**UNITED STATESSECURITIES AND EXCHANGE COMMISSION**

**Washington, D.C. 20549**

**FORM 10-K**

(Mark One)

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

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

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

**For the transition period from _____ to _____Commission file number of the issuing entity: 333-226850-03**

**Central Index Key Number of the issuing entity:0001780131**

**BBCMS Mortgage Trust 2019-C4**

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

** **

**Central Index Key Number of the depositor: 0001541480**

**Barclays Commercial MortgageSecurities LLC**

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

** **

**Central Index Key Number of the sponsor: 0001549574**

**Barclays Capital Real Estate Inc.**

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

** **

**Central Index Key Number of the sponsor: 0001755531**

**Societe Generale FinancialCorporation**

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

** **

**Central Index Key Number of the sponsor: 0001685185**

**UBS AG, acting through its branchlocated at 1285 Avenue of the Americas, New York, New York**

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

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**Central Index Key Number of the sponsor: 0001548405**

**Starwood Mortgage Capital LLC**

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

** **

**Central Index Key Number of the sponsor: 0001654834**

**Rialto Real Estate Fund III – Debt,LP**

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

** **

**Central Index Key Number of the sponsor: 0001548567**

**CIBC Inc.**

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

** **

**Central Index Key Number of the sponsor: 0001542256**

**Natixis Real Estate Capital LLC**

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

** **

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

**the issuing entity)** | **38-4123641**

**38-4123642**

**38-7221351**

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

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

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

**as Certificate Administrator**

**9062 Old Annapolis Road**

**Columbia, MD**

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

**21045**

**(Zip Code)**

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

**(212) 412-4000**

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 filed allreports required to be filed by Section 13 or 15(d) of the Securities ExchangeAct of 1934 during the preceding 12 months (or for such shorter period that theregistrant was required to file such reports), and (2) has been subject to suchfiling requirements for the past 90 days.  ⌧Yes oNo

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

Not applicable.

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

Not applicable.

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

Large acceleratedfiler        o                                                                                                       Acceleratedfiler                                     o

Non-acceleratedfiler          ⌧  (Do not check if asmaller reporting company)                          Smaller reporting company                    o

                                                                                                                                                       Emerging growthcompany                    o

If an emerging growth company, indicate by check mark if theregistrant has elected not to use the extended transition period for 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 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 188 Spear Street MortgageLoan, the ExchangeRight Net Leased Portfolio 28 Mortgage Loan, the MeidingerTower Mortgage Loan, the Maui Portfolio Mortgage Loan and the MarriottSpringHill Suites and Towneplace Suites Mortgage Loan, which constitutedapproximately 6.4%, 4.7%, 2.0%, 1.7% and 1.3%, respectively, of the asset poolof the issuing entity as of its cut-off date, are each an asset of the issuingentity and are each part of a loan combination that includes (a) with respectto the 188 Spear Street Mortgage Loan which is an asset of the issuing entityand two other *pari passu* loans, which are not assets of the issuingentity, (b) with respect to the ExchangeRight Net Leased Portfolio 28 MortgageLoan which is an asset of the issuing entity and two other *pari passu*loans, which are not assets of the issuing entity, (c) with respect to theMeidinger Tower Mortgage Loan which is an asset of the issuing entity and oneother *pari passu* loan, which is not an asset of the issuing entity, (d)with respect to the Maui Portfolio Mortgage Loan which is an asset of theissuing entity and one other *pari passu* loan, which is not an asset ofthe issuing entity and (e) with respect to the Marriott SpringHill Suites andTowneplace Suites Mortgage Loan which is an asset of the issuing entity and oneother *pari passu* loan, which is not an asset of the issuing entity.These loan combinations, including the 188 Spear Street Mortgage Loan, theExchangeRight Net Leased Portfolio 28 Mortgage Loan, the Meidinger TowerMortgage Loan, the Maui Portfolio Mortgage Loan and the Marriott SpringHillSuites and Towneplace Suites Mortgage Loan, are being serviced and administeredpursuant to the Pooling and Servicing Agreement, which is incorporated byreference as Exhibit 4.1 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 ILPT Hawaii Portfolio Mortgage Loan, whichconstituted approximately 2.0% 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 2 North 6th Place Mortgage Loan, which constitutedapproximately 2.1% of the asset pool of the issuing entity as of its cut-offdate.  The 2 North 6th Place Mortgage Loan is an asset of the issuingentity and is part of a loan combination that includes the 2 North 6th PlaceMortgage Loan and two other *pari passu* loans and two subordinatecompanion loans, which are not assets of the issuing entity. A portion of theloan combination was securitized in the Natixis Commercial Mortgage SecuritiesTrust 2019-LVL transaction (the “NCMS 2019-LVL Transaction”). This loancombination, including the 2 North 6th Place Mortgage Loan, is being servicedand administered pursuant to the trust and servicing agreement for the NCMS2019-LVL Transaction, which is incorporated by reference as Exhibit 4.3 to thisAnnual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Town Square Mortgage Loan, which constitutedapproximately 1.1% of the asset pool of the issuing entity as of its cut-offdate.  The Town Square Mortgage Loan is an asset of the issuing entity andis part of a loan combination that includes the Town Square Mortgage Loan andone other *pari passu* loan, which is not an asset of the issuing entity.The other *pari passu* portion of the loan combination was securitized inthe Wells Fargo Commercial Mortgage Trust 2019-C50 transaction, Commission FileNumber 333-226486-05 (the “WFCM 2019-C50 Transaction”). This loancombination, including the Town Square 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 4.4 to thisAnnual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the 10000 Santa Monica Boulevard Mortgage Loan,which constituted approximately 1.1% of the asset pool of the issuing entity asof its cut-off date.  The 10000 Santa Monica Boulevard Mortgage Loan is anasset of the issuing entity and is part of a loan combination that includes the10000 Santa Monica Boulevard Mortgage Loan and seven other *pari passu*loans and one subordinate companion loan, which are not assets of the issuingentity. A portion of the loan combination was securitized in the NatixisCommercial Mortgage Securities Trust 2019-10K transaction (the “NCMS2019-10K Transaction”). This loan combination, including the 10000 SantaMonica Boulevard Mortgage Loan, is being serviced and administered pursuant tothe trust and servicing agreement for the NCMS 2019-10K Transaction, which isincorporated by reference as Exhibit 4.5 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Vanguard Portfolio Mortgage Loan and theSWVP Portfolio Mortgage Loan, which constituted approximately 6.1% and 1.6%,respectively, of the asset pool of the issuing entity as of its cut-offdate.  The Vanguard Portfolio Mortgage Loan and the SWVP PortfolioMortgage Loan are each an asset of the issuing entity and are each part of aloan combination that includes (a) with respect to the Vanguard PortfolioMortgage Loan and three other *pari passu* loans and one subordinatecompanion loan, which are not assets of the issuing entity or (b) with respectto the SWVP Portfolio Mortgage Loan and eight other *pari passu* loans,which are not assets of the issuing entity. A *pari passu* portion of eachloan combination was securitized in the BBCMS Mortgage Trust 2019-C3transaction, Commission File Number 333-226850-02 (the “BBCMS 2019-C3Transaction”). These loan combinations, including the Vanguard PortfolioMortgage Loan and the SWVP Portfolio Mortgage Loan, are being serviced andadministered pursuant to the pooling and servicing agreement for the BBCMS2019-C3 Transaction, which is incorporated by reference as Exhibit 4.6 to thisAnnual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Moffett Towers II - Buildings 3 & 4Mortgage Loan, which constituted approximately 6.9% of the asset pool of theissuing entity as of its cut-off date.  The Moffett Towers II - Buildings3 & 4 Mortgage Loan is an asset of the issuing entity and is part of a loancombination that includes the Moffett Towers II - Buildings 3 & 4 MortgageLoan and ten other *pari passu* loans and three subordinate companionloans, which are not assets of the issuing entity. A portion of the loancombination was securitized in the MFTII 2019-B3B4 Mortgage Trust transaction(the “MFTII 2019-B3B4 Transaction”). This loan combination, includingthe Moffett Towers II - Buildings 3 & 4 Mortgage Loan, is being servicedand administered pursuant to the trust and servicing agreement for the MFTII2019-B3B4 Transaction, which is incorporated by reference as Exhibit 4.7 tothis Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the ExchangeRight Net Leased Portfolio #27Mortgage Loan, which constituted approximately 1.1% of the asset pool of theissuing entity as of its cut-off date.  The ExchangeRight Net LeasedPortfolio #27 Mortgage Loan is an asset of the issuing entity and is part of aloan combination that includes the ExchangeRight Net Leased Portfolio #27Mortgage Loan and one other *pari passu* loan, which is not an asset ofthe issuing entity. The other *pari passu* portion of the loan combinationwas securitized in the Wells Fargo Commercial Mortgage Trust 2019-C51transaction, Commission File Number 333-226486-06 (the “WFCM 2019-C51Transaction”). This loan combination, including the ExchangeRight NetLeased Portfolio #27 Mortgage Loan, is being serviced and administered pursuantto the pooling and servicing agreement for the WFCM 2019-C51 Transaction, whichis incorporated by reference as Exhibit 4.8 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Visions Hotel Portfolio II Mortgage Loan andthe 125 Borinquen Place Mortgage Loan, which constituted approximately 1.8% and1.8%, respectively, of the asset pool of the issuing entity as of its cut-offdate.  The Visions Hotel Portfolio II Mortgage Loan and the 125 BorinquenPlace Mortgage Loan are each an asset of the issuing entity and are each partof a loan combination that includes (a) with respect to the Visions HotelPortfolio II Mortgage Loan and two other *pari passu* loans, which are notassets of the issuing entity or (b) with respect to the 125 Borinquen PlaceMortgage Loan and one other *pari passu* loan, which is not an asset ofthe issuing entity. The other *pari passu* portion of each loancombination was securitized in the Morgan Stanley Capital I Trust 2019-H7transaction, Commission File Number 333-227446-05 (the “MSC 2019-H7Transaction”). These loan combinations, including the Visions HotelPortfolio II Mortgage Loan and the 125 Borinquen Place Mortgage Loan, are beingserviced and administered pursuant to the pooling and servicing agreement forthe MSC 2019-H7 Transaction, which is incorporated by reference as Exhibit 4.9to 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 CIRE Equity Retail & IndustrialPortfolio Mortgage Loan, which constituted approximately 1.0% of the asset poolof the issuing entity as of its cut-off date.  The CIRE Equity Retail& Industrial Portfolio Mortgage Loan is an asset of the issuing entity andis part of a loan combination that includes the CIRE Equity Retail &Industrial Portfolio Mortgage Loan and six other *pari passu* loans, whichare not assets of the issuing entity. A *pari passu* portion of the loancombination was securitized in the Benchmark 2019-B12 Mortgage Trusttransaction, Commission File Number 333-228597-01 (the “Benchmark 2019-B12Transaction”). This loan combination, including the CIRE Equity Retail& Industrial Portfolio Mortgage Loan, is being serviced and administeredpursuant to the pooling and servicing agreement for the Benchmark 2019-B12Transaction, which is incorporated by reference as Exhibit 4.10 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 Mount Kemble Mortgage Loan and theRenaissance Center VI Mortgage Loan, which constituted approximately 1.5% and1.3%, respectively, of the asset pool of the issuing entity as of its cut-offdate.  The Mount Kemble Mortgage Loan and the Renaissance Center VIMortgage Loan are each an asset of the issuing entity and are each part of aloan combination that includes the Mount Kemble Mortgage Loan or theRenaissance Center VI Mortgage Loan and one other *pari passu* loan, whichis not an asset of the issuing entity. The other *pari passu* portion ofeach loan combination was securitized in the Wells Fargo Commercial MortgageTrust 2019-C52 transaction, Commission File Number 333-226486-08 (the “WFCM2019-C52 Transaction”). These loan combinations, including the Mount KembleMortgage Loan and the Renaissance Center VI Mortgage Loan, are being servicedand administered pursuant to the pooling and servicing agreement for the WFCM2019-C52 Transaction, which is incorporated by reference as Exhibit 4.11 tothis Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Ambler Yards Mortgage Loan, whichconstituted approximately 1.1% of the asset pool of the issuing entity as ofits cut-off date.  The Ambler Yards Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the Ambler YardsMortgage Loan and one other *pari passu* loan, which is not an asset ofthe issuing entity. This loan combination, including the Ambler Yards MortgageLoan, was serviced under the Pooling and Servicing Agreement for the issuingentity prior to the closing of the securitization of the other *pari passu*portion of the Ambler Yards loan combination in the UBS Commercial MortgageTrust 2019-C17 transaction, Commission File Number 333-227784-04 (the “UBS2019-C17 Transaction”).  After the closing of the UBS 2019-C17Transaction on October 15, 2019, this loan combination, including the AmblerYards Mortgage Loan was, and will continue to be, serviced and administeredpursuant to the pooling and servicing agreement with respect to the UBS2019-C17 Transaction, which is incorporated by reference as Exhibit 4.12 tothis Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Inland Life Storage Portfolio Mortgage Loan,which constituted approximately 3.3% of the asset pool of the issuing entity asof its cut-off date.  The Inland Life Storage Portfolio Mortgage Loan isan asset of the issuing entity and is part of a loan combination that includesthe Inland Life Storage Portfolio Mortgage Loan and four other *pari passu*loans, which are not assets of the issuing entity. This loan combination,including the Inland Life Storage Portfolio Mortgage Loan, was serviced underthe pooling and servicing agreement for the WFCM 2019-C52 Transaction for theissuing entity prior to the closing of the securitization of a *pari passu*portion of the Inland Life Storage Portfolio loan combination in the CF2019-CF2 Mortgage Trust transaction, Commission File Number 333-228697-02 (the“CF 2019-CF2 Transaction”).  After the closing of the CF 2019-CF2Transaction on October 17, 2019, this loan combination, including the InlandLife Storage Portfolio Mortgage Loan was, and will continue to be, serviced andadministered pursuant to the pooling and servicing agreement with respect tothe CF 2019-CF2 Transaction, which is incorporated by reference as Exhibit 4.13to this Annual Report on Form 10-K.

The master servicer of a poolingand servicing agreement or trust and servicing agreement also functions as theprimary servicer of the related mortgage loans serviced and administered pursuantto 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 master servicer and certificate administrator of themortgage loans serviced under the Pooling and Servicing Agreement and the primaryservicer of the Mount Kemble Mortgage Loan, the Renaissance Center VI MortgageLoan, the ExchangeRight Net Leased Portfolio #27 Mortgage Loan and the TownSquare Mortgage Loan. As a result, Wells Fargo Bank, National Association 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 Wells Fargo Bank, National Association in the capacities described above arelisted in the Exhibit Index.

Wells Fargo Bank, NationalAssociation is the custodian of the mortgage loans serviced under the Poolingand Servicing Agreement, the ILPT Hawaii Portfolio Mortgage Loan, the 125Borinquen Place Mortgage Loan, the Visions Hotel Portfolio II Mortgage Loan,the Mount Kemble Mortgage Loan, the Renaissance Center VI Mortgage Loan, theTown Square Mortgage Loan, the Ambler Yards Mortgage Loan, the ExchangeRightNet Leased Portfolio #27 Mortgage Loan, the Moffett Towers II - Buildings 3& 4 Mortgage Loan, the Vanguard Portfolio Mortgage Loan, the 2 North 6th PlaceMortgage Loan, the SWVP Portfolio Mortgage Loan and the 10000 Santa MonicaBoulevard Mortgage Loan.  As a result, Wells Fargo Bank, NationalAssociation is a servicing function participant in the capacities describedabove, because it is servicing mortgage loans that constituted 5% or more ofthe assets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria and accountants’ attestationreports delivered by Wells Fargo Bank, National Association in the capacitiesdescribed above are listed in the Exhibit Index.

Rialto Capital Advisors, LLC isthe special servicer of the mortgage loans serviced under the Pooling andServicing Agreement, the ILPT Hawaii Portfolio Mortgage Loan, the Ambler YardsMortgage Loan and the Town Square Mortgage Loan. As a result, Rialto CapitalAdvisors, LLC is a “servicer” as defined in Item 1108(a)(2)(iii) of RegulationAB, in the capacities described above, because it is servicing mortgage loansthat constituted 10% or more of the assets of the issuing entity as of itscut-off date. The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby Rialto Capital Advisors, LLC in the capacities described above are listed inthe Exhibit Index.

Park Bridge Lender Services LLC isthe operating advisor of the mortgage loans serviced under the Pooling andServicing Agreement, the Inland Life Storage Portfolio Mortgage Loan, the ILPTHawaii Portfolio Mortgage Loan and the Town Square Mortgage Loan.  As aresult, Park Bridge Lender Services LLC is a servicing function participant inthe capacities described above, because it is servicing mortgage loans thatconstituted 5% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria andaccountants’ attestation reports delivered by Park Bridge Lender Services LLCin the capacities described above are listed in the Exhibit Index.

Midland Loan Services, a Divisionof PNC Bank, National Association is the primary servicer of the Ambler YardsMortgage Loan, the Meidinger Tower Mortgage Loan, the Maui Portfolio MortgageLoan, the ILPT Hawaii Portfolio Mortgage Loan, the 125 Borinquen Place MortgageLoan and the Visions Hotel Portfolio II Mortgage Loan and the primary servicerand special servicer of the Vanguard Portfolio Mortgage Loan, the SWVPPortfolio Mortgage Loan and the CIRE Equity Retail & Industrial PortfolioMortgage Loan. As a result, Midland Loan Services, a Division of PNC Bank,National Association is a “servicer” as defined in Item 1108(a)(2)(iii) ofRegulation 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 Midland Loan Services, a Division of PNC Bank, National Associationin the capacities described above are listed in the Exhibit Index.

KeyBank National Association isthe primary servicer of the Moffett Towers II - Buildings 3 & 4 MortgageLoan, the Inland Life Storage Portfolio Mortgage Loan and the 2 North 6th PlaceMortgage Loan and the primary servicer and special servicer of the 10000 SantaMonica Boulevard Mortgage Loan. As a result, KeyBank National Association 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 KeyBank National Association in the capacities described above are listed inthe Exhibit Index.

Situs Holdings, LLC is the specialservicer of the 2 North 6th Place Mortgage Loan and the Moffett Towers II -Buildings 3 & 4 Mortgage Loan. These mortgage loans constitute more than5%, but less than 10%, of the pool assets of the issuing entity. Therefore, the Depositor included in this Annual Report on Form 10-K anassessment of compliance with applicable servicing criteria for Situs Holdings,LLC and an accountants’ attestation report pursuant to Item 1122 of RegulationAB because Situs Holdings, LLC is servicing more than 5% of the poolassets.  However, the Depositor is not required to include in this AnnualReport on Form 10-K a servicer compliance statement pursuant to Item 1123 ofRegulation AB of Situs Holdings, LLC because Situs Holdings, LLC is anunaffiliated servicer servicing less than 10% of pool assets.

LNR Partners, LLC is the specialservicer of the Visions Hotel Portfolio II Mortgage Loan, the 125 BorinquenPlace Mortgage Loan, the Mount Kemble Mortgage Loan, the Renaissance Center VIMortgage Loan and the Inland Life Storage Portfolio Mortgage Loan.  Thesemortgage loans constitute more than 5%, but less than 10%, of the pool assetsof the issuing entity.  Therefore, the Depositor included in this AnnualReport on Form 10-K an assessment of compliance with applicable servicingcriteria for LNR Partners, LLC and an accountants’ attestation report pursuantto Item 1122 of Regulation AB because LNR Partners, LLC is servicing more than5% of the pool assets.  However, the Depositor is not required to includein this Annual Report on Form 10-K a servicer compliance statement pursuant toItem 1123 of Regulation AB of LNR Partners, LLC because LNR Partners, LLC is anunaffiliated servicer servicing less than 10% of pool assets.

Pentalpha Surveillance LLC is theoperating advisor of the Vanguard Portfolio Mortgage Loan, the 125 BorinquenPlace Mortgage Loan, the Visions Hotel Portfolio II Mortgage Loan, the SWVPPortfolio Mortgage Loan, the Mount Kemble Mortgage Loan, the Renaissance CenterVI Mortgage Loan, the Ambler Yards Mortgage Loan, the ExchangeRight Net LeasedPortfolio #27 Mortgage Loan and the CIRE Equity Retail & IndustrialPortfolio Mortgage Loan.  As a result, Pentalpha Surveillance LLC is aservicing function participant in the capacities described above, because it isservicing mortgage loans that constituted 5% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria and accountants’ attestation reports delivered byPentalpha Surveillance LLC in the capacities described above are listed in theExhibit Index.

Citibank, N.A. acts as trustee ofthe Inland Life Storage Portfolio Mortgage Loan.  Pursuant to the poolingand servicing agreement for the CF 2019-CF2 Transaction, the trustee isrequired to provide an assessment of compliance with applicable servicingcriteria solely with respect to Item 1122(d)(2)(iii) of Regulation AB(regarding advances of funds or guarantees regarding collections, cash flows ordistributions, and any interest or other fees charged for such advances, aremade, reviewed and approved as specified in the transaction agreements).However, during the reporting period, the trustee did not perform any servicingfunction with respect to the servicing criteria specified in Item1122(d)(2)(iii) of Regulation AB.  The master servicer or the specialservicer, to the extent required, performed the servicing function identifiedwith respect to Item 1122(d)(2)(iii) of Regulation AB, and each such partyincluded Item 1122(d)(2)(iii) of Regulation AB in the assessment of compliancewith applicable 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 Inland Life Storage Portfolio MortgageLoan have delivered one or more assessments of compliance with respect to Item1122(d)(2)(iii) of Regulation AB.

Wells Fargo Bank, NationalAssociation acts as trustee of the ILPT Hawaii Portfolio Mortgage Loan, the 2North 6th Place Mortgage Loan, the 10000 Santa Monica Boulevard Mortgage Loan,the Vanguard Portfolio Mortgage Loan, the SWVP Portfolio Mortgage Loan, theMoffett Towers II - Buildings 3 & 4 Mortgage Loan, the 125 Borinquen PlaceMortgage Loan and the Visions Hotel Portfolio II Mortgage Loan.  Pursuantto the trust and servicing agreement for the ILPT 2019-SURF Transaction, thetrust and servicing agreement for the NCMS 2019-LVL Transaction, the trust andservicing agreement for the NCMS 2019-10K Transaction, the pooling andservicing agreement for the BBCMS 2019-C3 Transaction, the trust and servicingagreement for the MFTII 2019-B3B4 Transaction and the pooling and servicingagreement for the MSC 2019-H7 Transaction, the trustee is required to providean assessment of compliance with applicable servicing criteria solely withrespect to Item 1122(d)(2)(iii) of Regulation AB (regarding advances of fundsor 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 with applicableservicing criteria and accountant’s attestation report for the subjecttransaction.  As a result, this Annual Report on Form 10-K does notinclude an assessment of compliance with applicable servicing criteria of thetrustee. One or more other servicers of the ILPT Hawaii Portfolio MortgageLoan, the 2 North 6th Place Mortgage Loan, the 10000 Santa Monica BoulevardMortgage Loan, the Vanguard Portfolio Mortgage Loan, the SWVP PortfolioMortgage Loan, the Moffett Towers II - Buildings 3 & 4 Mortgage Loan, the125 Borinquen Place Mortgage Loan and the Visions Hotel Portfolio II MortgageLoan have delivered one or more assessments of compliance with respect to Item1122(d)(2)(iii) of Regulation AB.

Wilmington Trust, NationalAssociation acts as trustee of the mortgage loans serviced under the Poolingand Servicing Agreement, the Town Square Mortgage Loan, the ExchangeRight NetLeased Portfolio #27 Mortgage Loan, the CIRE Equity Retail & IndustrialPortfolio Mortgage Loan, the Mount Kemble Mortgage Loan, the Renaissance CenterVI Mortgage Loan and the Ambler Yards Mortgage Loan.  Pursuant to thePooling and Servicing Agreement, the pooling and servicing agreement for theWFCM 2019-C50 Transaction, the pooling and servicing agreement for the WFCM 2019-C51Transaction, the pooling and servicing agreement for the Benchmark 2019-B12Transaction, the pooling and servicing agreement for the WFCM 2019-C52Transaction and the pooling and servicing agreement for the UBS 2019-C17Transaction, 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 with applicableservicing criteria of the trustee. One or more other servicers of the mortgageloans serviced under the Pooling and Servicing Agreement, the Town SquareMortgage Loan, the ExchangeRight Net Leased Portfolio #27 Mortgage Loan, theCIRE Equity Retail & Industrial Portfolio Mortgage Loan, the Mount KembleMortgage Loan, the Renaissance Center VI Mortgage Loan and the Ambler YardsMortgage Loan have delivered one or more assessments of compliance with respectto 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 Commercial Real EstateServices, Inc. and National Tax Search, LLC.  These entities were engagedby the master servicer under the Pooling and Servicing Agreement (except withrespect to those mortgage loans for which Midland Loan Services, a Division ofPNC Bank, National Association is the primary servicer) and the primaryservicer of the Town Square Mortgage Loan, the ExchangeRight Net LeasedPortfolio #27 Mortgage Loan, the Mount Kemble Mortgage Loan, the RenaissanceCenter VI Mortgage Loan and the Ambler Yards Mortgage Loan to remit taxpayments received from the escrow accounts of borrowers to local taxing authorities,to report tax amounts due, to verify tax parcel information, and to verifynon-escrow tax payments. These servicing functions are included within theservicing criteria set forth in Items 1122(d)(4)(xi) and 1122(d)(4)(xii) ofRegulation AB.  Therefore, under the principles-based definition of“servicer” set forth in Item 1101(j) of Regulation AB that looks to thefunctions that an entity performs, these vendors are “servicers” for thepurposes of Item 1122 of Regulation AB.  See Compliance and DisclosureInterpretations, Section 301.01 (Item 1101(j)).

The assessments of compliance withapplicable servicing criteria, accountants’ attestation reports and servicercompliance statements of the certificate administrator of the ILPT HawaiiPortfolio Mortgage Loan, the 2 North 6th Place Mortgage Loan, the Town SquareMortgage Loan, the 10000 Santa Monica Boulevard Mortgage Loan, the VanguardPortfolio Mortgage Loan, the SWVP Portfolio Mortgage Loan, the ExchangeRightNet Leased Portfolio #27 Mortgage Loan, the Moffett Towers II - Buildings 3& 4 Mortgage Loan, the 125 Borinquen Place Mortgage Loan, the Visions HotelPortfolio II Mortgage Loan, the Mount Kemble Mortgage Loan, the RenaissanceCenter VI Mortgage Loan, the Ambler Yards Mortgage Loan, the CIRE Equity Retail& Industrial Portfolio Mortgage Loan and the Inland Life Storage PortfolioMortgage Loan listed on the Exhibit Index are omitted from this Annual Reporton Form 10-K as the certificate administrator pursuant to the related poolingand servicing 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 Item1108(a)(2)(i) through (iii) of Regulation AB.

With respect to the *pari passu*loan combinations that include the 2 North 6th Place Mortgage Loan, the MoffettTowers II – Buildings 3 & 4 Mortgage Loan, the Visions Hotel Portfolio IIMortgage Loan, the 125 Borinquen Place Mortgage Loan, the Mount Kemble MortgageLoan, the Renaissance Center VI Mortgage Loan, the Inland Life StoragePortfolio Mortgage Loan, the ExchangeRight Net Leased Portfolio #27 MortgageLoan and the CIRE Equity Retail & Industrial Portfolio Mortgage Loan, (i)the reports on assessment of compliance with servicing criteria and attestationreports on assessment of compliance with servicing criteria of C-III AssetManagement LLC as special servicer of the ExchangeRight Net Leased Portfolio#27 Mortgage Loan and Citibank, N.A. as custodian of the CIRE Equity Retail& Industrial 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 of RegulationAB because they are parties performing activities that address servicingcriteria relating to 5% or less of the assets of the issuing entity; and (ii)the servicer compliance statements of Situs Holdings, LLC as special servicerof the 2 North 6th Place Mortgage Loan and the Moffett Towers II – Buildings 3& 4 Mortgage Loan, C-III Asset Management LLC as special servicer of theExchangeRight Net Leased Portfolio #27 Mortgage Loan and LNR Partners, LLC asspecial servicer of the Visions Hotel Portfolio II Mortgage Loan, the 125Borinquen Place Mortgage Loan, the Mount Kemble Mortgage Loan, the RenaissanceCenter VI Mortgage Loan and the Inland Life Storage Portfolio Mortgage Loan,listed on the Exhibit Index are omitted from this Annual Report on Form 10-K asthey are not required by Item 1123 of Regulation AB to be included on thisAnnual Report on Form 10-K because they are each an unaffiliated party that isnot a “servicer” that meets the criteria in Item 1108(a)(2)(i) through (iii) ofRegulation AB.

**PART I**

**Item 1.  Business.**

Omitted.

**Item 1A.  Risk Factors.**

Omitted.

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

None.

**Item 2.  Properties.**

Omitted.

**Item 3.  Legal Proceedings.**

Omitted.

**Item 4.  Mine Safety Disclosures.**

Not applicable.

**PART II**

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

Omitted.

**Item 6.  Selected Financial Data.**

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**Item 9B.  Other Information.**

None.

**PART III**

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

Omitted.

**Item 11.  Executive Compensation.**

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**ADDITIONAL DISCLOSURE ITEMS FOR REGULATION AB**

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

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

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

No entity or group of affiliated entities provides any externalcreditenhancement 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 material pending legal proceedinginvolving the trust or any party related to the trust, other than routinelitigation incidental to the duties of those respective parties, and thefollowing, with respect to Wells Fargo Bank, National Association, as trustee,as certificate administrator and as custodian, and Citibank, N.A., as trusteeand as custodian.

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

In the ordinary course of business, Citibank, N.A. (“Citibank”)is involved in a number of legal proceedings, including in connection with itsrole as trustee of certain RMBS transactions.  Certain of these Citibankas trustee-related matters are disclosed herein. 

On June 18, 2014, a civil action was filed against Citibankin the Supreme Court of the State of New York by a group of investors in 48private-label RMBS trusts for which Citibank allegedly serves or did serve astrustee, asserting claims for purported violations of the Trust Indenture Actof 1939 (the “Trust Indenture Act”), breach of contract, breach offiduciary duty and negligence based on Citibank’s alleged failure to performits duties as trustee for the 48 RMBS trusts.  On November 24, 2014,plaintiffs sought leave to withdraw this action.  On the same day, asmaller subset of similar plaintiff investors in 27 private-label RMBS trustsfor which Citibank allegedly serves or did serve as trustee, filed a new civilaction against Citibank in the United States District Court for the SouthernDistrict of New York asserting similar claims as the prior action filed instate court.  In January 2015, the court closed plaintiffs’ original statecourt action.  On September 8, 2015, the federal court dismissed allclaims as to 24 of the 27 trusts and allowed certain of the claims to proceedas to the other three trusts. Subsequently, plaintiffs voluntarily dismissed allclaims with respect to two of the three trusts. On April 7, 2017, Citibankfiled a motion for summary judgment. Plaintiffs filed its consolidatedopposition brief and cross motion for partial summary judgment on May 22,2017.  Briefing on those motions was completed on August 4, 2017. On March22, 2018, the court granted Citibank’s motion for summary judgment in itsentirety, denied Plaintiffs’ motion for summary judgment and ordered the clerkto close the case. On April 20, 2018, plaintiffs filed a notice of appeal.Plaintiffs’ opening brief was filed on August 3, 2018. Citibank filed itsopposition on November 2, 2018.  Plaintiffs’ filed their reply on November16, 2018.  On June 7, 2019, the Second Circuit dismissed plaintiffs’appeal following the parties’ filing of a stipulation withdrawing the case withprejudice pursuant to Federal Rule of Appellate Procedure 42.

On November 24, 2015, the same investors that brought thefederal case brought a new civil action in the Supreme Court of the State ofNew York related to 25 private-label RMBS trusts for which Citibank allegedlyserves or did serve as trustee.  This case includes the 24 trustspreviously dismissed in the federal action, and one additional trust.  Theinvestors assert claims for breach of contract, breach of fiduciary duty,breach of duty to avoid conflicts of interest, and violation of New York’sStreit Act (the “Streit Act”).  Following oral argument onCitibank’s motion to dismiss, Plaintiffs filed an amended complaint on August5, 2016.  On June 27, 2017, the state court issued a decision, dismissingthe Event of Default claims, mortgage-file-related claims, the fiduciary dutyclaims, and the conflict of interest claims.  The decision sustainedcertain breach of contract claims including the claim alleging discovery ofbreaches of representations and warranties, a claim related to robo-signing,and the implied covenant of good faith claim.  Citibank appealed the lowercourt’s decision, and on January 16, 2018, the Appellate Division, First Department,dismissed the claims related to robo-signing and the implied covenant of goodfaith, but allowed plaintiffs’ claim alleging discovery of breaches ofrepresentations and warranties to proceed.  On June 7, 2019, plaintiffsfiled a motion for discontinuance of the action and dismissal of plaintiffs’claims with prejudice.

On August 19, 2015, the Federal Deposit Insurance Corporation(“FDIC”) as Receiver for a failed financial institution filed a civilaction against Citibank in the Southern District of New York.  This actionrelates to one private-label RMBS trust for which Citibank formerly served astrustee.  FDIC asserts claims for breach of contract, violation of theStreit Act, and violation of the Trust Indenture Act. Citibank jointly briefeda motion to dismiss with The Bank of New York Mellon and U.S. Bank, N.A.,entities that have also been sued by FDIC in their capacity as trustee, andthese cases have all been consolidated in front of Judge Carter.  OnSeptember 30, 2016, the Court granted the motion to dismiss without prejudicefor lack of subject matter jurisdiction.  On October 14, 2016, FDIC fileda motion for reargument or relief from judgment from the Court’s dismissalorder.  On July 11, 2017, Judge Carter ruled on the motion for reconsiderationregarding his dismissal of the action.  He denied reconsideration of hisdecision on standing, but granted leave to amend the complaint by October 9,2017.  The FDIC subsequently requested an extension of time to file itsamended complaint, which was granted. The FDIC filed its amended complaint onDecember 8, 2017. Defendants’ jointly filed a motion to dismiss the amendedcomplaint and that joint motion was fully briefed as of May 3, 2018.  OnMarch 20, 2019, the Court granted Defendants’ joint motion to dismiss theamended complaint. The FDIC's deadline to file a notice of appeal was April 22,2019. The FDIC has not appealed. 

There can be no assurances as to the outcome of litigation orthe possible impact of litigation on the trustee or the RMBS trusts. However, Citibank denies liability and continues to vigorously defend againstthese litigations.  Furthermore, neither the above-disclosed litigationsnor any other pending legal proceeding involving Citibank will materiallyaffect Citibank’s ability to perform its duties under the related servicingagreement for this CMBS transaction.

**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 August 28, 2019 pursuant to Rule 424(b)(2).

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

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

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the 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 2 North 6th Place Mortgage Loan,which is being serviced and administered pursuant to the trust and servicingagreement for the NCMS 2019-LVL Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit K to the trust andservicing agreement for the NCMS 2019-LVL Transaction incorporated by referenceas Exhibit 4.3 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the NCMS 2019-LVLTransaction responsible for each applicable servicing criteria set forth inItem 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Town Square Mortgage Loan, whichis being serviced and administered pursuant to the pooling and servicingagreement for the WFCM 2019-C50 Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit AA to the pooling and servicingagreement for the WFCM 2019-C50 Transaction incorporated by reference asExhibit 4.4 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the WFCM 2019-C50Transaction responsible for each applicable servicing criteria set forth inItem 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the 10000 Santa Monica BoulevardMortgage Loan, which is being serviced and administered pursuant to the trustand servicing agreement for the NCMS 2019-10K Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit K to thetrust and servicing agreement for the NCMS 2019-10K Transaction incorporated byreference as Exhibit 4.5 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the NCMS2019-10K 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 Vanguard Portfolio Mortgage Loanand the SWVP Portfolio Mortgage Loan, which are being serviced and administeredpursuant to the pooling and servicing agreement for the BBCMS 2019-C3Transaction, are attached hereto under Item 15 to this Annual Report on Form10-K. Attached as Exhibit AA to the pooling and servicing agreement for theBBCMS 2019-C3 Transaction incorporated by reference as Exhibit 4.6 to thisAnnual Report on Form 10-K is a chart identifying the entities participating ina servicing function for the BBCMS 2019-C3 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 Moffett Towers II – Buildings 3& 4 Mortgage Loan, which is being serviced and administered pursuant to thetrust and servicing agreement for the MFTII 2019-B3B4 Transaction, are attachedhereto under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit Lto the trust and servicing agreement for the MFTII 2019-B3B4 Transactionincorporated by reference as Exhibit 4.7 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theMFTII 2019-B3B4 Transaction responsible for each applicable servicing criteriaset 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 ExchangeRight Net LeasedPortfolio #27 Mortgage Loan, which is being serviced and administered pursuantto the pooling and servicing agreement for the WFCM 2019-C51 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-C51Transaction incorporated by reference as Exhibit 4.8 to this Annual Report onForm 10-K is a chart identifying the entities participating in a servicingfunction for the WFCM 2019-C51 Transaction responsible for each applicableservicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the 125 Borinquen Place Mortgage Loanand the Visions Hotel Portfolio II Mortgage Loan, which are being serviced andadministered pursuant to the pooling and servicing agreement for the MSC 2019-H7Transaction, are attached hereto under Item 15 to this Annual Report on Form10-K. Attached as Exhibit AA to the pooling and servicing agreement for the MSC2019-H7 Transaction incorporated by reference as Exhibit 4.9 to this AnnualReport on Form 10-K is a chart identifying the entities participating in aservicing function for the MSC 2019-H7 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 CIRE Equity Retail &Industrial Portfolio Mortgage Loan, which is being serviced and administeredpursuant to the pooling and servicing agreement for the Benchmark 2019-B12Transaction, are attached hereto under Item 15 to this Annual Report on Form10-K. Attached as Exhibit O to the pooling and servicing agreement for theBenchmark 2019-B12 Transaction incorporated by reference as Exhibit 4.10 tothis Annual Report on Form 10-K is a chart identifying the entitiesparticipating in a servicing function for the Benchmark 2019-B12 Transactionresponsible for each applicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Mount Kemble Mortgage Loan andthe Renaissance Center VI Mortgage Loan, which are being serviced and administeredpursuant to the pooling and servicing agreement for the WFCM 2019-C52Transaction, are attached hereto under Item 15 to this Annual Report on Form10-K. Attached as Exhibit AA to the pooling and servicing agreement for theWFCM 2019-C52 Transaction incorporated by reference as Exhibit 4.11 to thisAnnual Report on Form 10-K is a chart identifying the entities participating ina servicing function for the WFCM 2019-C52 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 Ambler Yards Mortgage Loan, whichis being serviced and administered pursuant to the pooling and servicingagreement for the UBS 2019-C17 Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit Z to the pooling andservicing agreement for the UBS 2019-C17 Transaction incorporated by referenceas Exhibit 4.12 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the UBS 2019-C17 Transactionresponsible for each applicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Inland Life Storage PortfolioMortgage Loan, which is being serviced and administered pursuant to the poolingand servicing agreement for the CF 2019-CF2 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Schedule II tothe pooling and servicing agreement for the CF 2019-CF2 Transactionincorporated by reference as Exhibit 4.13 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theCF 2019-CF2 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

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

Material Instance of Noncompliance

In certain instances, the ScheduleAL Files (Item 1125 of Regulation AB) were not reported in accordance with theterms specified in the transaction agreements, in conflict with Item1122(d)(3)(i): “Reports to investors, including those to be filed with theCommission, are maintained in accordance with the transaction agreements andapplicable Commission requirements. Specifically, such reports: (A) Areprepared in accordance with timeframes and other terms set forth in thetransaction agreements”.  The noncompliance consisted of omitted orinaccurately reported fields as described in (1) and (2) below.  (1) Inconnection with other enhancements Midland made to its manual Schedule ALprocess, starting in April 2019, Midland developed and implemented new ScheduleAL reporting templates for each applicable CMBS transaction that closed priorto April 2019 and for each applicable CMBS transaction going forward. Related to this, Midland made certain template setup errors, along with relatedand other manual inputting of information errors, and the errors were notidentified prior to submission of the applicable Schedule AL Files in certaincases due to breakdowns in quality control.  (2) In one applicabletransaction, the related Schedule AL File for a given month was not savedproperly resulting in the prior month's Schedule AL File being submitted forthe given month instead of the correct Schedule AL File. 

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

Steps Taken to Remedy the Material Instance of Noncompliance

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

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

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

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

**PART IV**

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

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

(1) Not applicable

(2) Not applicable

(3) See below

 

4.1          Poolingand Servicing Agreement, dated as of August 1, 2019, among Barclays CommercialMortgage Securities LLC, as Depositor, Wells Fargo Bank, National Association,as Master Servicer, Rialto Capital Advisors, LLC, as Special Servicer, WellsFargo Bank, National Association, as Certificate Administrator, WilmingtonTrust, National Association, as Trustee and Park Bridge Lender Services LLC, asOperating Advisor and as Asset Representations Reviewer (filed as Exhibit 4.1to the registrant’s Current Report on Form 8-K filed on August 28, 2019 underCommission File No. 333-226850-03 and incorporated by reference herein).

4.2          Trustand Servicing Agreement, dated as of March 7, 2019, among Morgan StanleyCapital I Inc., as Depositor, Midland Loan Services, a Division of PNC Bank,National Association, as Servicer, Rialto Capital Advisors, LLC, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administrator,as Custodian and as Trustee, and Park Bridge Lender Services LLC, as OperatingAdvisor (filed as Exhibit 4.6 to the registrant’s Current Report on Form 8-Kfiled on August 28, 2019 under Commission File No. 333-226850-03 and incorporatedby reference herein).

4.3          Trustand Servicing Agreement, dated as of April 23, 2019, among Natixis CommercialMortgage Securities LLC, as Depositor, KeyBank National Association, asServicer, Situs Holdings, LLC, as Special Servicer, and Wells Fargo Bank,National Association, as Trustee and Certificate Administrator (filed asExhibit 4.5 to the registrant’s Current Report on Form 8-K filed on August 28,2019 under Commission File No. 333-226850-03 and incorporated by referenceherein).

4.4          Poolingand Servicing Agreement, dated as of May 1, 2019, among Wells Fargo CommercialMortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, Rialto Capital Advisors, LLC, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Park Bridge LenderServices LLC, as Operating Advisor and as Asset Representations Reviewer (filedas Exhibit 4.10 to the registrant’s Current Report on Form 8-K filed on August28, 2019 under Commission File No. 333-226850-03 and incorporated by referenceherein).

4.5          Trustand Servicing Agreement, dated as of June 4, 2019, among Natixis CommercialMortgage Securities LLC, as Depositor, KeyBank National Association, asServicer, KeyBank National Association, as Special Servicer, and Wells FargoBank, National Association, as Trustee and as Certificate Administrator (filed asExhibit 4.9 to the registrant’s Current Report on Form 8-K filed on August 28,2019 under Commission File No. 333-226850-03 and incorporated by referenceherein).

4.6          Poolingand Servicing Agreement, dated as of June 1, 2019, among Barclays CommercialMortgage Securities LLC, as Depositor, Midland Loan Services, a Division of PNCBank, National Association, as Master Servicer, Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer, Wells FargoBank, National Association, as Certificate Administrator, Wells Fargo Bank,National Association, as Trustee, and Pentalpha Surveillance LLC, as OperatingAdvisor and as Asset Representations Reviewer (filed as Exhibit 4.3 to theregistrant’s Current Report on Form 8-K filed on August 28, 2019 underCommission File No. 333-226850-03 and incorporated by reference herein).

4.7          Trustand Servicing Agreement, dated as of July 11, 2019, among Barclays CommercialMortgage Securities LLC, as Depositor, KeyBank National Association, asServicer, Situs Holdings, LLC, as Special Servicer, and Wells Fargo Bank,National Association, as Certificate Administrator and Trustee (filed asExhibit 4.2 to the registrant’s Current Report on Form 8-K filed on August 28,2019 under Commission File No. 333-226850-03 and incorporated by referenceherein).

4.8          Poolingand Servicing Agreement, dated as of July 1, 2019, among Wells Fargo CommercialMortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, C-III Asset Management LLC, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Pentalpha SurveillanceLLC, as Operating Advisor and as Asset Representations Reviewer (filed asExhibit 4.8 to the registrant’s Current Report on Form 8-K filed on August 28,2019 under Commission File No. 333-226850-03 and incorporated by referenceherein).

4.9          Poolingand Servicing Agreement, dated as of July 1, 2019, among Morgan Stanley CapitalI Inc., as Depositor, Midland Loan Services, a Division of PNC Bank, NationalAssociation, as Master Servicer, LNR Partners, LLC, as Special Servicer, WellsFargo Bank, National Association, as Certificate Administrator and Trustee, andPentalpha Surveillance LLC, as Operating Advisor and Asset RepresentationsReviewer (filed as Exhibit 4.7 to the registrant’s Current Report on Form 8-Kfiled on August 28, 2019 under Commission File No. 333-226850-03 andincorporated by reference herein).

4.10        Poolingand Servicing Agreement, dated as of August 1, 2019, among Citigroup CommercialMortgage Securities Inc., as Depositor, Midland Loan Services, a Division ofPNC Bank, National Association, as Master Servicer, Midland Loan Services, aDivision of PNC Bank, National Association, Pacific Life Insurance Company andTrimont Real Estate Advisors, LLC, each as Special Servicer, PentalphaSurveillance LLC, as Operating Advisor and Asset Representations Reviewer,Citibank, N.A., as Certificate Administrator, and Wilmington Trust, NationalAssociation, as Trustee (filed as Exhibit 4.11 to the registrant’s CurrentReport on Form 8-K filed on August 28, 2019 under Commission File No.333-226850-03 and incorporated by reference herein).

4.11        Poolingand Servicing Agreement, dated as of August 1, 2019, among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, LNR Partners, LLC, as Special Servicer, WellsFargo Bank, National Association, as Certificate Administrator, WilmingtonTrust, National Association, as Trustee, and Pentalpha Surveillance LLC, asOperating Advisor and as Asset Representations Reviewer (filed as Exhibit 4.4to the registrant’s Current Report on Form 8-K filed on August 28, 2019 underCommission File No. 333-226850-03 and incorporated by reference herein).

4.12        Poolingand Servicing Agreement, dated as of October 1, 2019, among UBS CommercialMortgage Securitization Corp., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, Rialto Capital Advisors, LLC, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Pentalpha SurveillanceLLC, as Operating Advisor and as Asset Representations Reviewer (filed asExhibit 4.1 to the registrant’s Current Report on Form 8-K filed on October 18,2019 under Commission File No. 333-226850-03 and incorporated by referenceherein).

4.13        Poolingand Servicing Agreement, dated as of October 1, 2019, among CCRE CommercialMortgage Securities, L.P., as Depositor, KeyBank National Association, asMaster Servicer, KeyBank National Association and LNR Partners, LLC, each as aSpecial Servicer, Citibank, N.A., as Trustee, Citibank, N.A., as CertificateAdministrator, Paying Agent and Custodian, and Park Bridge Lender Services LLC,as Operating Advisor and as Asset Representations Reviewer (filed as Exhibit4.2 to the registrant’s Current Report on Form 8-K filed on October 18, 2019under Commission File No. 333-226850-03 and incorporated by reference herein).

4.14        PrimaryServicing Agreement, dated as of August 1, 2019, between Wells Fargo Bank,National Association, as Master Servicer, and Midland Loan Services, a Divisionof PNC Bank, National Association, as Primary Servicer (filed as Exhibit 4.32to the registrant’s Current Report on Form 8-K filed on October 18, 2019 underCommission File No. 333-226850-03 and incorporated by reference herein).

4.15        Co-LenderAgreement, dated as of July 11, 2019, by and among Barclays Bank PLC, as NoteA-1-A and Note B-1 Holder, Barclays Capital Real Estate Inc., as Initial NoteA-1-B Holder, Initial Note A-1-D Holder and Initial Note A-1-E Holder, Bank ofAmerica, N.A., as Note A-1-C Holder, Deutsche Bank AG, New York Branch, asInitial Note A-2-A Holder, Initial Note A-2-B Holder, Initial Note A-2-C Holderand Initial Note B-2 Holder, and Goldman Sachs Bank USA, as Initial Note A-3-AHolder, Initial Note A-3-B Holder, Initial Note A-3-C Holder and Initial NoteB-3 Holder (filed as Exhibit 4.12 to the registrant’s Current Report on Form8-K filed on August 28, 2019 under Commission File No. 333-226850-03 andincorporated by reference herein).

4.16        AgreementBetween Note Holders, dated as of June 14, 2019, by and between BarclaysCapital Real Estate Inc., as Initial Note A-1 Holder, Barclays Capital RealEstate Inc., as Initial Note A-2 Holder and Barclays Capital Real Estate Inc.,as Initial Note A-3 Holder (filed as Exhibit 4.13 to the registrant’s CurrentReport on Form 8-K filed on October 18, 2019 under Commission File No.333-226850-03 and incorporated by reference herein).

4.17        Amendedand Restated Co-Lender Agreement, dated as of June 11, 2019, by and amongNatixis Real Estate Capital LLC, as Note A-1 Holder, Natixis Real EstateCapital LLC, as Note A-2 Holder, Natixis Real Estate Capital LLC, as Note A-3Holder, Natixis Real Estate Capital LLC, as Note A-4 Holder, Natixis RealEstate Capital LLC, as Note A-5 Holder, Natixis Real Estate Capital LLC, asNote A-6 Holder, and TCM CRE REIT LLC, as Note B Holder (filed as Exhibit 4.14to the registrant’s Current Report on Form 8-K filed on August 28, 2019 underCommission File No. 333-226850-03 and incorporated by reference herein).

4.18        AgreementBetween Note Holders, dated as of August 28, 2019 by and among, SocieteGenerale Financial Corporation, as Initial Note A-1 Holder, Societe GeneraleFinancial Corporation, as Initial Note A-2 Holder, and Societe GeneraleFinancial Corporation, as Initial Note A-3 Holder (filed as Exhibit 4.15 to theregistrant’s Current Report on Form 8-K filed on August 28, 2019 underCommission File No. 333-226850-03 and incorporated by reference herein).

4.19        AgreementBetween Note Holders, dated as of July 2, 2019 by and between, KeyBank NationalAssociation, as Initial Note A-1-A Holder, Initial Note A-1-B Holder andInitial Note A-1-C Holder, and Barclays Capital Real Estate Inc., as InitialNote A-2-A Holder and Initial Note A-2-B Holder (filed as Exhibit 4.16 to theregistrant’s Current Report on Form 8-K filed on August 28, 2019 underCommission File No. 333-226850-03 and incorporated by reference herein).

4.20        Amendedand Restated Co-Lender Agreement, dated as of February 11, 2019, by and amongNatixis Real Estate Capital LLC, as Note A-1 Holder, Natixis Real EstateCapital LLC, as Note A-2 Holder, Natixis Real Estate Capital LLC, as Note A-3Holder, Natixis Real Estate Capital LLC, as Note A-B Holder and John HancockLife Insurance Company (U.S.A.), as Note B Holder (filed as Exhibit 4.17 to theregistrant’s Current Report on Form 8-K filed on August 28, 2019 underCommission File No. 333-226850-03 and incorporated by reference herein).

4.21        AgreementBetween 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-5-2Holder, Initial Note A-5-3 Holder and Initial Note A-5-4 Holder, Citi RealEstate Funding Inc., as Initial Note A-2 Holder, Initial Note A-6-1 Holder,Initial Note A-6-2 Holder and Initial Note A-6-3 Holder, UBS AG, New YorkBranch, as Initial Note A-3 Holder, Initial Note A-7-1 Holder, Initial NoteA-7-2 Holder, Initial Note A-9 Holder, Initial Note A-10 Holder and InitialNote A-11 Holder, and JPMorgan Chase Bank, National Association, as InitialNote A-4 Holder, Initial Note A-8-1 Holder and Initial Note A-8-2 Holder (filedas Exhibit 4.18 to the registrant’s Current Report on Form 8-K filed on August28, 2019 under Commission File No. 333-226850-03 and incorporated by referenceherein).

4.22        AgreementBetween Note Holders, dated as of August 28, 2019, by and between UBS AG, byand through its branch office at 1285 Avenue of the Americas, New York, NewYork, as Initial Note A-1 Holder, and UBS AG, by and through its branch officeat 1285 Avenue of the Americas, New York, New York, as Initial Note A-2 Holder(filed as Exhibit 4.19 to the registrant’s Current Report on Form 8-K filed onAugust 28, 2019 under Commission File No. 333-226850-03 and incorporated byreference herein).

4.23        Co-LenderAgreement, dated as of May 31, 2019, by and between Starwood Mortgage CapitalLLC, as Initial Note A-1 Holder, and Starwood Mortgage Capital LLC, as InitialNote A-2 Holder (filed as Exhibit 4.20 to the registrant’s Current Report onForm 8-K filed on August 28, 2019 under Commission File No. 333-226850-03 andincorporated by reference herein).

4.24        Co-LenderAgreement, dated as of June 11, 2019, by and between Starwood Mortgage CapitalLLC, as Initial Note A-1 Holder, Starwood Mortgage Capital LLC, as Initial NoteA-2 Holder, and Starwood Mortgage Capital LLC, as Initial Note A-3 Holder(filed as Exhibit 4.21 to the registrant’s Current Report on Form 8-K filed onAugust 28, 2019 under Commission File No. 333-226850-03 and incorporated byreference herein).

4.25        AgreementBetween Note Holders, dated as of August 28, 2019, by and between UBS AG, byand through its branch office at 1285 Avenue of the Americas, New York, NewYork, as Initial Note A-1 Holder, and UBS AG, by and through its branch officeat 1285 Avenue of the Americas, New York, New York, as Initial Note A-2 Holder(filed as Exhibit 4.22 to the registrant’s Current Report on Form 8-K filed onAugust 28, 2019 under Commission File No. 333-226850-03 and incorporated byreference herein).

4.26        Co-LenderAgreement, dated as of June 11, 2019, by and between Societe Generale FinancialCorporation and JPMorgan Chase Bank, National Association (filed as Exhibit4.23 to the registrant’s Current Report on Form 8-K filed on August 28, 2019under Commission File No. 333-226850-03 and incorporated by reference herein).

4.27        Co-LenderAgreement, dated as of July 25, 2019, by and between BSPRT Finance Sub-LenderII, LLC, as Note A-1 Holder, and BSPRT Finance Sub-Lender II, LLC, as Note A-2Holder (filed as Exhibit 4.24 to the registrant’s Current Report on Form 8-Kfiled on August 28, 2019 under Commission File No. 333-226850-03 andincorporated by reference herein).

4.28        Co-LenderAgreement, dated as of July 25, 2019, by and between BSPRT Finance Sub-LenderI, LLC, as Note A-1 Holder, and BSPRT Finance Sub-Lender I, LLC, as Note A-2Holder (filed as Exhibit 4.25 to the registrant’s Current Report on Form 8-Kfiled on August 28, 2019 under Commission File No. 333-226850-03 andincorporated by reference herein).

4.29        Co-LenderAgreement, dated as of June 6, 2019, by and between Starwood Mortgage CapitalLLC, as Initial Note A-1 Holder, and Starwood Mortgage Capital LLC, as InitialNote A-2 Holder (filed as Exhibit 4.26 to the registrant’s Current Report onForm 8-K filed on August 28, 2019 under Commission File No. 333-226850-03 andincorporated by reference herein).

4.30        AgreementBetween Note Holders, dated as of June 14, 2019, by and between Barclays CapitalReal Estate Inc., as Initial Note A-1 Holder, and Barclays Capital Real EstateInc., as Initial Note A-2 Holder (filed as Exhibit 4.27 to the registrant’sCurrent Report on Form 8-K filed on August 28, 2019 under Commission File No.333-226850-03 and incorporated by reference herein).

4.31        Co-LenderAgreement, dated as of June 4, 2019, by and among Natixis Real Estate CapitalLLC, as Note A-1 Holder, Natixis Real Estate Capital LLC, as Note A-2 Holder,Natixis Real Estate Capital LLC, as Note A-3 Holder, Natixis Real EstateCapital LLC, as Note A-4 Holder, Natixis Real Estate Capital LLC, as Note A-5Holder, Natixis Real Estate Capital LC, as Note A-6 Holder, Natixis Real EstateCapital LLC, as Note A-7 Holder, and Natixis Real Estate Capital LLC, as NoteA-B Holder (filed as Exhibit 4.28 to the registrant’s Current Report on Form8-K filed on August 28, 2019 under Commission File No. 333-226850-03 andincorporated by reference herein).

4.32        Co-LenderAgreement, dated as of April 12, 2019, by and between BSPRT Finance Sub-LenderI, LLC, as Note A-1 Holder, and BSPRT Finance Sub-Lender I, LLC, as Note A-2Holder (filed as Exhibit 4.29 to the registrant’s Current Report on Form 8-Kfiled on August 28, 2019 under Commission File No. 333-226850-03 andincorporated by reference herein).

4.33        AgreementBetween Note Holders, dated as of August 28, 2019, by and between UBS AG, byand through its branch office at 1285 Avenue of the Americas, New York, NewYork, as Initial Note A-1 Holder, and UBS AG, by and through its branch officeat 1285 Avenue of the Americas, New York, New York, as Initial Note A-2 Holder(filed as Exhibit 4.30 to the registrant’s Current Report on Form 8-K filed onAugust 28, 2019 under Commission File No. 333-226850-03 and incorporated byreference herein).

4.34        AgreementBetween Noteholders, dated as of July 11, 2019, by and between Deutsche BankAG, New York Branch, as Initial Note A-1 Holder, Deutsche Bank AG, New YorkBranch, as Initial Note A-2 Holder, Deutsche Bank AG, New York Branch, asInitial Note A-3 Holder, UBS AG, by and through its branch office at 1285Avenue of the Americas, New York, New York, as Initial Note A-4 Holder, UBS AG,by and through its branch office at 1285 Avenue of the Americas, New York, NewYork, as Initial Note A-5 Holder, and UBS AG, by and through its branch officeat 1285 Avenue of the Americas, New York, New York, as Initial Note A-6 Holder(filed as Exhibit 4.31 to the registrant’s Current Report on Form 8-K filed onAugust 28, 2019 under Commission File No. 333-226850-03 and incorporated byreference 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, NationalAssociation, as Master Servicer

33.2        Rialto Capital Advisors,LLC, as Special Servicer

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

33.4        Wells Fargo Bank, NationalAssociation, as Certificate Administrator

33.5        Wells Fargo Bank, NationalAssociation, as Custodian

33.6        Park Bridge LenderServices LLC, as Operating Advisor

33.7        CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant

33.8        National Tax Search, LLC,as Servicing Function Participant

33.9        Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer

33.10      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 188 Spear Street Mortgage Loan (seeExhibit 33.1)

33.11      Rialto Capital Advisors,LLC, as Special Servicer of the 188 Spear Street Mortgage Loan (see Exhibit33.2)

33.12      Wilmington Trust, National Association, as Trustee of the 188 Spear StreetMortgage Loan (Omitted. See Explanatory Notes.)

33.13      Wells Fargo Bank, NationalAssociation, as Custodian of the 188 Spear Street Mortgage Loan (see Exhibit33.5)

33.14      Park Bridge LenderServices LLC, as Operating Advisor of the 188 Spear Street Mortgage Loan (seeExhibit 33.6)

33.15      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the 188 SpearStreet Mortgage Loan (see Exhibit 33.7)

33.16      National Tax Search, LLC,as Servicing Function Participant of the 188 Spear Street Mortgage Loan (seeExhibit 33.8)

33.17      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the ExchangeRight Net Leased Portfolio 28Mortgage Loan (see Exhibit 33.1)

33.18      Rialto Capital Advisors,LLC, as Special Servicer of the ExchangeRight Net Leased Portfolio 28 MortgageLoan (see Exhibit 33.2)

33.19      Wilmington Trust, National Association, as Trustee of the ExchangeRight NetLeased Portfolio 28 Mortgage Loan (Omitted. See Explanatory Notes.)

33.20      Wells Fargo Bank, NationalAssociation, as Custodian of the ExchangeRight Net Leased Portfolio 28 MortgageLoan (see Exhibit 33.5)

33.21      Park Bridge LenderServices LLC, as Operating Advisor of the ExchangeRight Net Leased Portfolio 28Mortgage Loan (see Exhibit 33.6)

33.22      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the ExchangeRightNet Leased Portfolio 28 Mortgage Loan (see Exhibit 33.7)

33.23      National Tax Search, LLC,as Servicing Function Participant of the ExchangeRight Net Leased Portfolio 28Mortgage Loan (see Exhibit 33.8)

33.24      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of theMeidinger Tower Mortgage Loan (see Exhibit 33.9)

33.25      Rialto Capital Advisors,LLC, as Special Servicer of the Meidinger Tower Mortgage Loan (see Exhibit33.2)

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

33.27      Wells Fargo Bank, NationalAssociation, as Custodian of the Meidinger Tower Mortgage Loan (see Exhibit33.5)

33.28      Park Bridge LenderServices LLC, as Operating Advisor of the Meidinger Tower Mortgage Loan (seeExhibit 33.6)

33.29      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the MauiPortfolio Mortgage Loan (see Exhibit 33.9)

33.30      Rialto Capital Advisors,LLC, as Special Servicer of the Maui Portfolio Mortgage Loan (see Exhibit 33.2)

33.31      Wilmington Trust, National Association, as Trustee of the Maui PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.32      Wells Fargo Bank, NationalAssociation, as Custodian of the Maui Portfolio Mortgage Loan (see Exhibit33.5)

33.33      Park Bridge LenderServices LLC, as Operating Advisor of the Maui Portfolio Mortgage Loan (seeExhibit 33.6)

33.34      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Marriott SpringHill Suites andTowneplace Suites Mortgage Loan (see Exhibit 33.1)

33.35      Rialto Capital Advisors,LLC, as Special Servicer of the Marriott SpringHill Suites and TowneplaceSuites Mortgage Loan (see Exhibit 33.2)

33.36      Wilmington Trust, National Association, as Trustee of the Marriott SpringHillSuites and Towneplace Suites Mortgage Loan (Omitted. See Explanatory Notes.)

33.37      Wells Fargo Bank, NationalAssociation, as Custodian of the Marriott SpringHill Suites and TowneplaceSuites Mortgage Loan (see Exhibit 33.5)

33.38      Park Bridge LenderServices LLC, as Operating Advisor of the Marriott SpringHill Suites andTowneplace Suites Mortgage Loan (see Exhibit 33.6)

33.39      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the MarriottSpringHill Suites and Towneplace Suites Mortgage Loan (see Exhibit 33.7)

33.40      National Tax Search, LLC,as Servicing Function Participant of the Marriott SpringHill Suites andTowneplace Suites Mortgage Loan (see Exhibit 33.8)

33.41      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the ILPTHawaii Portfolio Mortgage Loan (see Exhibit 33.9)

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

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

33.44      Wells Fargo Bank, NationalAssociation, as Custodian of the ILPT Hawaii Portfolio Mortgage Loan (seeExhibit 33.5)

33.45      Park Bridge LenderServices LLC, as Operating Advisor of the ILPT Hawaii Portfolio Mortgage Loan(see Exhibit 33.6)

33.46      KeyBank NationalAssociation, as Primary Servicer of the 2 North 6th Place Mortgage Loan

33.47      Situs Holdings, LLC, asSpecial Servicer of the 2 North 6th Place Mortgage Loan

33.48      Wells Fargo Bank, National Association, as Trustee of the 2 North 6th PlaceMortgage Loan (Omitted. See Explanatory Notes.)

33.49      Wells Fargo Bank, NationalAssociation, as Custodian of the 2 North 6th Place Mortgage Loan (see Exhibit33.5)

33.50      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Town Square Mortgage Loan (see Exhibit33.1)

33.51      Rialto Capital Advisors,LLC, as Special Servicer of the Town Square Mortgage Loan (see Exhibit 33.2)

33.52      Wilmington Trust, National Association, as Trustee of the Town Square MortgageLoan (Omitted. See Explanatory Notes.)

33.53      Wells Fargo Bank, NationalAssociation, as Custodian of the Town Square Mortgage Loan (see Exhibit 33.5)

33.54      Park Bridge LenderServices LLC, as Operating Advisor of the Town Square Mortgage Loan (seeExhibit 33.6)

33.55      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Town SquareMortgage Loan (see Exhibit 33.7)

33.56      National Tax Search, LLC,as Servicing Function Participant of the Town Square Mortgage Loan (see Exhibit33.8)

33.57      KeyBank NationalAssociation, as Primary Servicer of the 10000 Santa Monica Boulevard MortgageLoan (see Exhibit 33.46)

33.58      KeyBank NationalAssociation, as Special Servicer of the 10000 Santa Monica Boulevard MortgageLoan (see Exhibit 33.46)

33.59      Wells Fargo Bank, National Association, as Trustee of the 10000 Santa MonicaBoulevard Mortgage Loan (Omitted. See Explanatory Notes.)

33.60      Wells Fargo Bank, NationalAssociation, as Custodian of the 10000 Santa Monica Boulevard Mortgage Loan(see Exhibit 33.5)

33.61      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the VanguardPortfolio Mortgage Loan (see Exhibit 33.9)

33.62      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the VanguardPortfolio Mortgage Loan (see Exhibit 33.9)

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

33.64      Wells Fargo Bank, NationalAssociation, as Custodian of the Vanguard Portfolio Mortgage Loan (see Exhibit33.5)

33.65      Pentalpha SurveillanceLLC, as Operating Advisor of the Vanguard Portfolio Mortgage Loan

33.66      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the SWVPPortfolio Mortgage Loan (see Exhibit 33.9)

33.67      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the SWVPPortfolio Mortgage Loan (see Exhibit 33.9)

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

33.69      Wells Fargo Bank, NationalAssociation, as Custodian of the SWVP Portfolio Mortgage Loan (see Exhibit33.5)

33.70      Pentalpha SurveillanceLLC, as Operating Advisor of the SWVP Portfolio Mortgage Loan (see Exhibit33.65)

33.71      KeyBank NationalAssociation, as Primary Servicer of the Moffett Towers II - Buildings 3 & 4Mortgage Loan (see Exhibit 33.46)

33.72      Situs Holdings, LLC, asSpecial Servicer of the Moffett Towers II - Buildings 3 & 4 Mortgage Loan(see Exhibit 33.47)

33.73      Wells Fargo Bank, National Association, as Trustee of the Moffett Towers II -Buildings 3 & 4 Mortgage Loan (Omitted. See Explanatory Notes.)

33.74      Wells Fargo Bank, NationalAssociation, as Custodian of the Moffett Towers II - Buildings 3 & 4Mortgage Loan (see Exhibit 33.5)

33.75      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the ExchangeRight Net Leased Portfolio #27Mortgage Loan (see Exhibit 33.1)

33.76      C-III Asset Management LLC, as Special Servicer of the ExchangeRight Net LeasedPortfolio #27 Mortgage Loan (Omitted. See Explanatory Notes.)

33.77      Wilmington Trust, National Association, as Trustee of the ExchangeRight NetLeased Portfolio #27 Mortgage Loan (Omitted. See Explanatory Notes.)

33.78      Wells Fargo Bank, NationalAssociation, as Custodian of the ExchangeRight Net Leased Portfolio #27Mortgage Loan (see Exhibit 33.5)

33.79      Pentalpha SurveillanceLLC, as Operating Advisor of the ExchangeRight Net Leased Portfolio #27Mortgage Loan (see Exhibit 33.65)

33.80      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the ExchangeRightNet Leased Portfolio #27 Mortgage Loan (see Exhibit 33.7)

33.81      National Tax Search, LLC,as Servicing Function Participant of the ExchangeRight Net Leased Portfolio #27Mortgage Loan (see Exhibit 33.8)

33.82      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the VisionsHotel Portfolio II Mortgage Loan (see Exhibit 33.9)

33.83      LNR Partners, LLC, as SpecialServicer of the Visions Hotel Portfolio II Mortgage Loan

33.84      Wells Fargo Bank, National Association, as Trustee of the Visions HotelPortfolio II Mortgage Loan (Omitted. See Explanatory Notes.)

33.85      Wells Fargo Bank, NationalAssociation, as Custodian of the Visions Hotel Portfolio II Mortgage Loan (seeExhibit 33.5)

33.86      Pentalpha SurveillanceLLC, as Operating Advisor of the Visions Hotel Portfolio II Mortgage Loan (seeExhibit 33.65)

33.87      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the 125Borinquen Place Mortgage Loan (see Exhibit 33.9)

33.88      LNR Partners, LLC, asSpecial Servicer of the 125 Borinquen Place Mortgage Loan (see Exhibit 33.83)

33.89      Wells Fargo Bank, National Association, as Trustee of the 125 Borinquen PlaceMortgage Loan (Omitted. See Explanatory Notes.)

33.90      Wells Fargo Bank, NationalAssociation, as Custodian of the 125 Borinquen Place Mortgage Loan (see Exhibit33.5)

33.91      Pentalpha SurveillanceLLC, as Operating Advisor of the 125 Borinquen Place Mortgage Loan (see Exhibit33.65)

33.92      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the CIREEquity Retail & Industrial Portfolio Mortgage Loan (see Exhibit 33.9)

33.93      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the CIREEquity Retail & Industrial Portfolio Mortgage Loan (see Exhibit 33.9)

33.94      Wilmington Trust, National Association, as Trustee of the CIRE Equity Retail& Industrial Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.95      Citibank, N.A., as Custodian of the CIRE Equity Retail & IndustrialPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.96      Pentalpha SurveillanceLLC, as Operating Advisor of the CIRE Equity Retail & Industrial PortfolioMortgage Loan (see Exhibit 33.65)

33.97      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Mount Kemble Mortgage Loan (see Exhibit33.1)

33.98      LNR Partners, LLC, asSpecial Servicer of the Mount Kemble Mortgage Loan (see Exhibit 33.83)

33.99      Wilmington Trust, National Association, as Trustee of the Mount Kemble MortgageLoan (Omitted. See Explanatory Notes.)

33.100    Wells Fargo Bank, NationalAssociation, as Custodian of the Mount Kemble Mortgage Loan (see Exhibit 33.5)

33.101    Pentalpha SurveillanceLLC, as Operating Advisor of the Mount Kemble Mortgage Loan (see Exhibit 33.65)

33.102    CoreLogic Commercial Real EstateServices, Inc., as Servicing Function Participant of the Mount Kemble MortgageLoan (see Exhibit 33.7)

33.103    National Tax Search, LLC,as Servicing Function Participant of the Mount Kemble Mortgage Loan (see Exhibit33.8)

33.104    Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Renaissance Center VI Mortgage Loan(see Exhibit 33.1)

33.105    LNR Partners, LLC, as SpecialServicer of the Renaissance Center VI Mortgage Loan (see Exhibit 33.83)

33.106    Wilmington Trust, National Association, as Trustee of the Renaissance Center VIMortgage Loan (Omitted. See Explanatory Notes.)

33.107    Wells Fargo Bank, NationalAssociation, as Custodian of the Renaissance Center VI Mortgage Loan (seeExhibit 33.5)

33.108    Pentalpha SurveillanceLLC, as Operating Advisor of the Renaissance Center VI Mortgage Loan (seeExhibit 33.65)

33.109    CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the RenaissanceCenter VI Mortgage Loan (see Exhibit 33.7)

33.110    National Tax Search, LLC,as Servicing Function Participant of the Renaissance Center VI Mortgage Loan(see Exhibit 33.8)

33.111    Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the AmblerYards Mortgage Loan (see Exhibit 33.9)

33.112    Rialto Capital Advisors,LLC, as Special Servicer of the Ambler Yards Mortgage Loan (see Exhibit 33.2)

33.113    Wilmington Trust, National Association, as Trustee of the Ambler Yards MortgageLoan (Omitted. See Explanatory Notes.)

33.114    Wells Fargo Bank, NationalAssociation, as Custodian of the Ambler Yards Mortgage Loan (see Exhibit 33.5)

33.115    Pentalpha SurveillanceLLC, as Operating Advisor of the Ambler Yards Mortgage Loan (see Exhibit 33.65)

33.116    KeyBank NationalAssociation, as Primary Servicer of the Inland Life Storage Portfolio MortgageLoan (see Exhibit 33.46)

33.117    LNR Partners, LLC, asSpecial Servicer of the Inland Life Storage Portfolio Mortgage Loan (seeExhibit 33.83)

33.118    Citibank, N.A., as Trustee and Custodian of the Inland Life Storage PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.119    Park Bridge LenderServices LLC, as Operating Advisor of the Inland Life Storage PortfolioMortgage Loan (see Exhibit 33.6)

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

34.1        Wells Fargo Bank, NationalAssociation, as Master Servicer

34.2        Rialto Capital Advisors,LLC, as Special Servicer

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

34.4        Wells Fargo Bank, NationalAssociation, as Certificate Administrator

34.5        Wells Fargo Bank, NationalAssociation, as Custodian

34.6        Park Bridge LenderServices LLC, as Operating Advisor

34.7        CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant

34.8        National Tax Search, LLC,as Servicing Function Participant

34.9        Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer

34.10      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 188 Spear Street Mortgage Loan (seeExhibit 34.1)

34.11      Rialto Capital Advisors,LLC, as Special Servicer of the 188 Spear Street Mortgage Loan (see Exhibit34.2)

34.12      Wilmington Trust, National Association, as Trustee of the 188 Spear StreetMortgage Loan (Omitted. See Explanatory Notes.)

34.13      Wells Fargo Bank, NationalAssociation, as Custodian of the 188 Spear Street Mortgage Loan (see Exhibit34.5)

34.14      Park Bridge Lender ServicesLLC, as Operating Advisor of the 188 Spear Street Mortgage Loan (see Exhibit34.6)

34.15      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the 188 SpearStreet Mortgage Loan (see Exhibit 34.7)

34.16      National Tax Search, LLC,as Servicing Function Participant of the 188 Spear Street Mortgage Loan (seeExhibit 34.8)

34.17      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the ExchangeRight Net Leased Portfolio 28Mortgage Loan (see Exhibit 34.1)

34.18      Rialto Capital Advisors,LLC, as Special Servicer of the ExchangeRight Net Leased Portfolio 28 MortgageLoan (see Exhibit 34.2)

34.19      Wilmington Trust, National Association, as Trustee of the ExchangeRight NetLeased Portfolio 28 Mortgage Loan (Omitted. See Explanatory Notes.)

34.20      Wells Fargo Bank, NationalAssociation, as Custodian of the ExchangeRight Net Leased Portfolio 28 MortgageLoan (see Exhibit 34.5)

34.21      Park Bridge LenderServices LLC, as Operating Advisor of the ExchangeRight Net Leased Portfolio 28Mortgage Loan (see Exhibit 34.6)

34.22      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the ExchangeRightNet Leased Portfolio 28 Mortgage Loan (see Exhibit 34.7)

34.23      National Tax Search, LLC,as Servicing Function Participant of the ExchangeRight Net Leased Portfolio 28Mortgage Loan (see Exhibit 34.8)

34.24      Midland Loan Services, a Divisionof PNC Bank, National Association, as Primary Servicer of the Meidinger TowerMortgage Loan (see Exhibit 34.9)

34.25      Rialto Capital Advisors,LLC, as Special Servicer of the Meidinger Tower Mortgage Loan (see Exhibit34.2)

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

34.27      Wells Fargo Bank, NationalAssociation, as Custodian of the Meidinger Tower Mortgage Loan (see Exhibit34.5)

34.28      Park Bridge LenderServices LLC, as Operating Advisor of the Meidinger Tower Mortgage Loan (seeExhibit 34.6)

34.29      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the MauiPortfolio Mortgage Loan (see Exhibit 34.9)

34.30      Rialto Capital Advisors,LLC, as Special Servicer of the Maui Portfolio Mortgage Loan (see Exhibit 34.2)

34.31      Wilmington Trust, National Association, as Trustee of the Maui PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.32      Wells Fargo Bank, NationalAssociation, as Custodian of the Maui Portfolio Mortgage Loan (see Exhibit34.5)

34.33      Park Bridge LenderServices LLC, as Operating Advisor of the Maui Portfolio Mortgage Loan (seeExhibit 34.6)

34.34      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Marriott SpringHill Suites andTowneplace Suites Mortgage Loan (see Exhibit 34.1)

34.35      Rialto Capital Advisors,LLC, as Special Servicer of the Marriott SpringHill Suites and TowneplaceSuites Mortgage Loan (see Exhibit 34.2)

34.36      Wilmington Trust, National Association, as Trustee of the Marriott SpringHillSuites and Towneplace Suites Mortgage Loan (Omitted. See Explanatory Notes.)

34.37      Wells Fargo Bank, NationalAssociation, as Custodian of the Marriott SpringHill Suites and TowneplaceSuites Mortgage Loan (see Exhibit 34.5)

34.38      Park Bridge Lender ServicesLLC, as Operating Advisor of the Marriott SpringHill Suites and TowneplaceSuites Mortgage Loan (see Exhibit 34.6)

34.39      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the MarriottSpringHill Suites and Towneplace Suites Mortgage Loan (see Exhibit 34.7)

34.40      National Tax Search, LLC,as Servicing Function Participant of the Marriott SpringHill Suites andTowneplace Suites Mortgage Loan (see Exhibit 34.8)

34.41      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the ILPTHawaii Portfolio Mortgage Loan (see Exhibit 34.9)

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

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

34.44      Wells Fargo Bank, NationalAssociation, as Custodian of the ILPT Hawaii Portfolio Mortgage Loan (seeExhibit 34.5)

34.45      Park Bridge LenderServices LLC, as Operating Advisor of the ILPT Hawaii Portfolio Mortgage Loan(see Exhibit 34.6)

34.46      KeyBank NationalAssociation, as Primary Servicer of the 2 North 6th Place Mortgage Loan

34.47      Situs Holdings, LLC, asSpecial Servicer of the 2 North 6th Place Mortgage Loan

34.48      Wells Fargo Bank, National Association, as Trustee of the 2 North 6th PlaceMortgage Loan (Omitted. See Explanatory Notes.)

34.49      Wells Fargo Bank, NationalAssociation, as Custodian of the 2 North 6th Place Mortgage Loan (see Exhibit34.5)

34.50      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Town Square Mortgage Loan (see Exhibit34.1)

34.51      Rialto Capital Advisors,LLC, as Special Servicer of the Town Square Mortgage Loan (see Exhibit 34.2)

34.52      Wilmington Trust, National Association, as Trustee of the Town Square MortgageLoan (Omitted. See Explanatory Notes.)

34.53      Wells Fargo Bank, NationalAssociation, as Custodian of the Town Square Mortgage Loan (see Exhibit 34.5)

34.54      Park Bridge LenderServices LLC, as Operating Advisor of the Town Square Mortgage Loan (seeExhibit 34.6)

34.55      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Town SquareMortgage Loan (see Exhibit 34.7)

34.56      National Tax Search, LLC,as Servicing Function Participant of the Town Square Mortgage Loan (see Exhibit34.8)

34.57      KeyBank National Association,as Primary Servicer of the 10000 Santa Monica Boulevard Mortgage Loan (seeExhibit 34.46)

34.58      KeyBank NationalAssociation, as Special Servicer of the 10000 Santa Monica Boulevard MortgageLoan (see Exhibit 34.46)

34.59      Wells Fargo Bank, National Association, as Trustee of the 10000 Santa MonicaBoulevard Mortgage Loan (Omitted. See Explanatory Notes.)

34.60      Wells Fargo Bank, NationalAssociation, as Custodian of the 10000 Santa Monica Boulevard Mortgage Loan(see Exhibit 34.5)

34.61      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the VanguardPortfolio Mortgage Loan (see Exhibit 34.9)

34.62      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the VanguardPortfolio Mortgage Loan (see Exhibit 34.9)

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

34.64      Wells Fargo Bank, NationalAssociation, as Custodian of the Vanguard Portfolio Mortgage Loan (see Exhibit34.5)

34.65      Pentalpha SurveillanceLLC, as Operating Advisor of the Vanguard Portfolio Mortgage Loan

34.66      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the SWVPPortfolio Mortgage Loan (see Exhibit 34.9)

34.67      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the SWVPPortfolio Mortgage Loan (see Exhibit 34.9)

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

34.69      Wells Fargo Bank, NationalAssociation, as Custodian of the SWVP Portfolio Mortgage Loan (see Exhibit34.5)

34.70      Pentalpha SurveillanceLLC, as Operating Advisor of the SWVP Portfolio Mortgage Loan (see Exhibit34.65)

34.71      KeyBank NationalAssociation, as Primary Servicer of the Moffett Towers II - Buildings 3 & 4Mortgage Loan (see Exhibit 34.46)

34.72      Situs Holdings, LLC, asSpecial Servicer of the Moffett Towers II - Buildings 3 & 4 Mortgage Loan(see Exhibit 34.47)

34.73      Wells Fargo Bank, National Association, as Trustee of the Moffett Towers II -Buildings 3 & 4 Mortgage Loan (Omitted. See Explanatory Notes.)

34.74      Wells Fargo Bank, NationalAssociation, as Custodian of the Moffett Towers II - Buildings 3 & 4Mortgage Loan (see Exhibit 34.5)

34.75      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the ExchangeRight Net Leased Portfolio #27Mortgage Loan (see Exhibit 34.1)

34.76      C-III Asset Management LLC, as Special Servicer of the ExchangeRight Net LeasedPortfolio #27 Mortgage Loan (Omitted. See Explanatory Notes.)

34.77      Wilmington Trust, National Association, as Trustee of the ExchangeRight NetLeased Portfolio #27 Mortgage Loan (Omitted. See Explanatory Notes.)

34.78      Wells Fargo Bank, NationalAssociation, as Custodian of the ExchangeRight Net Leased Portfolio #27Mortgage Loan (see Exhibit 34.5)

34.79      Pentalpha SurveillanceLLC, as Operating Advisor of the ExchangeRight Net Leased Portfolio #27Mortgage Loan (see Exhibit 34.65)

34.80      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the ExchangeRightNet Leased Portfolio #27 Mortgage Loan (see Exhibit 34.7)

34.81      National Tax Search, LLC,as Servicing Function Participant of the ExchangeRight Net Leased Portfolio #27Mortgage Loan (see Exhibit 34.8)

34.82      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the VisionsHotel Portfolio II Mortgage Loan (see Exhibit 34.9)

34.83      LNR Partners, LLC, asSpecial Servicer of the Visions Hotel Portfolio II Mortgage Loan

34.84      Wells Fargo Bank, National Association, as Trustee of the Visions HotelPortfolio II Mortgage Loan (Omitted. See Explanatory Notes.)

34.85      Wells Fargo Bank, NationalAssociation, as Custodian of the Visions Hotel Portfolio II Mortgage Loan (seeExhibit 34.5)

34.86      Pentalpha SurveillanceLLC, as Operating Advisor of the Visions Hotel Portfolio II Mortgage Loan (seeExhibit 34.65)

34.87      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the 125Borinquen Place Mortgage Loan (see Exhibit 34.9)

34.88      LNR Partners, LLC, asSpecial Servicer of the 125 Borinquen Place Mortgage Loan (see Exhibit 34.83)

34.89      Wells Fargo Bank, National Association, as Trustee of the 125 Borinquen PlaceMortgage Loan (Omitted.  See Explanatory Notes).

34.90      Wells Fargo Bank, NationalAssociation, as Custodian of the 125 Borinquen Place Mortgage Loan (see Exhibit34.5)

34.91      Pentalpha SurveillanceLLC, as Operating Advisor of the 125 Borinquen Place Mortgage Loan (see Exhibit34.65)

34.92      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the CIREEquity Retail & Industrial Portfolio Mortgage Loan (see Exhibit 34.9)

34.93      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the CIREEquity Retail & Industrial Portfolio Mortgage Loan (see Exhibit 34.9)

34.94      Wilmington Trust, National Association, as Trustee of the CIRE Equity Retail& Industrial Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.95      Citibank, N.A., as Custodian of the CIRE Equity Retail & IndustrialPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.96      Pentalpha SurveillanceLLC, as Operating Advisor of the CIRE Equity Retail & Industrial PortfolioMortgage Loan (see Exhibit 34.65)

34.97      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Mount Kemble Mortgage Loan (see Exhibit34.1)

34.98      LNR Partners, LLC, asSpecial Servicer of the Mount Kemble Mortgage Loan (see Exhibit 34.83)

34.99      Wilmington Trust, National Association, as Trustee of the Mount Kemble MortgageLoan (Omitted. See Explanatory Notes.)

34.100    Wells Fargo Bank, NationalAssociation, as Custodian of the Mount Kemble Mortgage Loan (see Exhibit 34.5)

34.101    Pentalpha SurveillanceLLC, as Operating Advisor of the Mount Kemble Mortgage Loan (see Exhibit 34.65)

34.102    CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Mount KembleMortgage Loan (see Exhibit 34.7)

34.103    National Tax Search, LLC,as Servicing Function Participant of the Mount Kemble Mortgage Loan (seeExhibit 34.8)

34.104    Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Renaissance Center VI Mortgage Loan(see Exhibit 34.1)

34.105    LNR Partners, LLC, asSpecial Servicer of the Renaissance Center VI Mortgage Loan (see Exhibit 34.83)

34.106    Wilmington Trust, National Association, as Trustee of the Renaissance Center VIMortgage Loan (Omitted. See Explanatory Notes.)

34.107    Wells Fargo Bank, NationalAssociation, as Custodian of the Renaissance Center VI Mortgage Loan (seeExhibit 34.5)

34.108    Pentalpha SurveillanceLLC, as Operating Advisor of the Renaissance Center VI Mortgage Loan (seeExhibit 34.65)

34.109    CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the RenaissanceCenter VI Mortgage Loan (see Exhibit 34.7)

34.110    National Tax Search, LLC,as Servicing Function Participant of the Renaissance Center VI Mortgage Loan(see Exhibit 34.8)

34.111    Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the AmblerYards Mortgage Loan (see Exhibit 34.9)

34.112    Rialto Capital Advisors,LLC, as Special Servicer of the Ambler Yards Mortgage Loan (see Exhibit 34.2)

34.113    Wilmington Trust, National Association, as Trustee of the Ambler Yards MortgageLoan (Omitted. See Explanatory Notes.)

34.114    Wells Fargo Bank, NationalAssociation, as Custodian of the Ambler Yards Mortgage Loan (see Exhibit 34.5)

34.115    Pentalpha SurveillanceLLC, as Operating Advisor of the Ambler Yards Mortgage Loan (see Exhibit 34.65)

34.116    KeyBank NationalAssociation, as Primary Servicer of the Inland Life Storage Portfolio MortgageLoan (see Exhibit 34.46)

34.117    LNR Partners, LLC, asSpecial Servicer of the Inland Life Storage Portfolio Mortgage Loan (seeExhibit 34.83)

34.118    Citibank, N.A., as Trustee and Custodian of the Inland Life Storage PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.119    Park Bridge LenderServices LLC, as Operating Advisor of the Inland Life Storage PortfolioMortgage Loan (see Exhibit 34.6)

35           Servicer compliance statements.

35.1        Wells Fargo Bank, NationalAssociation, as Master Servicer

35.2        Rialto Capital Advisors,LLC, as Special Servicer

35.3        Wells Fargo Bank, NationalAssociation, as Certificate Administrator

35.4        Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer

35.5        Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 188 Spear Street Mortgage Loan (seeExhibit 35.1)

35.6        Rialto Capital Advisors,LLC, as Special Servicer of the 188 Spear Street Mortgage Loan (see Exhibit35.2)

35.7        Wells Fargo Bank, NationalAssociation, as Primary Servicer of the ExchangeRight Net Leased Portfolio 28Mortgage Loan (see Exhibit 35.1)

35.8        Rialto Capital Advisors,LLC, as Special Servicer of the ExchangeRight Net Leased Portfolio 28 MortgageLoan (see Exhibit 35.2)

35.9        Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of theMeidinger Tower Mortgage Loan (see Exhibit 35.4)

35.10      Rialto Capital Advisors,LLC, as Special Servicer of the Meidinger Tower Mortgage Loan (see Exhibit35.2)

35.11      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the MauiPortfolio Mortgage Loan (see Exhibit 35.4)

35.12      Rialto Capital Advisors,LLC, as Special Servicer of the Maui Portfolio Mortgage Loan (see Exhibit 35.2)

35.13      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Marriott SpringHill Suites andTowneplace Suites Mortgage Loan (see Exhibit 35.1)

35.14      Rialto Capital Advisors,LLC, as Special Servicer of the Marriott SpringHill Suites and TowneplaceSuites Mortgage Loan (see Exhibit 35.2)

35.15      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the ILPTHawaii Portfolio Mortgage Loan (see Exhibit 35.4)

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

35.17      KeyBank NationalAssociation, as Primary Servicer of the 2 North 6th Place Mortgage Loan

35.18      Situs Holdings, LLC, as Special Servicer of the 2 North 6th Place Mortgage Loan(Omitted. See Explanatory Notes.)

35.19      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Town Square Mortgage Loan (see Exhibit35.1)

35.20      Rialto Capital Advisors,LLC, as Special Servicer of the Town Square Mortgage Loan (see Exhibit 35.2)

35.21      KeyBank NationalAssociation, as Primary Servicer of the 10000 Santa Monica Boulevard MortgageLoan (see Exhibit 35.17)

35.22      KeyBank NationalAssociation, as Special Servicer of the 10000 Santa Monica Boulevard MortgageLoan (see Exhibit 35.17)

35.23      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the VanguardPortfolio Mortgage Loan (see Exhibit 35.4)

35.24      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the VanguardPortfolio Mortgage Loan (see Exhibit 35.4)

35.25      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the SWVPPortfolio Mortgage Loan (see Exhibit 35.4)

35.26      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the SWVPPortfolio Mortgage Loan (see Exhibit 35.4)

35.27      KeyBank NationalAssociation, as Primary Servicer of the Moffett Towers II - Buildings 3 & 4Mortgage Loan (see Exhibit 35.17)

35.28      Situs Holdings, LLC, as Special Servicer of the Moffett Towers II – Buildings 3& 4 Mortgage Loan (Omitted. See Explanatory Notes.)

35.29      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the ExchangeRight Net Leased Portfolio #27Mortgage Loan (see Exhibit 35.1)

35.30      C-III Asset Management LLC, as Special Servicer of the ExchangeRight Net LeasedPortfolio #27 Mortgage Loan (Omitted.  See Explanatory Notes.)

35.31      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the VisionsHotel Portfolio II Mortgage Loan (see Exhibit 35.4)

35.32      LNR Partners, LLC, as Special Servicer of the Visions Hotel Portfolio IIMortgage Loan (Omitted.  See Explanatory Notes.)

35.33      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the 125Borinquen Place Mortgage Loan (see Exhibit 35.4)

35.34      LNR Partners, LLC, as Special Servicer of the 125 Borinquen Place Mortgage Loan(Omitted.  See Explanatory Notes.)

35.35      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the CIREEquity Retail & Industrial Portfolio Mortgage Loan (see Exhibit 35.4)

35.36      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the CIREEquity Retail & Industrial Portfolio Mortgage Loan (see Exhibit 35.4)

35.37      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Mount Kemble Mortgage Loan (see Exhibit35.1)

35.38      LNR Partners, LLC, as Special Servicer of the Mount Kemble Mortgage Loan(Omitted.  See Explanatory Notes.)

35.39      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Renaissance Center VI Mortgage Loan(see Exhibit 35.1)

35.40      LNR Partners, LLC, as Special Servicer of the Renaissance Center VI MortgageLoan (Omitted.  See Explanatory Notes.)

35.41      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the AmblerYards Mortgage Loan (see Exhibit 35.4)

35.42      Rialto Capital Advisors,LLC, as Special Servicer of the Ambler Yards Mortgage Loan (see Exhibit 35.2)

35.43      KeyBank NationalAssociation, as Primary Servicer of the Inland Life Storage Portfolio MortgageLoan (see Exhibit 35.17)

35.44      LNR Partners, LLC, as Special Servicer of the Inland Life Storage PortfolioMortgage Loan (Omitted.  See Explanatory Notes.)

99.1        MortgageLoan Purchase Agreement, dated as of August 9, 2019, among Barclays CapitalReal Estate Inc., Barclays Capital Holdings Inc., and Barclays CommercialMortgage Securities LLC (filed as Exhibit 99.1 to the registrant’s CurrentReport on Form 8-K filed on August 28, 2019 under Commission File No.333-226850-03 and incorporated by reference herein).

99.2        MortgageLoan Purchase Agreement, dated as of August 9, 2019, among Societe Generale FinancialCorporation, Societe Generale Financial Corporation, and Barclays CommercialMortgage Securities LLC (filed as Exhibit 99.2 to the registrant’s CurrentReport on Form 8-K filed on August 28, 2019 under Commission File No.333-226850-03 and incorporated by reference herein).

99.3        MortgageLoan Purchase Agreement, dated as of August 9, 2019, between UBS AG, by andthrough its branch office at 1285 Avenue of the Americas, New York, New Yorkand Barclays Commercial Mortgage Securities LLC (filed as Exhibit 99.3 to theregistrant’s Current Report on Form 8-K filed on August 28, 2019 underCommission File No. 333-226850-03 and incorporated by reference herein).

99.4        MortgageLoan Purchase Agreement, dated as of August 9, 2019, between Starwood MortgageCapital LLC and Barclays Commercial Mortgage Securities LLC (filed as Exhibit99.4 to the registrant’s Current Report on Form 8-K filed on August 28, 2019under Commission File No. 333-226850-03 and incorporated by reference herein).

99.5        MortgageLoan Purchase Agreement, dated as of August 9, 2019, between Rialto Real EstateFund III – Debt, LP and Barclays Commercial Mortgage Securities LLC (filed asExhibit 99.5 to the registrant’s Current Report on Form 8-K filed on August 28,2019 under Commission File No. 333-226850-03 and incorporated by referenceherein).

99.6        MortgageLoan Purchase Agreement, dated as of August 9, 2019, between CIBC Inc. andBarclays Commercial Mortgage Securities LLC (filed as Exhibit 99.6 to theregistrant’s Current Report on Form 8-K filed on August 28, 2019 underCommission File No. 333-226850-03 and incorporated by reference herein).

99.7        MortgageLoan Purchase Agreement, dated as of August 9, 2019, between Natixis RealEstate Capital LLC and Barclays Commercial Mortgage Securities LLC (filed asExhibit 99.7 to the registrant’s Current Report on Form 8-K filed on August 28,2019 under Commission File No. 333-226850-03 and incorporated by referenceherein).

(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 to besigned on its behalf by the undersigned, thereunto duly authorized.

Barclays Commercial MortgageSecurities LLC(Depositor)

/s/ DanielVinson

DanielVinson, Chief Executive Officer

(senior officer in charge ofsecuritization of the depositor)

Date: March 23, 2020