statements delivered by Midland Loan Services, aDivision of PNC Bank, National Association in the capacities described aboveare listed in the Exhibit Index.

Rialto Capital Advisors, LLC isthe special servicer of the mortgage loans serviced under the Pooling and ServicingAgreement, the ILPT Hawaii Portfolio Mortgage Loan, the Central Tower OfficeMortgage Loan and the Heartland Dental Medical Office Portfolio Mortgage Loan.As a result, Rialto Capital Advisors, LLC is a “servicer” as defined in Item1108(a)(2)(iii) of Regulation AB, in the capacities described above, because itis servicing mortgage loans that constituted 10% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria, accountants’ attestation reports and servicercompliance statements delivered by Rialto Capital Advisors, LLC in thecapacities described above are listed in the Exhibit Index.

Wells Fargo Bank, NationalAssociation is the certificate administrator of the mortgage loans servicedunder the Pooling and Servicing Agreement and the primary servicer of theNewport Corporate Center Mortgage Loan and the Central Tower Office MortgageLoan. As a result, Wells Fargo Bank, National Association is a “servicer” asdefined in Item 1108(a)(2)(iii) of Regulation AB, in the capacities describedabove, because it is servicing mortgage loans that constituted 10% or more ofthe assets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria, accountants’ attestation reportsand servicer compliance statements delivered by Wells Fargo Bank, NationalAssociation in the capacities described above are listed in the Exhibit Index.

Wells Fargo Bank, National Association is the custodian ofthe mortgage loans serviced under the Pooling and Servicing Agreement, the 3Columbus Circle Mortgage Loan, the ILPT Hawaii Portfolio Mortgage Loan, the 59Maiden Lane Mortgage Loan, the 101 California Mortgage Loan, the Arbor HotelPortfolio Mortgage Loan, the SWVP Portfolio Mortgage Loan, the Moffett TowersII - Building V Mortgage Loan, the Lakeside Apartments Mortgage Loan, the 57East 11th Street Mortgage Loan, the Newport Corporate Center Mortgage Loan, theCentral Tower Office Mortgage Loan and the Heartland Dental Medical OfficePortfolio Mortgage Loan.  As a result, Wells Fargo Bank, NationalAssociation is a servicing function participant in the capacities describedabove, because it is servicing mortgage loans that constituted 5% or more ofthe assets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria and accountants’ attestationreports delivered by Wells Fargo Bank, National Association in the capacitiesdescribed above are listed in the Exhibit Index.

Pentalpha Surveillance LLC is the operating advisor of themortgage loans serviced under the Pooling and Servicing Agreement, the 3Columbus Circle Mortgage Loan, the SWVP Portfolio Mortgage Loan, the NewportCorporate Center Mortgage Loan, the Central Tower Office Mortgage Loan and the57 East 11th Street Mortgage Loan and the 101 California Mortgage Loan. As a result, Pentalpha Surveillance LLC is a servicing function participant inthe capacities described above, because it is servicing mortgage loans thatconstituted 5% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria andaccountants’ attestation reports delivered by Pentalpha Surveillance LLC in thecapacities described above are listed in the Exhibit Index.

Park Bridge Lender Services LLC is the operating advisor ofthe ILPT Hawaii Portfolio Mortgage Loan, the 59 Maiden Lane Mortgage Loan, theArbor Hotel Portfolio Mortgage Loan, the Moffett Towers II - Building VMortgage Loan, the Lakeside Apartments Mortgage Loan and the Heartland DentalMedical Office Portfolio Mortgage Loan.  As a result, Park Bridge LenderServices LLC is a servicing function participant in the capacities describedabove, because it is servicing mortgage loans that constituted 5% or more ofthe assets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria and accountants’ attestationreports delivered by Park Bridge Lender Services LLC in the capacitiesdescribed above are listed in the Exhibit Index.

KeyBank National Association isthe special servicer of the 59 Maiden Lane Mortgage Loan, the Arbor HotelPortfolio Mortgage Loan, the Moffett Towers II - Building V Mortgage Loan andthe Lakeside Apartments Mortgage Loan. As a result, KeyBank NationalAssociation is a “servicer” as defined in Item 1108(a)(2)(iii) of RegulationAB, in the capacities described above, because it is servicing mortgage loansthat constituted 10% or more of the assets of the issuing entity as of itscut-off date. The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby KeyBank National Association in the capacities described above are listed inthe Exhibit Index.

Wells Fargo Bank, NationalAssociation acts as trustee of the Green Hills Corporate Center Mortgage Loan,the Western Digital R&D Campus Mortgage Loan, the Greenleaf at HowellMortgage Loan, the 101 California Mortgage Loan, the ILPT Hawaii PortfolioMortgage Loan, the 3 Columbus Circle Mortgage Loan, the 59 Maiden Lane MortgageLoan, the Arbor Hotel Portfolio Mortgage Loan, the Moffett Towers II - BuildingV Mortgage Loan, the Lakeside Apartments Mortgage Loan, the SWVP PortfolioMortgage Loan and the 57 East 11th Street Mortgage Loan.  Pursuant to thePooling and Servicing Agreement, the pooling and servicing agreement for theCALI 2019-101C Transaction, the pooling and servicing agreement for the ILPT2019-SURF Transaction, the pooling and servicing agreement for the BMARK2019-B10 Transaction, the pooling and servicing agreement for the GSMS2019-GC39 Transaction, the pooling and servicing agreement for the BBCMS2019-C3 Transaction and the pooling and servicing agreement for the GSMS2019-GC40 Transaction, the trustee is required to provide an assessment ofcompliance with applicable servicing criteria solely with respect to Item1122(d)(2)(iii) of Regulation AB (regarding advances of funds or guarantees regardingcollections, cash flows or distributions, and any interest or other feescharged for such advances, are made, reviewed and approved as specified in thetransaction agreements). However, during the reporting period, the trustee didnot perform any servicing function with respect to the servicing criteriaspecified in Item 1122(d)(2)(iii) of Regulation AB.  The master serviceror the special servicer, to the extent required, performed the servicingfunction identified with respect to Item 1122(d)(2)(iii) of Regulation AB, andeach such party included Item 1122(d)(2)(iii) of Regulation AB in theassessment of compliance with applicable servicing criteria and accountant’sattestation report for the subject transaction.  As a result, this AnnualReport on Form 10-K does not include an assessment of compliance withapplicable servicing criteria of the trustee. One or more other servicers ofthe mortgage loans serviced under the Pooling and Servicing Agreement, the 101California Mortgage Loan, the ILPT Hawaii Portfolio Mortgage Loan, the 3Columbus Circle Mortgage Loan, the 59 Maiden Lane Mortgage Loan, the ArborHotel Portfolio Mortgage Loan, the Moffett Towers II - Building V MortgageLoan, the Lakeside Apartments Mortgage Loan, the SWVP Portfolio Mortgage Loanand the 57 East 11th Street Mortgage Loan have delivered one or moreassessments of compliance with respect to Item 1122(d)(2)(iii) of RegulationAB.

Wilmington Trust, NationalAssociation acts as trustee of the Heartland Dental Medical Office PortfolioMortgage Loan, the Newport Corporate Center Mortgage Loan and the Central TowerOffice Mortgage Loan.  Pursuant to the pooling and servicing agreement forthe WFCM 2019-C50 Transaction and the pooling and servicing agreement for theBANK 2019-BNK18 Transaction, the trustee is required to provide an assessmentof compliance with applicable servicing criteria solely with respect to Item1122(d)(2)(iii) of Regulation AB (regarding advances of funds or guaranteesregarding collections, cash flows or distributions, and any interest or otherfees charged for such advances, are made, reviewed and approved as specified inthe transaction agreements). However, during the reporting period, the trusteedid not perform any servicing function with respect to the servicing criteriaspecified in Item 1122(d)(2)(iii) of Regulation AB.  The master serviceror the special servicer, to the extent required, performed the servicingfunction identified with respect to Item 1122(d)(2)(iii) of Regulation AB, andeach such party included Item 1122(d)(2)(iii) of Regulation AB in theassessment of compliance with applicable servicing criteria and accountant’sattestation report for the subject transaction.  As a result, this AnnualReport on Form 10-K does not include an assessment of compliance withapplicable servicing criteria of the trustee. One or more other servicers ofthe Heartland Dental Medical Office Portfolio Mortgage Loan, the NewportCorporate Center Mortgage Loan and the Central Tower Office Mortgage Loan havedelivered one or more assessments of compliance with respect to Item1122(d)(2)(iii) of Regulation AB.

This Annual Report on Form 10-Kincludes assessments of compliance with applicable servicing criteria andaccountants’ attestation reports from CoreLogic Commercial Real EstateServices, Inc. and National Tax Search, LLC.  These entities were engagedby the primary servicer of the Heartland Dental Medical Office PortfolioMortgage Loan, the Newport Corporate Center Mortgage Loan and the Central TowerOffice Mortgage Loan to remit tax payments received from the escrow accounts ofborrowers to local taxing authorities, to report tax amounts due, to verify taxparcel information, and to verify non-escrow tax payments. These servicingfunctions are included within the servicing criteria set forth in Items1122(d)(4)(xi) and 1122(d)(4)(xii) of Regulation AB.  Therefore, under theprinciples-based definition of “servicer” set forth in Item 1101(j) ofRegulation AB that looks to the functions that an entity performs, thesevendors are “servicers” for the purposes of Item 1122 of Regulation AB.  *See*Compliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

Theassessments of compliance with applicable servicing criteria, accountants’attestation reports and servicer compliance statements of the certificateadministrator of the 101 California Mortgage Loan, the ILPT Hawaii PortfolioMortgage Loan, the 3 Columbus Circle Mortgage Loan, the Heartland DentalMedical Office Portfolio Mortgage Loan, the 59 Maiden Lane Mortgage Loan, theArbor Hotel Portfolio Mortgage Loan, the Moffett Towers II - Building VMortgage Loan, the Lakeside Apartments Mortgage Loan, the Newport CorporateCenter Mortgage Loan, the Central Tower Office Mortgage Loan, the SWVPPortfolio Mortgage Loan and the 57 East 11th Street Mortgage Loan listed on theExhibit Index are omitted from this Annual Report on Form 10-K as thecertificate administrator pursuant to the related pooling and servicingagreement or trust and servicing agreement does not perform any activities thataddress servicing criteria with respect to the issuing entity and because theyare each not a “servicer” that meets the criteria in Item 1108(a)(2)(i) through(iii) of Regulation AB.

With respect to the *pari passu*loan combinations that include the Lakeside Apartments Mortgage Loan, the 3Columbus Circle Mortgage Loan and the Newport Corporate Center Mortgage Loan,(i) the reports on assessment of compliance with servicing criteria andattestation reports on assessment of compliance with servicing criteria ofBerkadia Commercial Mortgage LLC as primary servicer of the Lakeside ApartmentsMortgage Loan and Situs Holdings, LLC as special servicer of the NewportCorporate Center Mortgage Loan, listed on the Exhibit Index are omitted fromthis Annual Report on Form 10-K as they are not required to be included on thisAnnual Report on Form 10-K per Instruction 3 to Item 1122 of Regulation ABbecause they are parties performing activities that address servicing criteriarelating to 5% or less of the assets of the issuing entity; and (ii) theservicer compliance statements of Berkadia Commercial Mortgage LLC as primaryservicer of the Lakeside Apartments Mortgage Loan, LNR Partners, LLC as specialservicer of the 3 Columbus Circle Mortgage Loan and Situs Holdings, LLC asspecial servicer of the Newport Corporate Center Mortgage Loan, listed on theExhibit Index are omitted from this Annual Report on Form 10-K as they are notrequired by Item 1123 of Regulation AB to be included on this Annual Report onForm 10-K because they are each an unaffiliated party that is not a “servicer”that meets the criteria in Item 1108(a)(2)(i) through (iii) of Regulation AB.

Situs Holdings LLC acts as EUreporting administrator with respect to the mortgage loans serviced under thePooling and Servicing Agreement.  However, during the reporting period,the EU reporting administrator did not perform any servicing functions withrespect to the mortgage loans serviced under the Pooling and Servicing Agreement;accordingly, the assessment of compliance with applicable servicing criteriaand accountant’s attestation report are omitted from this Annual Report on Form10-K.

**PART I**

**Item 1.  Business.**

Omitted.

**Item 1A.  Risk Factors.**

Omitted.

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

None.

**Item 2.  Properties.**

Omitted.

**Item 3.  Legal Proceedings.**

Omitted.

**Item 4.  Mine Safety Disclosures.**

Not applicable.

**PART II**

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

Omitted.

**Item 6.  Selected Financial Data.**

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**Item 9.  Changes in and Disagreements WithAccountants on Accounting and Financial Disclosure.**

Omitted.

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

Omitted.

**Item 9B.  Other Information.**

None.

**PART III**

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

Omitted.

**Item 11.  Executive Compensation.**

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**ADDITIONAL DISCLOSURE ITEMS FOR REGULATION AB**

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

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

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

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

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

No entity or group of affiliated entities provides any derivativeinstruments or other support for the certificates within this transaction asdescribed under Item 1115 of Regulation AB.

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

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

Beginning on June 18, 2014, a group of institutionalinvestors filed civil complaints in the Supreme Court of the State of New York,New York County, and later the U.S. District Court for the Southern District ofNew York, against Wells Fargo Bank, N.A., (“Wells Fargo Bank”) in itscapacity as trustee for certain residential mortgage backed securities (“RMBS”)trusts.  The complaints against Wells Fargo Bank alleged that the trusteecaused losses to investors and asserted causes of action based upon, amongother things, the trustee's alleged failure to: (i) notify and enforcerepurchase obligations of mortgage loan sellers for purported breaches ofrepresentations and warranties, (ii) notify investors of alleged events ofdefault, and (iii) abide by appropriate standards of care following allegedevents of default. Relief sought included money damages in an unspecifiedamount, reimbursement of expenses, and equitable relief. In November 2018,Wells Fargo Bank reached an agreement, in which it denied any wrongdoing, toresolve such claims on a classwide basis for the 271 RMBS trusts atissue.  On May 6, 2019, the court entered an order approving thesettlement agreement.  Separate lawsuits against Wells Fargo Bank makingsimilar allegations filed by certain other institutional investors concerningseveral RMBS trusts in New York federal and state court are not covered by theagreement.  With respect to such litigations, Wells Fargo Bank believesplaintiffs' claims are without merit and intends to contest the claimsvigorously, but there can be no assurances as to the outcome of the litigationsor the possible impact of the litigations on Wells Fargo Bank or the RMBStrusts.

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

The information regarding this Item has been previouslyprovided in the prospectus of the Registrant relating to the issuing entityfiled on June 17, 2019 pursuant to Rule 424(b)(2).

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

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

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the 101 California Mortgage Loan,which is being serviced and administered pursuant to the trust and servicingagreement for the CALI 2019-101C Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit L to the trust andservicing agreement for the CALI 2019-101C Transaction incorporated byreference as Exhibit 4.2 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the CALI2019-101C Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the ILPT Hawaii Portfolio MortgageLoan, which is being serviced and administered pursuant to the trust andservicing agreement for the ILPT 2019-SURF Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit L to thetrust and servicing agreement for the ILPT 2019-SURF Transaction incorporatedby reference as Exhibit 4.3 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the ILPT2019-SURF Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the 3 Columbus Circle Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the BMARK 2019-B10 Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Schedule II to the pooling andservicing agreement for the BMARK 2019-B10 Transaction incorporated byreference as Exhibit 4.4 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the BMARK2019-B10 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Heartland Dental Medical OfficePortfolio Mortgage Loan, which is being serviced and administered pursuant tothe pooling and servicing agreement for the WFCM 2019-C50 Transaction, areattached hereto under Item 15 to this Annual Report on Form 10-K. Attached asExhibit AA to the pooling and servicing agreement for the WFCM 2019-C50Transaction incorporated by reference as Exhibit 4.5 to this Annual Report onForm 10-K is a chart identifying the entities participating in a servicingfunction for the WFCM 2019-C50 Transaction responsible for each applicableservicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the 59 Maiden Lane Mortgage Loan, theArbor Hotel Portfolio Mortgage Loan, the Moffett Towers II - Building VMortgage Loan and the Lakeside Apartments Mortgage Loan, which are beingserviced and administered pursuant to the pooling and servicing agreement forthe GSMS 2019-GC39 Transaction, are attached hereto under Item 15 to thisAnnual Report on Form 10-K. Attached as Exhibit AA to the pooling and servicingagreement for the GSMS 2019-GC39 Transaction incorporated by reference as Exhibit4.6 to this Annual Report on Form 10-K is a chart identifying the entitiesparticipating in a servicing function for the GSMS 2019-GC39 Transactionresponsible for each applicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Newport Corporate Center MortgageLoan and the Central Tower Office Mortgage Loan, which are being serviced andadministered pursuant to the pooling and servicing agreement for the BANK2019-BNK18 Transaction, are attached hereto under Item 15 to this Annual Reporton Form 10-K. Attached as Exhibit Z to the pooling and servicing agreement forthe BANK 2019-BNK18 Transaction incorporated by reference as Exhibit 4.7 tothis Annual Report on Form 10-K is a chart identifying the entitiesparticipating in a servicing function for the BANK 2019-BNK18 Transactionresponsible for each applicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the SWVP Portfolio Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the BBCMS 2019-C3 Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit AA to the pooling andservicing agreement for the BBCMS 2019-C3 Transaction incorporated by referenceas Exhibit 4.8 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the BBCMS 2019-C3Transaction responsible for each applicable servicing criteria set forth inItem 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the 57 East 11th Street MortgageLoan, which is being serviced and administered pursuant to the pooling andservicing agreement for the GSMS 2019-GC40 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit AA to thepooling and servicing agreement for the GSMS 2019-GC40 Transaction incorporatedby reference as Exhibit 4.9 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the GSMS2019-GC40 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The report on assessment of compliance with applicableservicing criteria furnished pursuant to Item 1122 of Regulation AB by MidlandLoan Services, a Division of PNC Bank National Association (“Midland”)discloses that a material instance of noncompliance occurred, as describedbelow:

Material Instance of Noncompliance

In certain instances, the ScheduleAL Files (Item 1125 of Regulation AB) were not reported in accordance with theterms specified in the transaction agreements, in conflict with Item1122(d)(3)(i): “Reports to investors, including those to be filed with theCommission, are maintained in accordance with the transaction agreements andapplicable Commission requirements. Specifically, such reports: (A) Are preparedin accordance with timeframes and other terms set forth in the transactionagreements”.  The noncompliance consisted of omitted or inaccuratelyreported fields as described in (1) and (2) below.  (1) In connection withother enhancements Midland made to its manual Schedule AL process, starting inApril 2019, Midland developed and implemented new Schedule AL reportingtemplates for each applicable CMBS transaction that closed prior to April 2019and for each applicable CMBS transaction going forward.  Related to this,Midland made certain template setup errors, along with related and other manualinputting of information errors, and the errors were not identified prior tosubmission of the applicable Schedule AL Files in certain cases due tobreakdowns in quality control.  (2) In one applicable transaction, therelated Schedule AL File for a given month was not saved properly resulting inthe prior month's Schedule AL File being submitted for the given month insteadof the correct Schedule AL File. 

The identified instances did notinvolve the servicing of assets included in this securitization.

Steps Taken to Remedy the Material Instance of Noncompliance

Midland’s Schedule AL reportingprocess was enhanced in April of 2019, however, the process remained manualthroughout the 2019 calendar year.  Errors relating to certain Schedule ALFiles during 2019 were identified during the related audit.  Followingidentification, Midland made staffing changes and additional enhancements andimprovements to its processes and procedures to support its Schedule ALreporting obligations and expects to move to an automated solution for thisprocess.  

Midland is currently remediating theSchedule AL reporting for certain of the CMBS transactions found to beincorrect. 

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

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

**PART IV**

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

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

(1) Not applicable

(2) Not applicable

(3) See below

 

4.1          Poolingand Servicing Agreement, dated as of June 1, 2019, by and among J.P. MorganChase Commercial Mortgage Securities Corp., as Depositor, Midland LoanServices, a Division of PNC Bank, National Association, as Master Servicer,Rialto Capital Advisors, LLC, as Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator, Wells Fargo Bank, NationalAssociation, as Trustee, and Pentalpha Surveillance LLC, as Operating Advisorand Asset Representations Reviewer (filed as Exhibit 4.1 to the registrant’sCurrent Report on Form 8-K filed on June 17, 2019 under Commission File No.333-226123-03 and incorporated by reference herein). 

4.2          Trustand Servicing Agreement, dated as of March 6, 2019, by and among GS MortgageSecurities Corporation II, as Depositor, Midland Loan Services, a Division ofPNC Bank, National Association, as Servicer, Midland Loan Services, a Divisionof PNC Bank, National Association, as Special Servicer, Wells Fargo Bank,National Association, as Certificate Administrator, Custodian and Trustee, andPentalpha Surveillance LLC, as Operating Advisor (filed as Exhibit 4.5 to theregistrant’s Current Report on Form 8-K filed on June 17, 2019 under CommissionFile No. 333-226123-03 and incorporated by reference herein). 

4.3          Trustand Servicing Agreement, dated as of March 7, 2019, by and among Morgan StanleyCapital I Inc., as Depositor, Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer, Rialto Capital Advisors, LLC, asSpecial Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator, Custodian and Trustee, and Park Bridge Lender Services LLC, asOperating Advisor (filed as Exhibit 4.3 to the registrant’s Current Report onForm 8-K filed on June 17, 2019 under Commission File No. 333-226123-03 andincorporated by reference herein).

4.4          Poolingand Servicing Agreement, dated as of April 1, 2019, by and among DeutscheMortgage & Asset Receiving Corporation, as Depositor, KeyBank NationalAssociation, as Master Servicer, LNR Partners, LLC, as Special Servicer, WellsFargo Bank, National Association, as Trustee, Certificate Administrator, PayingAgent and Custodian, and Pentalpha Surveillance LLC, as Operating Advisor andAsset Representations Reviewer (filed as Exhibit 4.2 to the registrant’sCurrent Report on Form 8-K filed on June 17, 2019 under Commission File No.333-226123-03 and incorporated by reference herein). 

4.5          Poolingand Servicing Agreement, dated as of May 1, 2019, by and among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, Rialto Capital Advisors, LLC, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Park Bridge LenderServices LLC, as Operating Advisor and Asset Representations Reviewer (filed asExhibit 99.4 to the registrant’s Current Report on Form 8-K/A filed on February11, 2020 under Commission File No. 333-226123-03 and incorporated by referenceherein).

4.6          Poolingand Servicing Agreement, dated as of May 1, 2019, by and among GS MortgageSecurities Corporation II, as Depositor, Midland Loan Services, a Division ofPNC Bank, National Association, as Master Servicer, KeyBank NationalAssociation, as Special Servicer, Wells Fargo Bank, National Association, asCertificate Administrator and as Trustee, and Park Bridge Lender Services LLC,as Operating Advisor and as Asset Representations Reviewer (filed as Exhibit4.4 to the registrant’s Current Report on Form 8-K filed on June 17, 2019 underCommission File No. 333-226123-03 and incorporated by reference herein).

4.7          Poolingand Servicing Agreement, dated as of May 1, 2019, by and among Banc of AmericaMerrill Lynch Commercial Mortgage Inc., as Depositor, Wells Fargo Bank,National Association, as General Master Servicer, National Cooperative Bank,N.A., as NCB Master Servicer, Rialto Capital Advisors, LLC, as SpecialServicer, National Cooperative Bank, N.A., as NCB Special Servicer, SitusHoldings, LLC, as Newport Corporate Center Special Servicer, Wells Fargo Bank,National Association, as Certificate Administrator and Custodian, WilmingtonTrust, National Association, as Trustee, and Pentalpha Surveillance LLC, asOperating Advisor and Asset Representations Reviewer (filed as Exhibit 4.7 tothe registrant’s Current Report on Form 8-K filed on June 17, 2019 underCommission File No. 333-226123-03 and incorporated by reference herein).

4.8          Poolingand Servicing Agreement, dated as of June 1, 2019, by and among BarclaysCommercial Mortgage Securities LLC, as Depositor, Midland Loan Services, aDivision of PNC Bank, National Association, as Master Servicer, Midland LoanServices, a Division of PNC Bank, National Association, as Special Servicer,Wells Fargo Bank, National Association, as Certificate Administrator, WellsFargo Bank, National Association, as Trustee, and Pentalpha Surveillance LLC,as Operating Advisor and Asset Representations Reviewer (filed as Exhibit 4.6to the registrant’s Current Report on Form 8-K filed on June 17, 2019 underCommission File No. 333-226123-03 and incorporated by reference herein).

4.9          Poolingand Servicing Agreement, dated as of July 1, 2019, by and among GS MortgageSecurities Corporation II, as Depositor, Midland Loan Services, a Division ofPNC Bank, National Association, as Master Servicer and Special Servicer, WellsFargo Bank, National Association, as Certificate Administrator and Trustee, andPentalpha Surveillance LLC, as Operating Advisor and Asset RepresentationsReviewer (filed as Exhibit 4.1 to the registrant’s Current Report on Form 8-Kfiled on July 12, 2019 under Commission File No. 333-226123-03 and incorporatedby reference herein).

4.10        AgreementBetween Noteholders, dated as of March 13, 2019, by and between, JPMorgan ChaseBank, National Association, as Initial Note A-1-1 Holder, Initial Note A-1-2Holder, Initial Note A-1-3 Holder, Initial Note A-1-4 Holder, Initial NoteA-1-5 Holder, Initial Note A-1-6 Holder, Initial Note A-1-7 Holder and InitialNote A-1-8 Holder, Deutsche Bank AG, acting through its New York Branch, asNote A-2-1 Holder, Note A-2-2 Holder, Note A-2-3 Holder, Note A-2-4 Holder andNote A-2-5 Holder, JPMorgan Chase Bank, National Association, as Initial NoteB-1 Holder, and Deutsche Bank AG, acting through its New York Branch, as NoteB-2 Holder (filed as Exhibit 4.9 to the registrant’s Current Report on Form 8-Kfiled on June 17, 2019 under Commission File No. 333-226123-03 and incorporatedby reference herein).

4.11        AgreementBetween Note Holders, dated as of March 7, 2019, by and between Morgan StanleyBank, N.A., as Initial Note A-1 Holder, Initial Note A-5-1 Holder, Initial NoteA-5-2 Holder, Initial Note A-5-3 Holder and Initial Note A-5-4 Holder, CitiReal Estate Funding Inc., as Initial Note A-2 Holder, Initial Note A-6-1Holder, Initial Note A-6-2 Holder and Initial Note A-6-3 Holder, UBS AG, NewYork 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 (filedas Exhibit 4.10 to the registrant’s Current Report on Form 8-K filed on June17, 2019 under Commission File No. 333-226123-03 and incorporated by referenceherein).

4.12        AgreementBetween Note Holders, dated as of April 11, 2019, by and between Citi RealEstate Funding Inc., as Initial Note A-1 Holder, Citi Real Estate Funding Inc.,as Initial Note A-2 Holder, and Citi Real Estate Funding Inc., as Initial NoteA-3 Holder (filed as Exhibit 4.11 to the registrant’s Current Report on Form8-K filed on June 17, 2019 under Commission File No. 333-226123-03 andincorporated by reference herein).

4.13        Amendedand Restated Co-Lender Agreement, dated as of May 3, 2019, by and among, WellsFargo Bank, National Association, as Trustee for the Benefit of the RegisteredHolders of the CALI 2019-101C Mortgage Trust, Commercial Mortgage Pass-ThroughCertificates, Series 2019-101C, as Note A-1 Holder, Note A-2 Holder, Note B-1Holder and Note B-2 Holder, Wells Fargo Bank, National Association, as Trusteefor the Benefit of the Registered Holders of the Benchmark 2019-B10 MortgageTrust, Commercial Mortgage Pass-Through Certificates, Series 2019-B10, as NoteA-8 Holder and Note A-9 Holder, Goldman Sachs Mortgage Company, as Initial NoteA-3 Holder, Initial Note A-4 Holder and Initial Note A-5 Holder, and JPMorganChase Bank, National Association, as Initial Note A-6 Holder and Initial NoteA-7 Holder (filed as Exhibit 4.12 to the registrant’s Current Report on Form8-K filed on June 17, 2019 under Commission File No. 333-226123-03 andincorporated by reference herein).

4.14        Co-LenderAgreement, dated as of June 11, 2019, by and between Societe Generale FinancialCorporation and JPMorgan Chase Bank, National Association (filed as Exhibit4.13 to the registrant’s Current Report on Form 8-K filed on June 17, 2019under Commission File No. 333-226123-03 and incorporated by reference herein).

4.15        Co-LenderAgreement, dated as of April 17, 2019, by and between Citi Real Estate FundingInc., as Initial Note A-1 Holder, and Citi Real Estate Funding Inc., as InitialNote A-2 Holder (filed as Exhibit 4.14 to the registrant’s Current Report onForm 8-K filed on June 17, 2019 under Commission File No. 333-226123-03 andincorporated by reference herein).

4.16        Co-LenderAgreement, dated as of June 17, 2019, by and between Citi Real Estate FundingInc., as Initial Note A-1 Holder, and Citi Real Estate Funding Inc., as InitialNote A-2 Holder (filed as Exhibit 4.15 to the registrant’s Current Report onForm 8-K filed on June 17, 2019 under Commission File No. 333-226123-03 andincorporated by reference herein).

4.17        AgreementBetween Noteholders, dated as of March 8, 2019, by and between Goldman SachsBank USA, as Initial Note A-2 Holder, Initial Note A-3 Holder, Initial Note A-4Holder, Initial Note B-2 Holder and Initial Note C-2 Holder, and Deutsche BankAG, New York Branch, as Initial Note A-1 Holder, Initial Note B-1 Holder andInitial Note C-1 Holder (filed as Exhibit 4.16 to the registrant’s CurrentReport on Form 8-K filed on June 17, 2019 under Commission File No.333-226123-03 and incorporated by reference herein).

4.18        AgreementBetween Noteholders, dated as of May 16, 2019, by and between Deutsche Bank AG,New York Branch, as Initial Note A-1-A Holder, Initial Note A-1-B Holder,Initial Note A-1-C Holder, Initial Note B-1-A Holder, Initial Note B-1-BHolder, Initial Note C-1-A Holder, Initial Note C-1-B Holder and Initial NoteD-1 Holder, and Wells Fargo Bank, National Association, as Initial Note A-2-AHolder, Initial Note A-2-B Holder, Initial Note A-2-C Holder, Initial NoteB-2-A Holder, Initial Note B-2-B Holder, Initial Note C-2-A Holder, InitialNote C-2-B Holder and Initial Note D-2 Holder (filed as Exhibit 4.17 to theregistrant’s Current Report on Form 8-K filed on June 17, 2019 under CommissionFile No. 333-226123-03 and incorporated by reference herein).

4.19        Co-LenderAgreement, dated as of June 17, 2019, by and between Citi Real Estate FundingInc., as Initial Note A-1 Holder, and Citi Real Estate Funding Inc., as InitialNote A-2 Holder (filed as Exhibit 4.18 to the registrant’s Current Report onForm 8-K filed on June 17, 2019 under Commission File No. 333-226123-03 andincorporated by reference herein).

4.20        Co-LenderAgreement, dated as of March 1, 2019, by and between Citi Real Estate FundingInc., as Initial Note A-1 Holder, and Citi Real Estate Funding Inc., as InitialNote A-2 Holder (filed as Exhibit 4.19 to the registrant’s Current Report onForm 8-K filed on June 17, 2019 under Commission File No. 333-226123-03 andincorporated by reference herein).

4.21        AgreementBetween Note Holders, dated as of April 26, 2019, by and between Morgan StanleyBank, N.A., as Initial Note A-1 Holder, and Deutsche Bank AG, New York Branch,as Initial Note A-2 Holder (filed as Exhibit 4.20 to the registrant’s CurrentReport on Form 8-K filed on June 17, 2019 under Commission File No.333-226123-03 and incorporated by reference herein).

4.22        Co-LenderAgreement, dated as of June 17, 2019, by and between JPMorgan Chase Bank, NationalAssociation, as Initial Note A-1 Holder, and JPMorgan Chase Bank, NationalAssociation, as Initial Note A-2 Holder (filed as Exhibit 4.21 to theregistrant’s Current Report on Form 8-K filed on June 17, 2019 under CommissionFile No. 333-226123-03 and incorporated by reference herein).

4.23        Co-LenderAgreement, dated as of May 15, 2019, by and between Citi Real Estate FundingInc., as Initial Note A-1 Holder, Citi Real Estate Funding Inc., as InitialNote A-2 Holder, and Citi Real Estate Funding Inc., as Initial Note A-3 Holder(filed as Exhibit 4.22 to the registrant’s Current Report on Form 8-K filed onJune 17, 2019 under Commission File No. 333-226123-03 and incorporated byreference herein).

4.24        AgreementBetween Note Holders, dated as of December 12, 2018, by and between UBS AG, byand through its branch office at 1285 Avenue of the Americas, New York, NewYork, as Initial Note A-1 Holder, Initial Note A-2 Holder, Initial Note A-3Holder, Initial Note A-4 Holder, Initial Note A-5 Holder, Initial Note A-6Holder, Initial Note A-7 Holder, Initial Note A-8 Holder, Initial Note A-9Holder and Initial Note A-10 Holder (filed as Exhibit 4.23 to the registrant’sCurrent Report on Form 8-K filed on June 17, 2019 under Commission File No.333-226123-03 and incorporated by reference herein).

 

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

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

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

33.2        Rialto Capital Advisors,LLC, as Special Servicer

33.3        Wells Fargo Bank, NationalAssociation, as Trustee and Certificate Administrator

33.4        Wells Fargo Bank, NationalAssociation, as Custodian

33.5        Pentalpha SurveillanceLLC, as Operating Advisor

33.6        Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the GreenHills Corporate Center Mortgage Loan (see Exhibit 33.1)

33.7        Rialto Capital Advisors,LLC, as Special Servicer of the Green Hills Corporate Center Mortgage Loan (seeExhibit 33.2)

33.8        Wells Fargo Bank, National Association, as Trustee of the Green Hills CorporateCenter Mortgage Loan (Omitted. See Explanatory Notes.)

33.9        Wells Fargo Bank, NationalAssociation, as Custodian of the Green Hills Corporate Center Mortgage Loan(see Exhibit 33.4)

33.10      Pentalpha SurveillanceLLC, as Operating Advisor of the Green Hills Corporate Center Mortgage Loan(see Exhibit 33.5)

33.11      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the WesternDigital R&D Campus Mortgage Loan (see Exhibit 33.1)

33.12      Rialto Capital Advisors,LLC, as Special Servicer of the Western Digital R&D Campus Mortgage Loan(see Exhibit 33.2)

33.13      Wells Fargo Bank, National Association, as Trustee of the Western DigitalR&D Campus Mortgage Loan (Omitted. See Explanatory Notes.)

33.14      Wells Fargo Bank, NationalAssociation, as Custodian of the Western Digital R&D Campus Mortgage Loan(see Exhibit 33.4)

33.15      Pentalpha SurveillanceLLC, as Operating Advisor of the Western Digital R&D Campus Mortgage Loan(see Exhibit 33.5)

33.16      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of theGreenleaf at Howell Mortgage Loan (see Exhibit 33.1)

33.17      Rialto Capital Advisors,LLC, as Special Servicer of the Greenleaf at Howell Mortgage Loan (see Exhibit33.2)

33.18      Wells Fargo Bank, National Association, as Trustee of the Greenleaf at HowellMortgage Loan (Omitted. See Explanatory Notes.)

33.19      Wells Fargo Bank, NationalAssociation, as Custodian of the Greenleaf at Howell Mortgage Loan (see Exhibit33.4)

33.20      Pentalpha SurveillanceLLC, as Operating Advisor of the Greenleaf at Howell Mortgage Loan (see Exhibit33.5)

33.21      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the 101California Mortgage Loan (see Exhibit 33.1)

33.22      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the 101California Mortgage Loan (see Exhibit 33.1)

33.23      Wells Fargo Bank, National Association, as Trustee of the 101 CaliforniaMortgage Loan (Omitted. See Explanatory Notes.)

33.24      Wells Fargo Bank, NationalAssociation, as Custodian of the 101 California Mortgage Loan (see Exhibit33.4)

33.25      Pentalpha SurveillanceLLC, as Operating Advisor of the 101 California Mortgage Loan (see Exhibit33.5)

33.26      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the ILPTHawaii Portfolio Mortgage Loan (see Exhibit 33.1)

33.27      Rialto Capital Advisors,LLC, as Special Servicer of the ILPT Hawaii Portfolio Mortgage Loan (seeExhibit 33.2)

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

33.29      Wells Fargo Bank, NationalAssociation, as Custodian of the ILPT Hawaii Portfolio Mortgage Loan (seeExhibit 33.4)

33.30      Park Bridge LenderServices LLC, as Operating Advisor of the ILPT Hawaii Portfolio Mortgage Loan

33.31      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the 3Columbus Circle Mortgage Loan (see Exhibit 33.1)

33.32      LNR Partners, LLC, asSpecial Servicer of the 3 Columbus Circle Mortgage Loan

33.33      Wells Fargo Bank, National Association, as Trustee of the 3 Columbus CircleMortgage Loan (Omitted. See Explanatory Notes.)

33.34      Wells Fargo Bank, NationalAssociation, as Custodian of the 3 Columbus Circle Mortgage Loan (see Exhibit33.4)

33.35      Pentalpha SurveillanceLLC, as Operating Advisor of the 3 Columbus Circle Mortgage Loan (see Exhibit33.5)

33.36      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of theHeartland Dental Medical Office Portfolio Mortgage Loan (see Exhibit 33.1)

33.37      Rialto Capital Advisors,LLC, as Special Servicer of the Heartland Dental Medical Office PortfolioMortgage Loan (see Exhibit 33.2)

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

33.39      Wells Fargo Bank, NationalAssociation, as Custodian of the Heartland Dental Medical Office PortfolioMortgage Loan (see Exhibit 33.4)

33.40      Park Bridge LenderServices LLC, as Operating Advisor of the Heartland Dental Medical OfficePortfolio Mortgage Loan (see Exhibit 33.30)

33.41      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the HeartlandDental Medical Office Portfolio Mortgage Loan

33.42      National Tax Search, LLC,as Servicing Function Participant of the Heartland Dental Medical OfficePortfolio Mortgage Loan

33.43      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the 59 MaidenLane Mortgage Loan (see Exhibit 33.1)

33.44      KeyBank NationalAssociation, as Special Servicer of the 59 Maiden Lane Mortgage Loan

33.45      Wells Fargo Bank, National Association, as Trustee of the 59 Maiden LaneMortgage Loan (Omitted. See Explanatory Notes.)

33.46      Wells Fargo Bank, NationalAssociation, as Custodian of the 59 Maiden Lane Mortgage Loan (see Exhibit33.4)

33.47      Park Bridge LenderServices LLC, as Operating Advisor of the 59 Maiden Lane Mortgage Loan (seeExhibit 33.30)

33.48      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the Arbor HotelPortfolio Mortgage Loan (see Exhibit 33.1)

33.49      KeyBank NationalAssociation, as Special Servicer of the Arbor Hotel Portfolio Mortgage Loan(see Exhibit 33.44)

33.50      Wells Fargo Bank, National Association, as Trustee of the Arbor Hotel PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.51      Wells Fargo Bank, NationalAssociation, as Custodian of the Arbor Hotel Portfolio Mortgage Loan (seeExhibit 33.4)

33.52      Park Bridge LenderServices LLC, as Operating Advisor of the Arbor Hotel Portfolio Mortgage Loan(see Exhibit 33.30)

33.53      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the MoffettTowers II - Building V Mortgage Loan (see Exhibit 33.1)

33.54      KeyBank NationalAssociation, as Special Servicer of the Moffett Towers II - Building V MortgageLoan (see Exhibit 33.44)

33.55      Wells Fargo Bank, National Association, as Trustee of the Moffett Towers II -Building V Mortgage Loan (Omitted. See Explanatory Notes.)

33.56      Wells Fargo Bank, NationalAssociation, as Custodian of the Moffett Towers II - Building V Mortgage Loan(see Exhibit 33.4)

33.57      Park Bridge LenderServices LLC, as Operating Advisor of the Moffett Towers II - Building VMortgage Loan (see Exhibit 33.30)

33.58      Berkadia Commercial Mortgage LLC, as Primary Servicer of the LakesideApartments Mortgage Loan (Omitted. See Explanatory Notes.)

33.59      KeyBank NationalAssociation, as Special Servicer of the Lakeside Apartments Mortgage Loan (seeExhibit 33.44)

33.60      Wells Fargo Bank, National Association, as Trustee of the Lakeside ApartmentsMortgage Loan (Omitted. See Explanatory Notes.)

33.61      Wells Fargo Bank, NationalAssociation, as Custodian of the Lakeside Apartments Mortgage Loan (see Exhibit33.4)

33.62      Park Bridge LenderServices LLC, as Operating Advisor of the Lakeside Apartments Mortgage Loan(see Exhibit 33.30)

33.63      Wells Fargo Bank,National Association, as Primary Servicer of the Newport Corporate CenterMortgage Loan

33.64      Situs Holdings, LLC, as Special Servicer of the Newport Corporate CenterMortgage Loan (Omitted. See Explanatory Notes.)

33.65      Wilmington Trust, National Association, as Trustee of the Newport CorporateCenter Mortgage Loan (Omitted. See Explanatory Notes.)

33.66      Wells Fargo Bank, NationalAssociation, as Custodian of the Newport Corporate Center Mortgage Loan (seeExhibit 33.4)

33.67      Pentalpha SurveillanceLLC, as Operating Advisor of the Newport Corporate Center Mortgage Loan (seeExhibit 33.5)

33.68      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the NewportCorporate Center Mortgage Loan (see Exhibit 33.41)

33.69      National Tax Search, LLC,as Servicing Function Participant of the Newport Corporate Center Mortgage Loan(see Exhibit 33.42)

33.70      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Central Tower Office Mortgage Loan (seeExhibit 33.63)

33.71      Rialto Capital Advisors,LLC, as Special Servicer of the Central Tower Office Mortgage Loan (see Exhibit33.2)

33.72      Wilmington Trust, National Association, as Trustee of the Central Tower OfficeMortgage Loan (Omitted. See Explanatory Notes.)

33.73      Wells Fargo Bank, NationalAssociation, as Custodian of the Central Tower Office Mortgage Loan (seeExhibit 33.4)

33.74      Pentalpha SurveillanceLLC, as Operating Advisor of the Central Tower Office Mortgage Loan (seeExhibit 33.5)

33.75      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Central TowerOffice Mortgage Loan (see Exhibit 33.41)

33.76      National Tax Search, LLC,as Servicing Function Participant of the Central Tower Office Mortgage Loan(see Exhibit 33.42)

33.77      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the SWVPPortfolio Mortgage Loan (see Exhibit 33.1)

33.78      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the SWVPPortfolio Mortgage Loan (see Exhibit 33.1)

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

33.80      Wells Fargo Bank, NationalAssociation, as Custodian of the SWVP Portfolio Mortgage Loan (see Exhibit33.4)

33.81      Pentalpha SurveillanceLLC, as Operating Advisor of the SWVP Portfolio Mortgage Loan (see Exhibit33.5)

33.82      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the 57 East11th Street Mortgage Loan (see Exhibit 33.1)

33.83      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the 57 East11th Street Mortgage Loan (see Exhibit 33.1)

33.84      Wells Fargo Bank, National Association, as Trustee of the 57 East 11th StreetMortgage Loan (Omitted. See Explanatory Notes.)

33.85      Wells Fargo Bank, NationalAssociation, as Custodian of the 57 East 11th Street Mortgage Loan (see Exhibit33.4)

33.86      Pentalpha SurveillanceLLC, as Operating Advisor of the 57 East 11th Street Mortgage Loan (see Exhibit33.5)

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

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

34.2        Rialto Capital Advisors,LLC, as Special Servicer

34.3        Wells Fargo Bank, NationalAssociation, as Trustee and Certificate Administrator

34.4        Wells Fargo Bank, NationalAssociation, as Custodian

34.5        Pentalpha SurveillanceLLC, as Operating Advisor

34.6        Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the GreenHills Corporate Center Mortgage Loan (see Exhibit 34.1)

34.7        Rialto Capital Advisors,LLC, as Special Servicer of the Green Hills Corporate Center Mortgage Loan (seeExhibit 34.2)

34.8        Wells Fargo Bank, National Association, as Trustee of the Green Hills CorporateCenter Mortgage Loan (Omitted. See Explanatory Notes.)

34.9        Wells Fargo Bank, NationalAssociation, as Custodian of the Green Hills Corporate Center Mortgage Loan(see Exhibit 34.4)

34.10      Pentalpha SurveillanceLLC, as Operating Advisor of the Green Hills Corporate Center Mortgage Loan(see Exhibit 34.5)

34.11      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the WesternDigital R&D Campus Mortgage Loan (see Exhibit 34.1)

34.12      Rialto Capital Advisors,LLC, as Special Servicer of the Western Digital R&D Campus Mortgage Loan(see Exhibit 34.2)

34.13      Wells Fargo Bank, National Association, as Trustee of the Western DigitalR&D Campus Mortgage Loan (Omitted. See Explanatory Notes.)

34.14      Wells Fargo Bank, NationalAssociation, as Custodian of the Western Digital R&D Campus Mortgage Loan(see Exhibit 34.4)

34.15      Pentalpha SurveillanceLLC, as Operating Advisor of the Western Digital R&D Campus Mortgage Loan(see Exhibit 34.5)

34.16      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of theGreenleaf at Howell Mortgage Loan (see Exhibit 34.1)

34.17      Rialto Capital Advisors,LLC, as Special Servicer of the Greenleaf at Howell Mortgage Loan (see Exhibit34.2)

34.18      Wells Fargo Bank, National Association, as Trustee of the Greenleaf at HowellMortgage Loan (Omitted. See Explanatory Notes.)

34.19      Wells Fargo Bank, NationalAssociation, as Custodian of the Greenleaf at Howell Mortgage Loan (see Exhibit34.4)

34.20      Pentalpha Surveillance LLC,as Operating Advisor of the Greenleaf at Howell Mortgage Loan (see Exhibit34.5)

34.21      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the 101California Mortgage Loan (see Exhibit 34.1)

34.22      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the 101California Mortgage Loan (see Exhibit 34.1)

34.23      Wells Fargo Bank, National Association, as Trustee of the 101 CaliforniaMortgage Loan (Omitted. See Explanatory Notes.)

34.24      Wells Fargo Bank, NationalAssociation, as Custodian of the 101 California Mortgage Loan (see Exhibit34.4)

34.25      Pentalpha SurveillanceLLC, as Operating Advisor of the 101 California Mortgage Loan (see Exhibit34.5)

34.26      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the ILPTHawaii Portfolio Mortgage Loan (see Exhibit 34.1)

34.27      Rialto Capital Advisors,LLC, as Special Servicer of the ILPT Hawaii Portfolio Mortgage Loan (seeExhibit 34.2)

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

34.29      Wells Fargo Bank, NationalAssociation, as Custodian of the ILPT Hawaii Portfolio Mortgage Loan (seeExhibit 34.4)

34.30      Park Bridge LenderServices LLC, as Operating Advisor of the ILPT Hawaii Portfolio Mortgage Loan

34.31      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the 3Columbus Circle Mortgage Loan (see Exhibit 34.1)

34.32      LNR Partners, LLC, asSpecial Servicer of the 3 Columbus Circle Mortgage Loan

34.33      Wells Fargo Bank, National Association, as Trustee of the 3 Columbus CircleMortgage Loan (Omitted. See Explanatory Notes.)

34.34      Wells Fargo Bank, NationalAssociation, as Custodian of the 3 Columbus Circle Mortgage Loan (see Exhibit34.4)

34.35      Pentalpha SurveillanceLLC, as Operating Advisor of the 3 Columbus Circle Mortgage Loan (see Exhibit34.5)

34.36      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of theHeartland Dental Medical Office Portfolio Mortgage Loan (see Exhibit 34.1)

34.37      Rialto Capital Advisors,LLC, as Special Servicer of the Heartland Dental Medical Office PortfolioMortgage Loan (see Exhibit 34.2)

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

34.39      Wells Fargo Bank, NationalAssociation, as Custodian of the Heartland Dental Medical Office PortfolioMortgage Loan (see Exhibit 34.4)

34.40      Park Bridge LenderServices LLC, as Operating Advisor of the Heartland Dental Medical OfficePortfolio Mortgage Loan (see Exhibit 34.30)

34.41      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the HeartlandDental Medical Office Portfolio Mortgage Loan

34.42      National Tax Search, LLC,as Servicing Function Participant of the Heartland Dental Medical OfficePortfolio Mortgage Loan

34.43      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the 59Maiden Lane Mortgage Loan (see Exhibit 34.1)

34.44      KeyBank NationalAssociation, as Special Servicer of the 59 Maiden Lane Mortgage Loan

34.45      Wells Fargo Bank, National Association, as Trustee of the 59 Maiden LaneMortgage Loan (Omitted. See Explanatory Notes.)

34.46      Wells Fargo Bank, NationalAssociation, as Custodian of the 59 Maiden Lane Mortgage Loan (see Exhibit34.4)

34.47      Park Bridge LenderServices LLC, as Operating Advisor of the 59 Maiden Lane Mortgage Loan (seeExhibit 34.30)

34.48      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the ArborHotel Portfolio Mortgage Loan (see Exhibit 34.1)

34.49      KeyBank NationalAssociation, as Special Servicer of the Arbor Hotel Portfolio Mortgage Loan(see Exhibit 34.44)

34.50      Wells Fargo Bank, National Association, as Trustee of the Arbor Hotel PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.51      Wells Fargo Bank, NationalAssociation, as Custodian of the Arbor Hotel Portfolio Mortgage Loan (seeExhibit 34.4)

34.52      Park Bridge LenderServices LLC, as Operating Advisor of the Arbor Hotel Portfolio Mortgage Loan (seeExhibit 34.30)

34.53      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the MoffettTowers II - Building V Mortgage Loan (see Exhibit 34.1)

34.54      KeyBank NationalAssociation, as Special Servicer of the Moffett Towers II - Building V MortgageLoan (see Exhibit 34.44)

34.55      Wells Fargo Bank, National Association, as Trustee of the Moffett Towers II -Building V Mortgage Loan (Omitted. See Explanatory Notes.)

34.56      Wells Fargo Bank, NationalAssociation, as Custodian of the Moffett Towers II - Building V Mortgage Loan(see Exhibit 34.4)

34.57      Park Bridge LenderServices LLC, as Operating Advisor of the Moffett Towers II - Building VMortgage Loan (see Exhibit 34.30)

34.58      Berkadia Commercial Mortgage LLC, as Primary Servicer of the LakesideApartments Mortgage Loan (Omitted. See Explanatory Notes.)

34.59      KeyBank NationalAssociation, as Special Servicer of the Lakeside Apartments Mortgage Loan (seeExhibit 34.44)

34.60      Wells Fargo Bank, National Association, as Trustee of the Lakeside ApartmentsMortgage Loan (Omitted. See Explanatory Notes.)

34.61      Wells Fargo Bank, NationalAssociation, as Custodian of the Lakeside Apartments Mortgage Loan (see Exhibit34.4)

34.62      Park Bridge LenderServices LLC, as Operating Advisor of the Lakeside Apartments Mortgage Loan(see Exhibit 34.30)

34.63      Wells Fargo Bank,National Association, as Primary Servicer of the Newport Corporate CenterMortgage Loan

34.64      Situs Holdings, LLC, as Special Servicer of the Newport Corporate CenterMortgage Loan (Omitted. See Explanatory Notes.)

34.65      Wilmington Trust, National Association, as Trustee of the Newport CorporateCenter Mortgage Loan (Omitted. See Explanatory Notes.)

34.66      Wells Fargo Bank, NationalAssociation, as Custodian of the Newport Corporate Center Mortgage Loan (seeExhibit 34.4)

34.67      Pentalpha SurveillanceLLC, as Operating Advisor of the Newport Corporate Center Mortgage Loan (seeExhibit 34.5)

34.68      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the NewportCorporate Center Mortgage Loan (see Exhibit 34.41)

34.69      National Tax Search, LLC,as Servicing Function Participant of the Newport Corporate Center Mortgage Loan(see Exhibit 34.42)

34.70      Wells Fargo Bank,National Association, as Primary Servicer of the Central Tower Office MortgageLoan (see Exhibit 34.63)

34.71      Rialto Capital Advisors,LLC, as Special Servicer of the Central Tower Office Mortgage Loan (see Exhibit34.2)

34.72      Wilmington Trust, National Association, as Trustee of the Central Tower OfficeMortgage Loan (Omitted. See Explanatory Notes.)

34.73      Wells Fargo Bank, NationalAssociation, as Custodian of the Central Tower Office Mortgage Loan (seeExhibit 34.4)

34.74      Pentalpha SurveillanceLLC, as Operating Advisor of the Central Tower Office Mortgage Loan (seeExhibit 34.5)

34.75      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Central TowerOffice Mortgage Loan (see Exhibit 34.41)

34.76      National Tax Search, LLC,as Servicing Function Participant of the Central Tower Office Mortgage Loan(see Exhibit 34.42)

34.77      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the SWVPPortfolio Mortgage Loan (see Exhibit 34.1)

34.78      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the SWVPPortfolio Mortgage Loan (see Exhibit 34.1)

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

34.80      Wells Fargo Bank, NationalAssociation, as Custodian of the SWVP Portfolio Mortgage Loan (see Exhibit34.4)

34.81      Pentalpha SurveillanceLLC, as Operating Advisor of the SWVP Portfolio Mortgage Loan (see Exhibit34.5)

34.82      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the 57 East11th Street Mortgage Loan (see Exhibit 34.1)

34.83      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the 57 East11th Street Mortgage Loan (see Exhibit 34.1)

34.84      Wells Fargo Bank, National Association, as Trustee of the 57 East 11th StreetMortgage Loan (Omitted. See Explanatory Notes.)

34.85      Wells Fargo Bank, NationalAssociation, as Custodian of the 57 East 11th Street Mortgage Loan (see Exhibit34.4)

34.86      Pentalpha SurveillanceLLC, as Operating Advisor of the 57 East 11th Street Mortgage Loan (see Exhibit34.5)

35           Servicer compliance statements.

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

35.2        Rialto Capital Advisors,LLC, as Special Servicer

35.3        Wells Fargo Bank, NationalAssociation, as Certificate Administrator

35.4        Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the GreenHills Corporate Center Mortgage Loan (see Exhibit 35.1)

35.5        Rialto Capital Advisors,LLC, as Special Servicer of the Green Hills Corporate Center Mortgage Loan (seeExhibit 35.2)

35.6        Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the WesternDigital R&D Campus Mortgage Loan (see Exhibit 35.1)

35.7        Rialto Capital Advisors, LLC,as Special Servicer of the Western Digital R&D Campus Mortgage Loan (seeExhibit 35.2)

35.8        Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of theGreenleaf at Howell Mortgage Loan (see Exhibit 35.1)

35.9        Rialto Capital Advisors,LLC, as Special Servicer of the Greenleaf at Howell Mortgage Loan (see Exhibit35.2)

35.10      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the 101California Mortgage Loan (see Exhibit 35.1)

35.11      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the 101California Mortgage Loan (see Exhibit 35.1)

35.12      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the ILPTHawaii Portfolio Mortgage Loan (see Exhibit 35.1)

35.13      Rialto Capital Advisors,LLC, as Special Servicer of the ILPT Hawaii Portfolio Mortgage Loan (seeExhibit 35.2)

35.14      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the 3Columbus Circle Mortgage Loan (see Exhibit 35.1)

35.15      LNR Partners, LLC, as Special Servicer of the 3 Columbus Circle Mortgage Loan(Omitted. See Explanatory Notes.)

35.16      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of theHeartland Dental Medical Office Portfolio Mortgage Loan (see Exhibit 35.1)

35.17      Rialto Capital Advisors,LLC, as Special Servicer of the Heartland Dental Medical Office PortfolioMortgage Loan (see Exhibit 35.2)

35.18      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the 59Maiden Lane Mortgage Loan (see Exhibit 35.1)

35.19      KeyBank NationalAssociation, as Special Servicer of the 59 Maiden Lane Mortgage Loan

35.20      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the ArborHotel Portfolio Mortgage Loan (see Exhibit 35.1)

35.21      KeyBank NationalAssociation, as Special Servicer of the Arbor Hotel Portfolio Mortgage Loan(see Exhibit 35.19)

35.22      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the MoffettTowers II - Building V Mortgage Loan (see Exhibit 35.1)

35.23      KeyBank NationalAssociation, as Special Servicer of the Moffett Towers II - Building V MortgageLoan (see Exhibit 35.19)

35.24      Berkadia Commercial Mortgage LLC, as Primary Servicer of the LakesideApartments Mortgage Loan (Omitted. See Explanatory Notes.)

35.25      KeyBank NationalAssociation, as Special Servicer of the Lakeside Apartments Mortgage Loan (seeExhibit 35.19)

35.26      Wells Fargo Bank,National Association, as Primary Servicer of the Newport Corporate CenterMortgage Loan

35.27      Situs Holdings, LLC, as Special Servicer of the Newport Corporate CenterMortgage Loan (Omitted. See Explanatory Notes.)

35.28      Wells Fargo Bank,National Association, as Primary Servicer of the Central Tower Office MortgageLoan (see Exhibit 35.26)

35.29      Rialto Capital Advisors,LLC, as Special Servicer of the Central Tower Office Mortgage Loan (see Exhibit35.2)

35.30      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the SWVPPortfolio Mortgage Loan (see Exhibit 35.1)

35.31      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the SWVPPortfolio Mortgage Loan (see Exhibit 35.1)

35.32      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the 57 East11th Street Mortgage Loan (see Exhibit 35.1)

35.33      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the 57 East11th Street Mortgage Loan (see Exhibit 35.1)

99.1        MortgageLoan Purchase Agreement, dated as of June 17, 2019, between J.P. Morgan ChaseCommercial Mortgage Securities Corp. and JPMorgan Chase Bank, NationalAssociation (filed as Exhibit 99.1 to the registrant’s Current Report on Form8-K filed on June 17, 2019 under Commission File No. 333-226123-03 andincorporated by reference herein).

99.2        MortgageLoan Purchase Agreement, dated as of June 17, 2019, between J.P. Morgan ChaseCommercial Mortgage Securities Corp. and German American Capital Corporation(filed as Exhibit 99.2 to the registrant’s Current Report on Form 8-K filed onJune 17, 2019 under Commission File No. 333-226123-03 and incorporated byreference herein).

99.3        MortgageLoan Purchase Agreement, dated as of June 17, 2019, between J.P. Morgan ChaseCommercial Mortgage Securities Corp. and Citi Real Estate Funding Inc. (filedas Exhibit 99.3 to the registrant’s Current Report on Form 8-K filed on June17, 2019 under Commission File No. 333-226123-03 and incorporated by referenceherein).

99.4        PrimaryServicing Agreement, dated as of May 1, 2019, between Wells Fargo Bank,National Association, as Master Servicer, and Midland Loan Services, a Divisionof PNC Bank, National Association, as Primary Servicer (filed as Exhibit 99.4to the registrant’s Current Report on Form 8-K/A filed on February 11, 2020under Commission File No. 333-226123-03 and incorporated by reference herein).

(b)  The exhibits required to be filed by the Registrant pursuant to Item 601 ofRegulation S-K are listed above.

(c)    Not Applicable.

 

**SIGNATURES**

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

J.P. Morgan Chase CommercialMortgage Securities Corp.(Depositor)

/s/ KunalK. Singh

Kunal K.Singh, President and Chief Executive Officer

(senior officer in charge ofsecuritization of the depositor)

Date: March 17, 2020