**Report on Assessment of Compliance with SEC RegulationAB**

**Servicing Criteria as Primary Servicer**

 

 

Berkadia Commercial MortgageLLC ("Berkadia'') is responsible for assessing compliance, as of and forthe year ended December 31, 2019 (the "Reporting Period''), with theServicing Criteria set forth in Item 1122(d) of Regulation AB of the U.S.Securities and Exchange Commission for asset-backed securities transactions.This assertion includes all commercial mortgage loans sold in public securitizationsfrom the period January 1, 2006 through December 31, 2019 for which Berkadiaserved as primary servicer (the "Platform").

 

Berkadia has concluded thatthe criteria are applicable as shown below (indicated by X) to the primaryservicing of the loans in the Platform:

 

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**Regulation AB Criteria 1122(d)**                                                                                                                                                                                                                                                                                                                                                        | **Applicability of Criteria as the Primary**

**Servicer** |   |
|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------|--------|
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | (1)     General servicing considerations.                                                                                                                                                                                                                                                                                                                                                     |                                                       |   |
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | (i)       Policies and procedures are instituted to monitor any  performance or other triggers and events of default in accordance with the  transaction agreements.                                                                                                                                                                                                                | X                                                          |   |
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | (ii)     If any material servicing activities are outsourced  to third parties, policies and procedures are instituted to monitor the third  party's performance and compliance with such servicing activities.                                                                                                                                                                               | X                                                          |   |
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | (iii)   Any  requirements in the transaction agreements to maintain a back- up servicer  for the pool assets are maintained.                                                                                                                                                                                                                                                                            | (1)                                                        |   |
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | (iv)    A fidelity bond and errors and omissions policy is in effect on the  party participating in the servicing function throughout the reporting period  in the amount of coverage required by and otherwise in accordance with the  terms of the transaction agreements .                                                                                                                      | X                                                          |   |
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | (v)     Aggregation of information, as applicable, is  mathematically accurate and the information conveyed accurately reflects the  information.                                                                                                                                                                                                                                             | X                                                          |   |
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | (2)     Cash collection and administration.                                                                                                                                                                                                                                                                                                                                                   |                                                       |   |
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | (i)       Payments on pool assets are deposited into the  custodial bank accounts and related bank clearing accounts no more than two  business days of receipt, or such other number of days specified in the  transaction agreements.                                                                                                                                             | X                                                          |   |
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | (ii)     Disbursements made via wire transfer on behalf of an  obligor or to an investor are made only by authorized personnel.                                                                                                                                                                                                                                                               | X                                                          |   |
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | (iii)   Advances  of funds or guarantees regarding collections, cash flows or distributions,  and any interest or other fees charged for such advances, are made, reviewed  and approved as specified in the transection agreements.                                                                                                                                                                    | X                                                          |   |
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | (iv)    The related accounts for the transaction, such as cash reserve  accounts or accounts established as a form of overcollateralization, are  separately maintained (e.g., with respect to commingling of cash) as set  forth in the transaction agreements.                                                                                                                                   | X                                                          |   |
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | (v)     Each custodial account is maintained at a federally  insured depository institution as set forth in the transaction agreements.  For purposes of this criterion, "federally insured depository  institution" with respect to a foreign financial institution means a  foreign financial institution that meets the requirements of §240.13k-1  (b)(l) of this chapter. | X                                                          |   |
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | (vi)    Unissued checks are safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                      | X                                                          |   |
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | (vii) Reconciliations  are prepared on a monthly basis for all asset-backed securities related bank  accounts, including custodial accounts and related bank clearing accounts.  These reconciliations:                                                                                                                                                                                                      |                                                       |   |
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | (A) Are  mathematically accurate;                                                                                                                                                                                                                                                                                                                                                                            | X                                                          |   |
| (B)    Are prepared within 30 calendar days after the bank statement cutoff  date, or such other number of days specified in the transaction agreements ;                                                                                                                                                                                                                                                                                                                                                     | X                                                                                                                                                                                                                                                                                                                                                                                                                 |                                                       |   |
| (C)   Are  reviewed and approved by someone other than the person who prepared the  reconciliation; and                                                                                                                                                                                                                                                                                                                                                                                                            | X                                                                                                                                                                                                                                                                                                                                                                                                                 |                                                       |   |
| (D)   Contain  explanations for reconciling items. These reconciling items are resolved  within 90 calendar days of their original identification, or such other  number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                          | X                                                                                                                                                                                                                                                                                                                                                                                                                 |                                                       |   |
| (3)     Investor remittances and reporting.                                                                                                                                                                                                                                                                                                                                                                                                                                                              |                                                                                                                                                                                                                                                                                                                                                                                                              |                                                       |   |
| (i)       Reports to investors, including those to be filed  with the Commission, are maintained in accordance with the transaction agreements  and applicable Commission requirements. Specifically, such reports:                                                                                                                                                                                                                                                                            |                                                                                                                                                                                                                                                                                                                                                                                                              |                                                       |   |
| (A)  Are  prepared in accordance with timeframes and other terms set forth in the  transaction agreements;                                                                                                                                                                                                                                                                                                                                                                                                              | X                                                                                                                                                                                                                                                                                                                                                                                                                 |                                                       |   |
| (B)    Provide  information calculated in accordance with the terms specified in the  transaction agreements;                                                                                                                                                                                                                                                                                                                                                                                                      | X                                                                                                                                                                                                                                                                                                                                                                                                                 |                                                       |   |
| (C)    Are  filed with the Commission as required by its rules and regulations; and                                                                                                                                                                                                                                                                                                                                                                                                                                | (l )                                                                                                                                                                                                                                                                                                                                                                                                              |                                                       |   |
| (D)  Agree  with investors' or the trustee's records as to the total unpaid principal  balance and number of pool assets serviced by the servicer.                                                                                                                                                                                                                                                                                                                                                                      | X                                                                                                                                                                                                                                                                                                                                                                                                                 |                                                       |   |
| (ii)     Amounts due to investors are allocated and remitted  in accordance with timeframes, distribution priority and other terms set forth  in the transaction agreements.                                                                                                                                                                                                                                                                                                                             | X                                                                                                                                                                                                                                                                                                                                                                                                                 |                                                       |   |
| (iii)   Disbursements  made to an investor are posted within two business days to the servicer's  investor records, or such other number of days specified in the transaction  agreements.                                                                                                                                                                                                                                                                                                                         | X                                                                                                                                                                                                                                                                                                                                                                                                                 |                                                       |   |
| (iv)    Amounts remitted to investors per the investor reports agree with  cancelled checks, or other form of payment, or custodial bank statements.                                                                                                                                                                                                                                                                                                                                                          | X                                                                                                                                                                                                                                                                                                                                                                                                                 |                                                       |   |
| (4)     Pool asset administration.                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |                                                                                                                                                                                                                                                                                                                                                                                                              |                                                       |   |
| (i)       Collateral or security on pool assets is maintained as  required by the transaction agreements or related pool asset documents.                                                                                                                                                                                                                                                                                                                                                      | X(2)                                                                                                                                                                                                                                                                                                                                                                                                              |                                                       |   |
| (ii)     Pool assets and related documents are safeguarded as  required by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                   | (1)                                                                                                                                                                                                                                                                                                                                                                                                               |                                                       |   |
| (iii)   Any  additions, removals or substitutions to the asset pool are made, reviewed and  approved in accordance with any conditions or requirements in the transaction  agreements.                                                                                                                                                                                                                                                                                                                             | X                                                                                                                                                                                                                                                                                                                                                                                                                 |                                                       |   |
| (iv)    Payments on pool assets, including any payoffs, made in accordance with  the related pool asset documents are posted to the applicable servicer's  obligor records maintained no more than two business days after receipt, or  such other number of days specified in the transaction agreements, and  allocated to principal, interest or other items (e.g., escrow) in accordance  with the related pool asset documents.                                                                          | X                                                                                                                                                                                                                                                                                                                                                                                                                 |                                                       |   |
| (v)     The servicer's records regarding the pool assets  agree with the servicer's records with respect to an obligor's unpaid  principal balance.                                                                                                                                                                                                                                                                                                                                                      | X                                                                                                                                                                                                                                                                                                                                                                                                                 |                                                       |   |
| (vi)    Changes with respect to the terms or status of an obligor's pool asset  (e.g., loan modifications or re-agings) are made, reviewed and approved by  authorized personnel in accordance with the transaction agreements and  related pool asset documents.                                                                                                                                                                                                                                             | X                                                                                                                                                                                                                                                                                                                                                                                                                 |                                                       |   |
| (vii) Loss  mitigation or recovery actions (e.g., forbearance plans, modifications and  deeds in lieu of foreclosure , foreclosures and repossessions, as applicable)  are initiated, conducted and concluded in accordance with the timeframes or  other requirements established by the transaction agreements.                                                                                                                                                                                                       | (1)                                                                                                                                                                                                                                                                                                                                                                                                               |                                                       |   |
| (viii)Records  documenting collection efforts are maintained during the period a pool asset  is delinquent in accordance with the transaction agreements. Such records are  maintained on at least a monthly basis, or such other period specified in the  transaction agreements, and describe the entity's activities in monitoring  delinquent pool assets including, for example, phone calls, letters and  payment rescheduling plans in cases where delinquency is deemed temporary  (e.g., illness or unemployment ). | X                                                                                                                                                                                                                                                                                                                                                                                                                 |                                                       |   |
| (ix)    Adjustments to interest rates or rates of return for pool assets with  variable rates are computed based on the related pool asset documents.                                                                                                                                                                                                                                                                                                                                                         | X                                                                                                                                                                                                                                                                                                                                                                                                                 |                                                       |   |
| (x)     Regarding any funds held in trust for an obligor  (such as escrow accounts):                                                                                                                                                                                                                                                                                                                                                                                                                     |                                                                                                                                                                                                                                                                                                                                                                                                              |                                                       |   |
| (A)     Such funds are analyzed, in accordance with the obligor's pool  asset documents, on at least an annual basis, or such other period specified  in the transaction agreements;                                                                                                                                                                                                                                                                                                                     | X                                                                                                                                                                                                                                                                                                                                                                                                                 |                                                       |   |
| (B)     Interest on such funds is paid, or credited, to obligors in  accordance with applicable pool asset documents and state laws; and                                                                                                                                                                                                                                                                                                                                                                 | X                                                                                                                                                                                                                                                                                                                                                                                                                 |                                                       |   |
| (C)     Such funds are returned to the obligor within 30 calendar days of  full repayment of the related pool asset, or such other number of days  specified in the transaction agreements.                                                                                                                                                                                                                                                                                                              | X                                                                                                                                                                                                                                                                                                                                                                                                                 |                                                       |   |
| (xi)    Payments made on behalf of an obligor (such as tax or insurance  payments) are made on or before the related penalty or expiration dates, as  indicated on the appropriate bills or notices for such payments, provided  that such support has been received by the servicer at least 30 calendar days  prior to these dates, or such other number of days specified in the  transaction agreements.                                                                                                  | X (2)                                                                                                                                                                                                                                                                                                                                                                                                             |                                                       |   |
| (xii) Any late  payment penalties in connection with any payment to be made on behalf of an  obligor are paid from the servicer's funds and not charged to the obligor,  unless the late payment was due to the obligor's error or omission.                                                                                                                                                                                                                                                                            |  

X (2)                                                                                                                                                                                                                                                                                                                                                                                                     |                                                       |   |
| (xiii) Disbursements  made on behalf of an obligor are posted within two business days to the  obligor's records maintained by the servicer, or such other number of days  specified in the transaction agreements.                                                                                                                                                                                                                                                                                                          |  

X (2)                                                                                                                                                                                                                                                                                                                                                                                                     |                                                       |   |
| (xiv)Delinquencies,  charge-offs and uncollectible accounts are recognized and recorded in  accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                      | X                                                                                                                                                                                                                                                                                                                                                                                                                 |                                                       |   |
| (xv) Any  external enhancement or other support, identified in Item 1114(a) (1) through  (3) or Item 1115 of this Regulation AB, is maintained as set forth in the  transaction agreements.                                                                                                                                                                                                                                                                                                                             | (1)                                                                                                                                                                                                                                                                                                                                                                                                               |                                                       |   |
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X Servicer was responsible forthis criteria in its role as Primary Servicer.

(1) Per servicing and pooling agreements, the criteria doesnot apply to the role of Primary Servicer.

(2) Vendor(s), for which Berkadia is the ResponsibleParty, contributes to the servicing activities for this criteria.

 

 

The Servicing Criteria, aftergiving effect to the foregoing exclusions, are referred to as the"Applicable Servicing Criteria".

 

Berkadia utilizes vendors tosupport its servicing operations, including the use of a commercial tax servicewhich supports its assertions under 1122(d)(4)(xi) through (xiii) and the useof a lien filing firm to support its assertion under 1122(d)(4)(i). This vendoractivity contributes to the servicing activities to which Berkadia isasserting. In all cases, the vendors' activities are limited, and Berkadiaassumes responsibility for the 1122 assessment for these vendor activities.These vendors do not fit the definition of servicer under Item 1101(j), andBerkadia employs policies and procedures designed to provide assurance that thevendors' activities comply with the Applicable Servicing Criteria to such vendors.

 

For the Reporting Period,Berkadia has assessed its compliance with the Applicable Servicing Criteria forthe Platform and has concluded that its servicing operation has complied, inall material respects, with the Applicable Servicing Criteria.

 

Grant Thornton LLP, anindependent registered public accounting firm, has issued an attestation reporton management's assertion of compliance with the Applicable Servicing Criteria.

 

 

Berkadia Commercial MortgageLLC 

 

February 14, 2020

 

/s/ Mark E. McCool

Mark E. McCool

Executive Vice President

Berkadia Commercial MortgageLLC