**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, 2023or**

**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: 333-228375-01**

**Central Index Key Number of the issuing entity:0001774962**

**BANK 2019-BNK18**

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

** **

**Central Index Key Number of the depositor: 0001005007**

**Banc of America Merrill LynchCommercial Mortgage Inc.**

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

** **

**Central Index Key Number of the sponsor: 0001102113**

**Bank of America, NationalAssociation**

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

** **

**Central Index Key Number of the sponsor: 0000740906**

**Wells Fargo Bank, NationalAssociation**

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

** **

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

**Morgan Stanley Mortgage CapitalHoldings LLC**

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

** **

**Central Index Key Number of the sponsor: 0001577313**

**National Cooperative Bank, N.A.**

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

** **

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

**the issuing entity)** | **38-4117273**

**38-4117274**

**38-7221292**

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

**Identification Numbers)** |
|------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------|

**c/o Computershare Trust Company, National Association, as agent for**

**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:**

**(646) 855-3953**

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 every Interactive Data File required to be submitted pursuant toRule 405 of Regulation S-T (Section 232.405 of this chapter) during thepreceding 12 months (or for such shorter period that the registrant wasrequired to submit such files).

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          ⌧                                                                                                       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 complyingwith any new or revised financial accounting standards provided pursuant toSection 13(a) of the Exchange Act.  o

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

If securities are registered pursuant to Section 12(b) of theAct, indicate by check mark whether the financial statements of the registrantincluded in the filing reflect the correction of an error to previously issuedfinancial statements. o

Indicate by check mark whether any of those error correctionsare restatements that required a recovery analysis of incentive-basedcompensation received by any of the registrant’s executive officers during therelevant recovery period pursuant to §240.10D-1(b). 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 Alhambra Mortgage Loan, the 350 BushStreet Mortgage Loan, the Ford Factory Mortgage Loan, the Newport CorporateCenter Mortgage Loan, the 9201 West Sunset Boulevard Mortgage Loan, the CentralTower Mortgage Loan and the Westin Atlanta Airport Mortgage Loan, whichconstituted approximately 9.6%, 9.6%, 9.2%, 7.1%, 6.8%, 6.1% and 4.4%,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 (a) with respect to The Alhambra Mortgage Loan, two other *paripassu* loans, which are not assets of the issuing entity, (b) with respectto the 350 Bush Street Mortgage Loan, two other *pari passu* loans, whichare not assets of the issuing entity, (c) with respect to the Ford FactoryMortgage Loan, one other *pari passu* loan, which is not an asset of theissuing entity, (d) with respect to the Newport Corporate Center Mortgage Loan,three other *pari passu* loans and ten subordinate companion loans, eachof which are not assets of the issuing entity, (e) with respect to the 9201West Sunset Boulevard Mortgage Loan, one other *pari passu* loan, which isnot an asset of the issuing entity, (f) with respect to the Central TowerMortgage Loan, one other *pari passu* loan, which is not an asset of theissuing entity and (g) with respect to the Westin Atlanta Airport MortgageLoan, one other *pari passu* loan, which is not an asset of the issuingentity. These loan combinations, including The Alhambra Mortgage Loan, the 350Bush Street Mortgage Loan, the Ford Factory Mortgage Loan, the NewportCorporate Center Mortgage Loan, the 9201 West Sunset Boulevard Mortgage Loan,the Central Tower Mortgage Loan and the Westin Atlanta Airport Mortgage Loan,are being serviced and administered pursuant to the Pooling and ServicingAgreement, which is incorporated by reference as Exhibit 4.1 to this AnnualReport 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 3.9% 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 seventeen other *pari passu* loans,which are not assets of the issuing entity. A *pari passu* portion of theloan combination 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 isincorporated by reference as Exhibit 4.2 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 Great Wolf Lodge Southern CaliforniaMortgage Loan, which constituted approximately 3.9% of the asset pool of theissuing entity as of its cut-off date.  The Great Wolf Lodge SouthernCalifornia Mortgage Loan is an asset of the issuing entity and is part of aloan combination that includes the Great Wolf Lodge Southern CaliforniaMortgage Loan, three other *pari passu* loans and one subordinatecompanion loan, which are not assets of the issuing entity. A *pari passu*portion of the loan combination was securitized in the Wells Fargo CommercialMortgage Trust 2019-C50 transaction, Commission File Number 333-226486-05 (the“WFCM 2019-C50 Transaction”). This loan combination, including the GreatWolf Lodge Southern California Mortgage Loan, is being serviced andadministered pursuant to the pooling and servicing agreement for the WFCM2019-C50 Transaction, which is incorporated by reference as Exhibit 4.3 to thisAnnual 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.

Wells Fargo Bank, NationalAssociation is the general master servicer and certificate administrator of themortgage loans serviced under the Pooling and Servicing Agreement and theprimary servicer of the Great Wolf Lodge Southern California Mortgage Loan. Asa result, Wells Fargo Bank, National Association is a “servicer” as defined inItem 1108(a)(2)(iii) of Regulation AB, in the capacities described above,because it is servicing mortgage loans that constituted 10% or more of theassets 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, NationalAssociation is the custodian of the mortgage loans serviced under the Poolingand Servicing Agreement, the Great Wolf Lodge Southern California Mortgage Loanand the ILPT Hawaii Portfolio Mortgage Loan.  As a result, Wells FargoBank, National Association is a servicing function participant in thecapacities 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 Wells Fargo Bank, NationalAssociation in the capacities described above are listed in the Exhibit Index.

RialtoCapital Advisors, LLC is the special servicer of the mortgage loans servicedunder the Pooling and Servicing Agreement (other than the Newport CorporateCenter Mortgage Loan) and the ILPT Hawaii Portfolio Mortgage Loan. As a result,Rialto Capital Advisors, LLC is a “servicer” as defined in Item 1108(a)(2)(iii)of Regulation AB, in the capacities described above, because it is servicingmortgage loans that constituted 10% or more of the assets of the issuing entityas of its cut-off date. The assessments of compliance with applicable servicingcriteria, accountants’ attestation reports and servicer compliance statementsdelivered by Rialto Capital Advisors, LLC in the capacities described above arelisted in the Exhibit Index.

SitusHoldings, LLC is the special servicer of the Newport Corporate Center MortgageLoan and the Great Wolf Lodge Southern California. As a result, Situs Holdings,LLC is a “servicer” as defined in Item 1108(a)(2)(iii) of Regulation AB, in thecapacities described above, because it is servicing mortgage loans thatconstituted 10% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby Situs Holdings, LLC in the capacities described above are listed in theExhibit Index.

Park Bridge Lender Services LLC isthe operating advisor of the Great Wolf Lodge Southern California Mortgage Loanand the ILPT Hawaii Portfolio Mortgage Loan.  As a result, Park BridgeLender Services LLC is a servicing function participant in the capacitiesdescribed above, because it is servicing mortgage loans that constituted 5% ormore of the assets of the issuing entity as of its cut-off date. Theassessments of compliance with applicable servicing criteria and accountants’attestation reports delivered by Park Bridge Lender Services LLC in thecapacities described above are listed in the Exhibit Index.

Wells Fargo Bank, NationalAssociation acts as trustee of the ILPT Hawaii Portfolio Mortgage Loan. Pursuant to the trust and servicing agreement for the ILPT 2019-SURFTransaction, the trustee is required to provide an assessment of compliancewith applicable servicing criteria solely with respect to Item 1122(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 ILPT Hawaii Portfolio Mortgage Loan have delivered one or more assessmentsof compliance with respect to Item 1122(d)(2)(iii) of Regulation AB.

Wilmington Trust, NationalAssociation acts as trustee of the mortgage loans serviced under the Poolingand Servicing Agreement and the Great Wolf Lodge Southern California MortgageLoan.  Pursuant to the Pooling and Servicing Agreement and the pooling andservicing agreement for the WFCM 2019-C50 Transaction, the trustee is requiredto provide an assessment of compliance with applicable servicing criteria solelywith respect to Item 1122(d)(2)(iii) of Regulation AB (regarding advances offunds or guarantees regarding collections, cash flows or distributions, and anyinterest or other fees charged for such advances, are made, reviewed andapproved as specified in the transaction agreements). However, during thereporting period, the trustee did not perform any servicing function withrespect to the servicing criteria specified in Item 1122(d)(2)(iii) ofRegulation AB.  The master servicer or the special servicer, to the extentrequired, performed the servicing function identified with respect to Item1122(d)(2)(iii) of Regulation AB, and each such party included Item1122(d)(2)(iii) of Regulation AB in the assessment of compliance withapplicable servicing criteria and accountant’s attestation report for thesubject transaction.  As a result, this Annual Report on Form 10-K doesnot include an assessment of compliance with applicable servicing criteria ofthe trustee. One or more other servicers of the mortgage loans serviced underthe Pooling and Servicing Agreement and the Great Wolf Lodge SouthernCalifornia Mortgage Loan have delivered one or more assessments of compliancewith respect to Item 1122(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 Solutions, LLC  Thisentity was engaged by the master servicer under the Pooling and ServicingAgreement and the primary servicer of the Great Wolf Lodge Southern CaliforniaMortgage 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, this vendoris a “servicer” for the purposes of Item 1122 of Regulation AB.  *See*Compliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

This Annual Report on Form 10-Kincludes an assessment of compliance with applicable servicing criteria,accountants’ attestation report and servicer compliance statement fromComputershare Trust Company, National Association (“CTCNA”).  CTCNAwas engaged by Wells Fargo Bank, National Association (“Wells Fargo”),in its capacity as certificate administrator and custodian, to perform certainspecified servicing functions identified in the assessment of compliance withapplicable servicing criteria and accountants’ attestation reports.  WellsFargo engaged CTCNA in connection with the sale of Wells Fargo’s corporatetrust services business to CTCNA and its affiliates.  Further, under theprinciples-based definition of “servicer” set forth in Item 1101(j) ofRegulation AB that looks to the functions that an entity performs, this partyis a “servicer” for the purposes of Item 1123 of Regulation AB.  SeeCompliance 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 ILPT Hawaii Portfolio Mortgage Loan and the Great WolfLodge Southern California Mortgage Loan are omitted from this Annual Report onForm 10-K as the certificate administrator pursuant to the related pooling andservicing agreement or trust and servicing agreement does not perform anyactivities that address servicing criteria with respect to the issuing entityand because they are 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 combination that includes the ILPT Hawaii Portfolio Mortgage Loan, (i) thereport on assessment of compliance with servicing criteria and attestationreport on assessment of compliance with servicing criteria of Midland LoanServices, a Division of PNC Bank, National Association as primary servicer ofthe ILPT Hawaii Portfolio Mortgage Loan, listed on the Exhibit Index areomitted from this Annual Report on Form 10-K as they are not required to beincluded on this Annual Report on Form 10-K per Instruction 3 to Item 1122 ofRegulation AB because it is a party performing activities that addressservicing criteria relating to 5% or less of the assets of the issuing entity;and (ii) the servicer compliance statement of Midland Loan Services, a Divisionof PNC Bank, National Association as primary servicer of the ILPT HawaiiPortfolio Mortgage Loan, listed on the Exhibit Index is omitted from thisAnnual Report on Form 10-K as it is not required by Item 1123 of Regulation ABto be included on this Annual Report on Form 10-K because it is an unaffiliatedparty that is not a “servicer” that meets the criteria in Item 1108(a)(2)(i)through (iii) of Regulation AB.

**PART I**

**Item 1.  Business.**

Omitted.

**Item 1A.  Risk Factors.**

Omitted.

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

None.

**Item 1C.  Cybersecurity.**

Omitted.

**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.**

[Reserved].

**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.

**Item 9C.  Disclosure Regarding Foreign Jurisdictionsthat Prevent Inspections.**

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 Accountant 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 anyderivative instruments or other support for the certificates within thistransaction as described under Item 1115 of Regulation AB.

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

The registrant knows of no materialpending legal proceeding involving the trust or any party related to the trust,other than routine litigation incidental to the duties of those respectiveparties, and the following, with respect to Wells Fargo Bank, NationalAssociation, as certificate administrator, as trustee and as custodian.

In December 2014, Phoenix Light SF Limited (Phoenix Light)and certain related entities filed a complaint in the United States DistrictCourt for the Southern District of New York alleging claims against Wells FargoBank, N.A., in its capacity as trustee for a number of residentialmortgage-backed securities (RMBS) trusts. Complaints raising similarallegations have been filed by Commerzbank AG in the Southern District of NewYork, IKB International and IKB Deutsche Industriebank (together, IKB) in NewYork state court, and Park Royal I LLC and Park Royal II LLC in New York statecourt. In each case, the plaintiffs allege that Wells Fargo Bank, N.A., astrustee, caused losses to investors, and plaintiffs assert causes of actionbased upon, among other things, the trustee’s alleged failure to notify andenforce repurchase obligations of mortgage loan sellers for purported breachesof representations and warranties, notify investors of alleged events ofdefault, and abide by appropriate standards of care following alleged events ofdefault. In July 2022, the district court dismissed Phoenix Light’s claims andcertain of the claims asserted by Commerzbank AG, and subsequently enteredjudgment in each case in favor of Wells Fargo Bank, N.A. In August 2022,Phoenix Light and Commerzbank AG each appealed the district court’s decision tothe United States Court of Appeals for the Second Circuit. Phoenix Lightdismissed its appeal in May 2023, terminating its case. In November 2023, WellsFargo Bank, N.A. entered into an agreement with IKB to resolve IKB’s claims.Wells Fargo Bank, N.A. previously settled two class actions filed byinstitutional investors and an action filed by the National Credit UnionAdministration with similar allegations.

**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 May 31, 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 Zto 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 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 4.2 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 Great Wolf Lodge SouthernCalifornia 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 4.3 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).

**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. Exhibit and Financial Statement Schedules.**

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

(1) Not applicable

(2) Not applicable

(3) See below

4.1          Pooling and Servicing Agreement, dated as of May 1, 2019,by and among Banc of America Merrill Lynch Commercial Mortgage Inc., asDepositor, Wells Fargo Bank, National Association, as General Master Servicer,Rialto Capital Advisors, LLC, as General Special Servicer, National CooperativeBank, N.A., as NCB Master Servicer and as NCB Special Servicer, Situs Holdings,LLC, as Newport Corporate Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator, Wilmington Trust, 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 May 31, 2019 under Commission File No.333-228375-01 and incorporated by reference herein).

4.2          Trust and Servicing Agreement, dated as of March 7, 2019,by and among Morgan Stanley Capital I Inc., as Depositor, Midland LoanServices, a Division of PNC Bank, National Association, as Servicer, RialtoCapital Advisors, LLC, as Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator, Custodian and as Trustee, and ParkBridge Lender Services LLC, as Operating Advisor (filed as Exhibit 4.2 to theregistrant’s Current Report on Form 8-K filed on May 31, 2019 under CommissionFile No. 333-228375-01 and incorporated by reference herein).

4.3          Pooling and Servicing Agreement, dated as of May 1, 2019,by and among Wells Fargo Commercial Mortgage Securities, Inc., as Depositor,Wells Fargo Bank, National Association, as Master Servicer, Rialto CapitalAdvisors, LLC, as Special Servicer, Wells Fargo Bank, National Association, asCertificate Administrator, Wilmington Trust, National Association, as Trustee,and Park Bridge Lender Services LLC, as Operating Advisor and AssetRepresentations Reviewer (filed as Exhibit 4.3 to the registrant’s CurrentReport on Form 8-K filed on May 31, 2019 under Commission File No.333-228375-01 and incorporated by reference herein).

4.4          Agreement Between Note Holders, dated as of May 31, 2019,by and between Wells Fargo Bank, National Association, as Initial Note A-1Holder, Wells Fargo Bank, National Association, as Initial Note A-2 Holder, andWells Fargo Bank, National Association, as Initial Note A-3 Holder (filed asExhibit 4.4 to the registrant’s Current Report on Form 8-K filed on May 31,2019 under Commission File No. 333-228375-01 and incorporated by referenceherein).

4.5          Agreement Between Note Holders, dated as of May 31, 2019,by and between Wells Fargo Bank, National Association, as Initial Note A-1Holder, Wells Fargo Bank, National Association, as Initial Note A-2 Holder, andWells Fargo Bank, National Association, as Initial Note A-3 Holder (filed asExhibit 4.5 to the registrant’s Current Report on Form 8-K filed on May 31,2019 under Commission File No. 333-228375-01 and incorporated by referenceherein).

4.6          Agreement Between Note Holders, dated as of March 29,2019, by and between Bank of America, N.A., as Initial Note A-1 Holder, andBank of America, N.A., as Initial Note A-2 Holder (filed as Exhibit 4.6 to theregistrant’s Current Report on Form 8-K filed on May 31, 2019 under CommissionFile No. 333-228375-01 and incorporated by reference herein).

4.7          Agreement Between Note Holders, 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-AHolder, Initial Note B-1-B Holder, Initial Note C-1-A Holder, Initial NoteC-1-B Holder and Initial Note D-1 Holder, and Wells Fargo Bank, NationalAssociation, Initial Note A-2-A Holder, Initial Note A-2-B Holder, Initial NoteA-2-C Holder, Initial Note B-2-A Holder, Initial Note B-2-B Holder, InitialNote C-2-A Holder, Initial Note C-2-B Holder and Initial Note D-2 Holder (filedas Exhibit 4.7 to the registrant’s Current Report on Form 8-K filed on May 31,2019 under Commission File No. 333-228375-01 and incorporated by referenceherein).

4.8          Agreement Between Note Holders, dated as of May 31, 2019,by and between Morgan Stanley Bank, N.A., as Initial Note A-1 Holder, andMorgan Stanley Bank, N.A., as Initial Note A-2 Holder (filed as Exhibit 4.8 tothe registrant’s Current Report on Form 8-K filed on May 31, 2019 underCommission File No. 333-228375-01 and incorporated by reference herein).

4.9          Agreement Between Note Holders, dated as of April 26,2019, by and between Morgan Stanley Bank, N.A., as Initial Note A-1 Holder, andDeutsche Bank AG, New York Branch, as Initial Note A-2 Holder (filed as Exhibit4.9 to the registrant’s Current Report on Form 8-K filed on May 31, 2019 underCommission File No. 333-228375-01 and incorporated by reference herein).

4.10         Agreement Between Note Holders, dated as of May 31, 2019,by and between Morgan Stanley Bank, N.A., as Initial Note A-1-A Holder, MorganStanley Bank, N.A., as Initial Note A-1-B Holder, and Morgan Stanley Bank,N.A., as Initial Note A-2 Holder (filed as Exhibit 4.10 to the registrant’sCurrent Report on Form 8-K/A filed on February 25, 2020 under Commission FileNo. 333-228375-01 and incorporated by reference herein).

4.11         Agreement Between Note Holders, dated as of March 7,2019, by and between Morgan Stanley Bank, N.A., as Initial Note A-1 Holder,Initial Note A-5-1 Holder, Initial Note A-5-2 Holder, Initial Note A-5-3 Holderand Initial Note A-5-4 Holder, Citi Real Estate Funding Inc., as Initial NoteA-2 Holder, Initial Note A-6-1 Holder, Initial Note A-6-2 Holder and InitialNote A-6-3 Holder, UBS AG, New York Branch, as Initial Note A-3 Holder, InitialNote A-7-1 Holder, Initial Note A-7-2 Holder, Initial Note A-9 Holder, InitialNote A-10 Holder and Initial Note A-11 Holder, and JPMorgan Chase Bank,National Association, Initial Note A-4 Holder, Initial Note A-8-1 Holder andInitial Note A-8-2 Holder (filed as Exhibit 4.11 to the registrant’s CurrentReport on Form 8-K filed on May 31, 2019 under Commission File No.333-228375-01 and incorporated by reference herein).

4.12         Amended and Restated Co-Lender Agreement, dated as ofMarch 15, 2019, by and between Wells Fargo Bank, National Association, asInitial Note A-1 Holder, Wells Fargo Bank, National Association, as InitialNote A-2 Holder, Wells Fargo Bank, National Association, as Initial Note A-3Holder, Column Financial, Inc., as Initial Note A-4 Holder, Wells Fargo Bank,National Association, as Initial Note A-5 Holder, and KSL Capital Partners CoTrust II, as Initial Note B-1 Holder (filed as Exhibit 4.12 to the registrant’sCurrent Report on Form 8-K filed on May 31, 2019 under Commission File No.333-228375-01 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        Wells Fargo Bank, National Association, as GeneralMaster Servicer

33.2        National Cooperative Bank, N.A., as NCB MasterServicer

33.3        Rialto Capital Advisors, LLC, as General SpecialServicer

33.4        National Cooperative Bank, N.A., as NCB SpecialServicer (see Exhibit 33.2)

33.5        Wilmington Trust, National Association, as Trustee (Omitted. See ExplanatoryNotes.)

33.6        Wells Fargo Bank, National Association, asCertificate Administrator

33.7        Wells Fargo Bank, National Association, asCustodian

33.8        Pentalpha Surveillance LLC, as Operating Advisor

33.9        CoreLogic Solutions, LLC, as Servicing FunctionParticipant

33.10      Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator

33.11      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian

33.12      Wells Fargo Bank, National Association, as PrimaryServicer of The Alhambra Mortgage Loan (see Exhibit 33.1)

33.13      Rialto Capital Advisors, LLC, as Special Servicerof The Alhambra Mortgage Loan (see Exhibit 33.3)

33.14      Wilmington Trust, National Association, as Trustee of The Alhambra MortgageLoan (Omitted. See Explanatory Notes.)

33.15      Wells Fargo Bank, National Association, asCustodian of The Alhambra Mortgage Loan (see Exhibit 33.7)

33.16      Pentalpha Surveillance LLC, as Operating Advisor ofThe Alhambra Mortgage Loan (see Exhibit 33.8)

33.17      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of The Alhambra Mortgage Loan (see Exhibit 33.9)

33.18      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

33.19      Wells Fargo Bank, National Association, as PrimaryServicer of the 350 Bush Street Mortgage Loan (see Exhibit 33.1)

33.20      Rialto Capital Advisors, LLC, as Special Servicerof the 350 Bush Street Mortgage Loan (see Exhibit 33.3)

33.21      Wilmington Trust, National Association, as Trustee of the 350 Bush StreetMortgage Loan (Omitted. See Explanatory Notes.)

33.22      Wells Fargo Bank, National Association, asCustodian of the 350 Bush Street Mortgage Loan (see Exhibit 33.7)

33.23      Pentalpha Surveillance LLC, as Operating Advisor ofthe 350 Bush Street Mortgage Loan (see Exhibit 33.8)

33.24      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 350 Bush Street Mortgage Loan (see Exhibit 33.9)

33.25      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

33.26      Wells Fargo Bank, National Association, as PrimaryServicer of the Ford Factory Mortgage Loan (see Exhibit 33.1)

33.27      Rialto Capital Advisors, LLC, as Special Servicerof the Ford Factory Mortgage Loan (see Exhibit 33.3)

33.28      Wilmington Trust, National Association, as Trustee of the Ford Factory MortgageLoan (Omitted. See Explanatory Notes.)

33.29      Wells Fargo Bank, National Association, asCustodian of the Ford Factory Mortgage Loan (see Exhibit 33.7)

33.30      Pentalpha Surveillance LLC, as Operating Advisor ofthe Ford Factory Mortgage Loan (see Exhibit 33.8)

33.31      CoreLogic Solutions, LLC, as Servicing Function Participantof the Ford Factory Mortgage Loan (see Exhibit 33.9)

33.32      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

33.33      Wells Fargo Bank, National Association, as PrimaryServicer of the Newport Corporate Center Mortgage Loan (see Exhibit 33.1)

33.34      Situs Holdings, LLC, as Special Servicer of theNewport Corporate Center Mortgage Loan

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

33.36      Wells Fargo Bank, National Association, asCustodian of the Newport Corporate Center Mortgage Loan (see Exhibit 33.7)

33.37      Pentalpha Surveillance LLC, as Operating Advisor ofthe Newport Corporate Center Mortgage Loan (see Exhibit 33.8)

33.38      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Newport Corporate Center Mortgage Loan (see Exhibit 33.9)

33.39      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

33.40      Wells Fargo Bank, National Association, as PrimaryServicer of the 9201 West Sunset Boulevard Mortgage Loan (see Exhibit 33.1)

33.41      Rialto Capital Advisors, LLC, as Special Servicerof the 9201 West Sunset Boulevard Mortgage Loan (see Exhibit 33.3)

33.42      Wilmington Trust, National Association, as Trustee of the 9201 West SunsetBoulevard Mortgage Loan (Omitted. See Explanatory Notes.)

33.43      Wells Fargo Bank, National Association, asCustodian of the 9201 West Sunset Boulevard Mortgage Loan (see Exhibit 33.7)

33.44      Pentalpha Surveillance LLC, as Operating Advisor ofthe 9201 West Sunset Boulevard Mortgage Loan (see Exhibit 33.8)

33.45      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 9201 West Sunset Boulevard Mortgage Loan (see Exhibit 33.9)

33.46      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

33.47      Wells Fargo Bank, National Association, as PrimaryServicer of the Central Tower Mortgage Loan (see Exhibit 33.1)

33.48      Rialto Capital Advisors, LLC, as Special Servicerof the Central Tower Mortgage Loan (see Exhibit 33.3)

33.49      Wilmington Trust, National Association, as Trustee of the Central TowerMortgage Loan (Omitted. See Explanatory Notes.)

33.50      Wells Fargo Bank, National Association, as Custodianof the Central Tower Mortgage Loan (see Exhibit 33.7)

33.51      Pentalpha Surveillance LLC, as Operating Advisor ofthe Central Tower Mortgage Loan (see Exhibit 33.8)

33.52      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Central Tower Mortgage Loan (see Exhibit 33.9)

33.53      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

33.54      Wells Fargo Bank, National Association, as PrimaryServicer of the Westin Atlanta Airport Mortgage Loan (see Exhibit 33.1)

33.55      Rialto Capital Advisors, LLC, as Special Servicerof the Westin Atlanta Airport Mortgage Loan (see Exhibit 33.3)

33.56      Wilmington Trust, National Association, as Trustee of the Westin AtlantaAirport Mortgage Loan (Omitted. See Explanatory Notes.)

33.57      Wells Fargo Bank, National Association, asCustodian of the Westin Atlanta Airport Mortgage Loan (see Exhibit 33.7)

33.58      Pentalpha Surveillance LLC, as Operating Advisor ofthe Westin Atlanta Airport Mortgage Loan (see Exhibit 33.8)

33.59      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Westin Atlanta Airport Mortgage Loan (see Exhibit 33.9)

33.60      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

33.61      Midland Loan Services, a Division of PNC Bank, National Association, as PrimaryServicer of the ILPT Hawaii Portfolio Mortgage Loan (Omitted. See ExplanatoryNotes.) 

33.62      Rialto Capital Advisors, LLC, as Special Servicerof the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 33.3)

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

33.64      Wells Fargo Bank, National Association, asCustodian of the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 33.7)

33.65      Park Bridge Lender Services LLC, as OperatingAdvisor of the ILPT Hawaii Portfolio Mortgage Loan

33.66      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

33.67      Wells Fargo Bank, National Association, as PrimaryServicer of the Great Wolf Lodge Southern California Mortgage Loan (see Exhibit33.1)

33.68      Situs Holdings, LLC, as Special Servicer of theGreat Wolf Lodge Southern California Mortgage Loan (see Exhibit 33.34)

33.69      Wilmington Trust, National Association, as Trustee of the Great Wolf LodgeSouthern California Mortgage Loan (Omitted. See Explanatory Notes.)

33.70      Wells Fargo Bank, National Association, asCustodian of the Great Wolf Lodge Southern California Mortgage Loan (seeExhibit 33.7)

33.71      Park Bridge Lender Services LLC, as OperatingAdvisor of the Great Wolf Lodge Southern California Mortgage Loan (see Exhibit33.65)

33.72      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Great Wolf Lodge Southern California Mortgage Loan (seeExhibit 33.9)

33.73      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

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

34.1        Wells Fargo Bank, National Association, as GeneralMaster Servicer

34.2        National Cooperative Bank, N.A., as NCB MasterServicer

34.3        Rialto Capital Advisors, LLC, as General SpecialServicer

34.4        National Cooperative Bank, N.A., as NCB SpecialServicer (see Exhibit 34.2)

34.5        Wilmington Trust, National Association, as Trustee (Omitted. See ExplanatoryNotes.)

34.6        Wells Fargo Bank, National Association, asCertificate Administrator

34.7        Wells Fargo Bank, National Association, asCustodian

34.8        Pentalpha Surveillance LLC, as Operating Advisor

34.9        CoreLogic Solutions, LLC, as Servicing FunctionParticipant

34.10      Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator

34.11      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian

34.12      Wells Fargo Bank, National Association, as PrimaryServicer of The Alhambra Mortgage Loan (see Exhibit 34.1)

34.13      Rialto Capital Advisors, LLC, as Special Servicerof The Alhambra Mortgage Loan (see Exhibit 34.3)

34.14      Wilmington Trust, National Association, as Trustee of The Alhambra MortgageLoan (Omitted. See Explanatory Notes.)

34.15      Wells Fargo Bank, National Association, asCustodian of The Alhambra Mortgage Loan (see Exhibit 34.7)

34.16      Pentalpha Surveillance LLC, as Operating Advisor ofThe Alhambra Mortgage Loan (see Exhibit 34.8)

34.17      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of The Alhambra Mortgage Loan (see Exhibit 34.9)

34.18      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

34.19      Wells Fargo Bank, National Association, as PrimaryServicer of the 350 Bush Street Mortgage Loan (see Exhibit 34.1)

34.20      Rialto Capital Advisors, LLC, as Special Servicerof the 350 Bush Street Mortgage Loan (see Exhibit 34.3)

34.21      Wilmington Trust, National Association, as Trustee of the 350 Bush StreetMortgage Loan (Omitted. See Explanatory Notes.)

34.22      Wells Fargo Bank, National Association, asCustodian of the 350 Bush Street Mortgage Loan (see Exhibit 34.7)

34.23      Pentalpha Surveillance LLC, as Operating Advisor ofthe 350 Bush Street Mortgage Loan (see Exhibit 34.8)

34.24      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 350 Bush Street Mortgage Loan (see Exhibit 34.9)

34.25      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

34.26      Wells Fargo Bank, National Association, as PrimaryServicer of the Ford Factory Mortgage Loan (see Exhibit 34.1)

34.27      Rialto Capital Advisors, LLC, as Special Servicerof the Ford Factory Mortgage Loan (see Exhibit 34.3)

34.28      Wilmington Trust, National Association, as Trustee of the Ford Factory MortgageLoan (Omitted. See Explanatory Notes.)

34.29      Wells Fargo Bank, National Association, asCustodian of the Ford Factory Mortgage Loan (see Exhibit 34.7)

34.30      Pentalpha Surveillance LLC, as Operating Advisor ofthe Ford Factory Mortgage Loan (see Exhibit 34.8)

34.31      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Ford Factory Mortgage Loan (see Exhibit 34.9)

34.32      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

34.33      Wells Fargo Bank, National Association, as PrimaryServicer of the Newport Corporate Center Mortgage Loan (see Exhibit 34.1)

34.34      Situs Holdings, LLC, as Special Servicer of theNewport Corporate Center Mortgage Loan

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

34.36      Wells Fargo Bank, National Association, asCustodian of the Newport Corporate Center Mortgage Loan (see Exhibit 34.7)

34.37      Pentalpha Surveillance LLC, as Operating Advisor ofthe Newport Corporate Center Mortgage Loan (see Exhibit 34.8)

34.38      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Newport Corporate Center Mortgage Loan (see Exhibit 34.9)

34.39      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

34.40      Wells Fargo Bank, National Association, as Primary Servicerof the 9201 West Sunset Boulevard Mortgage Loan (see Exhibit 34.1)

34.41      Rialto Capital Advisors, LLC, as Special Servicerof the 9201 West Sunset Boulevard Mortgage Loan (see Exhibit 34.3)

34.42      Wilmington Trust, National Association, as Trustee of the 9201 West SunsetBoulevard Mortgage Loan (Omitted. See Explanatory Notes.)

34.43      Wells Fargo Bank, National Association, asCustodian of the 9201 West Sunset Boulevard Mortgage Loan (see Exhibit 34.7)

34.44      Pentalpha Surveillance LLC, as Operating Advisor ofthe 9201 West Sunset Boulevard Mortgage Loan (see Exhibit 34.8)

34.45      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 9201 West Sunset Boulevard Mortgage Loan (see Exhibit 34.9)

34.46      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

34.47      Wells Fargo Bank, National Association, as PrimaryServicer of the Central Tower Mortgage Loan (see Exhibit 34.1)

34.48      Rialto Capital Advisors, LLC, as Special Servicerof the Central Tower Mortgage Loan (see Exhibit 34.3)

34.49      Wilmington Trust, National Association, as Trustee of the Central TowerMortgage Loan (Omitted. See Explanatory Notes.)

34.50      Wells Fargo Bank, National Association, asCustodian of the Central Tower Mortgage Loan (see Exhibit 34.7)

34.51      Pentalpha Surveillance LLC, as Operating Advisor ofthe Central Tower Mortgage Loan (see Exhibit 34.8)

34.52      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Central Tower Mortgage Loan (see Exhibit 34.9)

34.53      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

34.54      Wells Fargo Bank, National Association, as PrimaryServicer of the Westin Atlanta Airport Mortgage Loan (see Exhibit 34.1)

34.55      Rialto Capital Advisors, LLC, as Special Servicerof the Westin Atlanta Airport Mortgage Loan (see Exhibit 34.3)

34.56      Wilmington Trust, National Association, as Trustee of the Westin Atlanta AirportMortgage Loan (Omitted. See Explanatory Notes.)

34.57      Wells Fargo Bank, National Association, asCustodian of the Westin Atlanta Airport Mortgage Loan (see Exhibit 34.7)

34.58      Pentalpha Surveillance LLC, as Operating Advisor ofthe Westin Atlanta Airport Mortgage Loan (see Exhibit 34.8)

34.59      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Westin Atlanta Airport Mortgage Loan (see Exhibit 34.9)

34.60      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

34.61      Midland Loan Services, a Division of PNC Bank, National Association, as PrimaryServicer of the ILPT Hawaii Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.62      Rialto Capital Advisors, LLC, as Special Servicerof the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 34.3)

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

34.64      Wells Fargo Bank, National Association, asCustodian of the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 34.7)

34.65      Park Bridge Lender Services LLC, as OperatingAdvisor of the ILPT Hawaii Portfolio Mortgage Loan

34.66      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

34.67      Wells Fargo Bank, National Association, as PrimaryServicer of the Great Wolf Lodge Southern California Mortgage Loan (see Exhibit34.1)

34.68      Situs Holdings, LLC, as Special Servicer of theGreat Wolf Lodge Southern California Mortgage Loan (see Exhibit 34.34)

34.69      Wilmington Trust, National Association, as Trustee of the Great Wolf LodgeSouthern California Mortgage Loan (Omitted. See Explanatory Notes.)

34.70      Wells Fargo Bank, National Association, asCustodian of the Great Wolf Lodge Southern California Mortgage Loan (seeExhibit 34.7)

34.71      Park Bridge Lender Services LLC, as OperatingAdvisor of the Great Wolf Lodge Southern California Mortgage Loan (see Exhibit34.65)

34.72      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Great Wolf Lodge Southern California Mortgage Loan (seeExhibit 34.9)

34.73      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

35           Servicer compliance statements.

35.1        Wells Fargo Bank, National Association, as GeneralMaster Servicer

35.2        National Cooperative Bank, N.A., as NCB MasterServicer

35.3        Rialto Capital Advisors, LLC, as General SpecialServicer

35.4        National Cooperative Bank, N.A., as NCB SpecialServicer (see Exhibit 35.2)

35.5        Wells Fargo Bank, National Association, asCertificate Administrator

35.6        Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator

35.7        Wells Fargo Bank, National Association, as PrimaryServicer of The Alhambra Mortgage Loan (see Exhibit 35.1)

35.8        Rialto Capital Advisors, LLC, as Special Servicerof The Alhambra Mortgage Loan (see Exhibit 35.3)

35.9        Wells Fargo Bank, National Association, as PrimaryServicer of the 350 Bush Street Mortgage Loan (see Exhibit 35.1)

35.10      Rialto Capital Advisors, LLC, as Special Servicerof the 350 Bush Street Mortgage Loan (see Exhibit 35.3)

35.11      Wells Fargo Bank, National Association, as PrimaryServicer of the Ford Factory Mortgage Loan (see Exhibit 35.1)

35.12      Rialto Capital Advisors, LLC, as Special Servicerof the Ford Factory Mortgage Loan (see Exhibit 35.3)

35.13      Wells Fargo Bank, National Association, as PrimaryServicer of the Newport Corporate Center Mortgage Loan (see Exhibit 35.1)

35.14      Situs Holdings, LLC, as Special Servicer of theNewport Corporate Center Mortgage Loan

35.15      Wells Fargo Bank, National Association, as PrimaryServicer of the 9201 West Sunset Boulevard Mortgage Loan (see Exhibit 35.1)

35.16      Rialto Capital Advisors, LLC, as Special Servicerof the 9201 West Sunset Boulevard Mortgage Loan (see Exhibit 35.3)

35.17      Wells Fargo Bank, National Association, as PrimaryServicer of the Central Tower Mortgage Loan (see Exhibit 35.1)

35.18      Rialto Capital Advisors, LLC, as Special Servicerof the Central Tower Mortgage Loan (see Exhibit 35.3)

35.19      Wells Fargo Bank, National Association, as PrimaryServicer of the Westin Atlanta Airport Mortgage Loan (see Exhibit 35.1)

35.20      Rialto Capital Advisors, LLC, as Special Servicerof the Westin Atlanta Airport Mortgage Loan (see Exhibit 35.3)

35.21      Midland Loan Services, a Division of PNC Bank, National Association, as PrimaryServicer of the ILPT Hawaii Portfolio Mortgage Loan (Omitted. See ExplanatoryNotes.) 

35.22      Rialto Capital Advisors, LLC, as Special Servicerof the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 35.3)

35.23      Wells Fargo Bank, National Association, as PrimaryServicer of the Great Wolf Lodge Southern California Mortgage Loan (see Exhibit35.1)

35.24      Situs Holdings, LLC, as Special Servicer of theGreat Wolf Lodge Southern California Mortgage Loan (see Exhibit 35.14)

99.1         Mortgage Loan Purchase Agreement, dated as of May 21,2019, between Banc of America Merrill Lynch Commercial Mortgage Inc. and Bankof America, National Association (filed as Exhibit 99.3 to the registrant’sCurrent Report on Form 8-K filed on May 31, 2019 under Commission File No.333-228375-01 and incorporated by reference herein)

99.2         Mortgage Loan Purchase Agreement, dated as of May 21,2019, between Banc of America Merrill Lynch Commercial Mortgage Inc. and WellsFargo Bank, National Association (filed as Exhibit 99.1 to the registrant’sCurrent Report on Form 8-K filed on May 31, 2019 under Commission File No.333-228375-01 and incorporated by reference herein)

99.3         Mortgage Loan Purchase Agreement, dated as of May 21,2019, between Banc of America Merrill Lynch Commercial Mortgage Inc. and MorganStanley Mortgage Capital Holdings LLC (filed as Exhibit 99.2 to theregistrant’s Current Report on Form 8-K filed on May 31, 2019 under CommissionFile No. 333-228375-01 and incorporated by reference herein)

99.4         Mortgage Loan Purchase Agreement, dated as of May 21,2019, between Banc of America Merrill Lynch Commercial Mortgage Inc. andNational Cooperative Bank, N.A. (filed as Exhibit 99.4 to the registrant’sCurrent Report on Form 8-K filed on May 31, 2019 under Commission File No.333-228375-01 and incorporated by reference herein)

(b)   The exhibits required to be filed by theRegistrant pursuant to Item 601 of Regulation 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.

Banc of America Merrill LynchCommercial Mortgage Inc.(Depositor)

/s/ Leland F. Bunch, III

Leland F.Bunch, III, President and Chief Executive Officer

(senior officer in charge ofsecuritization of the depositor)

Date: March 14, 2024