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National Cooperative Bank

 

**MANAGEMENT'S ASSERTION ON COMPLIANCE WITH APPLICABLESERVICING CRITERIA PURSUANT TO ITEM 1122 OF REGULATION AB**

 

 

1.       Management of the National Cooperative Bank,N.A., (“NCB”, the “Company”, or the “Bank”) is responsible for assessingcompliance with the servicing criteria applicable to it under paragraph (d) ofItem 1122 of Regulation AB of the Securities and Exchange Commission (“SEC”)relating to the servicing of asset-backed securities transactions conducted bythe Bank (the “Platform”) as of and for the year ended December 31, 2019 (the“Reporting Period”). Appendix A identifies the individual asset-backedtransactions and securities defined by management as constituting the Platform;

 

2.       Except as set forth in paragraph 3 below,NCB used the criteria set forth in paragraph (d) of Item 1122 of Regulation ABto assess the compliance with the applicable servicing criteria;

 

3.       The criteria listed in the column titled“Inapplicable Servicing Criteria” on Appendix B hereto are inapplicable to NCBbased on the activities it performed with respect to the Platform for theReporting Period;

 

4.       During the Reporting Period, there were nocash reserve accounts or accounts established as a form of overcollateralization that were required to be separately maintained according totransaction agreements, therefore NCB did not perform any servicing activitiesrelated to these types of accounts as part of criteria 1122(d)(2)(iv) as of andfor the year ended December 31, 2019.

 

5.       During the Reporting Period, there were noadjustments to interest rates or rates of return for pool assets with variablerates, therefore NCB did not perform any servicing activities related tocriteria 1122(d)(4)(ix) as of and for the year ended December 31, 2019.

 

6.       With respect to servicing criteria1122(d)(4)(xi), the Bank has engaged various vendors to perform the activitiesrequired by these servicing criteria. Management has determined that thesevendors are not considered a “servicer” as defined in Item 1101(j) ofRegulation AB, and has elected to take responsibility for assessing compliancewith the servicing criteria applicable to each vendor as permitted by the SEC’sCompliance & Disclosure Interpretation 200.06, Vendors Engaged by Servicers(“C&DI 200.06”), formerly Interpretation 17.06 of the SEC Division ofCorporation Finance Manual of Publicly Available Telephone Interpretations. Aspermitted by C&DI 200.06, management asserts that it has policies andprocedures in place designed to provide reasonable assurance that the vendor’sactivities comply in all material respects with the servicing criteriaapplicable to each vendor. Management is not aware of any material deficienciesin such policies and procedures or any material instances of non-compliance ofthe servicing criteria as relates to NCB by such vendors. Management is solelyresponsible for determining that it meets the SEC requirements to applyC&DI 200.06 for the vendors and related criteria.

 

7.       NCB has complied, in all materialrespects, with the applicable servicing criteria set forth in Item 1122(d) ofRegulation AB, as of December 31, 2019 and for the Reporting Period with respectto the Platform taken as a whole;

 

8.       Grant Thornton LLP, an independentregistered public accounting firm, has issued an attestation report on NCB’sassessment of compliance with the applicable servicing criteria for theReporting Period.

 

 

National Cooperative Bank,N.A.

February 5, 2020

 

 

/s/ Kathleen Luzik

Kathleen Luzik

*Chief Operating Officer*

 

 

**Appendix A to Management’s Assertion**

** **

*Individual Investors for which National CooperativeBank, N.A. Performed Servicing Activities*

 

| **Investor #** | **Pool Description** |
|----------------|----------------------|
| 363            | CSFB 2000 PS4        |
| 377            | MSCI 2004 IQ7        |
| 378            | CSFB 2004 C4         |
| 379            | MSCI 2005 IQ9        |
| 380            | CSFB 2005 C3         |
| 381            | CSFB 2005 C5         |
| 382            | MSCI 2005 IQ10       |
| 383            | CSFB 2006 C1         |
| 384            | MSCI 2006 IQ11       |
| 385            | CSMC 2006 C4         |
| 386            | MSCI 2007 IQ13       |
| 387            | CSFB 2007 C4         |
| 389            | WFBRBS 2013 C12      |
| 391            | WFBRBS 2013 C13      |
| 392            | WFBRBS 2013 C15      |
| 393            | WFBRBS 2013 C16      |
| 394            | WFBRBS 2013 C18      |
| 395            | WFBRBS 2014 C19      |
| 396            | WFBRBS 2014 C20      |
| 397            | WFBRBS 2014 C21      |
| 398            | WFBRBS 2014 C22      |
| 399            | WFBRBS 2014 C23      |
| 400            | WFCM 2014 LC18       |
| 401            | WFCM 2015 C26        |
| 402            | WFCM 2015 C29        |
| 403            | WFCM 2015 C30        |
| 404            | WFCM 2015 LC22       |
| 405            | WFCM 2015 NXS3       |
| 406            | WFCM 2016 C32        |
| 407            | WFCM 2016 C33        |
| 408            | WFCM 2016 C35        |
| 409            | WFCM 2016 LC24       |
| 410            | WFCM 2016 C36        |
| 411            | WFCM 2016 LC25       |
| 412            | WFCM 2017 RC1        |
| 413            | BANK 2017 BNK5       |
| 414            | BANK 2017 BNK6       |
| 415            | BANK 2017 BNK7       |
| 416            | BANK 2017 BNK8       |
| 417            | BANK 2018 BNK10      |
| 418            | BANK 2018 BNK11      |
| 419            | BANK 2018 BNK12      |
| 422            | BANK 2018 BNK13      |
| 423            | BANK 2018 BNK14      |
| 424            | BANK 2018 BNK15      |
| 426            | BANK 2019 BNK16      |
| 427            | BANK 2019 BNK18      |
| 428            | BANK 2019 BNK19      |
| 429            | BANK 2019 BNK20      |
| 461            | BANK 2019 BNK22      |
| 462            | BANK 2019 BNK24      |

 

 

**APPENDIX B to Management’s Assertion**

 

| **SERVICING CRITERIA**                  | **APPLICABLE SERVICING CRITERIA**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | **INAPPLICABLE SERVICING CRITERIA** |
|-----------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------|
| **Reference**                           | **Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | **Performed Directly by NCB**       | **Performed by Vendor(s) for which NCB is the  Responsible Party** | **Performed by subservicer(s) or vendor(s) for which  NCB is NOT the Responsible Party** | **NOT performed by NCB or by subservicer(s) or  vendor(s) retained by NCB** |
| **General Servicing  Considerations**   |
| 1122(d)(1)(i)                           | Policies and procedures are  instituted to monitor any performance or other triggers and events of default  in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | X                                   |   |   |   |
| 1122(d)(1)(ii)                          | If any material servicing  activities are outsourced to third parties, policies and procedures are  instituted to monitor the third party’s performance and compliance with such  servicing activities.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | X                                   |   |   |   |
| 1122(d)(1)(iii)                         | Any requirements in the transaction  agreements to maintain a back-up servicer for the pool assets are maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                |   |   | X |
| 1122(d)(1)(iv)                          | A fidelity bond and errors  and omissions policy is in effect on the party participating in the servicing  function throughout the reporting period in the amount of coverage required  by and otherwise in accordance with the terms of the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                    | X                                   |   |   |   |
| 1122(d)(1)(v)                           | Aggregation of information,  as applicable, is mathematically accurate and the information conveyed  accurately reflects the information.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | X                                   |   |   |   |
| **Cash Collection and  Administration** |
| 1122(d)(2)(i)                           | Payments on pool assets are  deposited into the appropriate custodial bank accounts and related bank clearing  accounts no more than two business days of receipt, or such other number of  days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | X                                   |   |   |   |
| 1122(d)(2)(ii)                          | Disbursements made via wire  transfer on behalf of an obligor or to an investor are made only by authorized  personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | X                                   |   |   |   |
| 1122(d)(2)(iii)                         | Advances of funds or  guarantees regarding collections, cash flows or distributions, and any  interest or other fees charged for such advances, are made, reviewed and  approved as specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | X                                   |   |   |   |
| 1122(d)(2)(iv)                          | The related accounts for the  transaction, such as cash reserve accounts or accounts established as a form  of over collateralization, are separately maintained (e.g., with respect to  commingling of cash) as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                               | X                                   |   |   |   |
| 1122(d)(2)(v)                           | Each custodial account is  maintained at a federally insured depository institution as set forth in the  transaction agreements. For purposes of this criterion, "federally  insured depository institution" with respect to a foreign financial  institution means a foreign financial institution that meets the requirements  of §240.13k-1(b)(1) of this chapter.                                                                                                                                                                                                                                                                                                                                    | X                                   |   |   |   |
| 1122(d)(2)(vi)                          | Unissued checks are  safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | X                                   |   |   |   |
| 1122(d)(2)(vii)                         | Reconciliations are prepared  on a monthly basis for all asset- backed securities related bank accounts,  including custodial accounts and related bank clearing accounts. These  reconciliations: (A) Are mathematically accurate; (B) Are prepared within 30  calendar days after the bank statement cutoff date, or such other number of  days specified in the transaction agreements; (C) Are reviewed and approved  by someone other than the person who prepared the reconciliation; and (D)  Contain explanations for reconciling items. These reconciling items are  resolved within 90 calendar days of their original identification, or such  other number of days specified in the transaction agreements. | X                                   |   |   |   |
| **Investor Remittances and  Reporting** |
| 1122(d)(3)(i)                           | Reports to investors,  including those to be filed with the Commission, are maintained in accordance  with the transaction agreements and applicable Commission requirements.  Specifically, such reports: (A) Are prepared in accordance with timeframes  and other terms set forth in the transaction agreements; (B) Provide  information calculated in accordance with the terms specified in the  transaction agreements; (C) Are filed with the Commission as required by its  rules and regulations; and (D) Agree with investors’ or the trustee’s records  as to the total unpaid principal balance and number of pool assets serviced  by the servicer.                                           |                                |   |   | X |
| 1122(d)(3)(ii)                          | Amounts due to investors are  allocated and remitted in accordance with timeframes, distribution priority  and other terms set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |                                |   |   | X |
| 1122(d)(3)(iii)                         | Disbursements made to an  investor are posted within two business days to the servicer’s investor  records, or such other number of days specified in the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                |   |   | X |
| 1122(d)(3)(iv)                          | Amounts remitted to  investors per the investor reports agree with cancelled checks, or other form  of payment, or custodial bank statements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |                                |   |   | X |
| **Pool Asset Administration**           |
| 1122(d)(4)(i)                           | Collateral or security on  pool assets is maintained as required by the transaction agreements or  related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | X                                   |   |   |   |
| 1122(d)(4)(ii)                          | Pool assets and related  documents are safeguarded as required by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |                                |   |   | X |
| 1122(d)(4)(iii)                         | Any additions, removals or  substitutions to the asset pool are made, reviewed and approved in accordance  with any conditions or requirements in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | X                                   |   |   |   |
| 1122(d)(4)(iv)                          | Payments on pool assets,  including any payoffs, made in accordance with the related pool asset  documents are posted to the applicable servicer's obligor records maintained  no more than two business days after receipt, or such other number of days  specified in the transaction agreements, and allocated to principal, interest  or other items (e.g., escrow) in accordance with the related pool asset  documents.                                                                                                                                                                                                                                                                                           | X                                   |   |   |   |
| 1122(d)(4)(v)                           | The servicer's records  regarding the pool assets agree with the servicer's records with respect to  an obligor's unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | X                                   |   |   |   |
| 1122(d)(4)(vi)                          | Changes with respect to the  terms or status of an obligor's mortgage loans (e.g., loan modifications or  re-aging's) are made, reviewed and approved by authorized personnel in  accordance with the transaction agreements and related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                          | X                                   |   |   |   |
| 1122(d)(4)(vii)                         | Loss mitigation or recovery  actions (e.g. forbearance plans, modifications and deeds in lieu of  foreclosure, foreclosure and repossessions, as applicable) are initiated,  conducted and concluded in accordance with the timeframes or other  requirements established by the a transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                              | X                                   |   |   |   |
| 1122(d)(4)(viii)                        | Records documenting  collection efforts are maintained during the period a pool asset is  delinquent in accordance with the transaction agreements. Such records are  maintained on at least a monthly basis, or such other period specified in the  transaction agreements, and describe the entity's activities in monitoring  delinquent pool assets including, for example, phone calls, letters and  payment rescheduling plans in cases where delinquency is deemed temporary  (e.g., illness or unemployment).                                                                                                                                                                                                   | X                                   |   |   |   |
| 1122(d)(4)(ix)                          | Adjustments to interest  rates or rates of return for pool assets with variable rates are computed  based on the related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | X                                   |   |   |   |
| 1122(d)(4)(x)                           | Regarding any funds held in  trust for an obligor (such as escrow accounts) See following: (A) Such funds  are analyzed, in accordance with the obligor's pool asset documents, on at  least an annual basis, or such other period specified in the transaction  agreements; (B) Interest on such funds is paid, or credited, to obligors in  accordance with applicable pool asset documents and state laws; and (C) Such  funds are returned to the obligor within 30 calendar days of full repayment  of the related pool asset, or such other number of days specified in the  transaction agreements.                                                                                                              | X                                   |   |   |   |
| 1122(d)(4)(xi)                          | Payments made on behalf of  an obligor (such as tax or insurance payments) are made on or before the  related penalty or expiration dates, as indicated on the appropriate bills or  notices for such payments, provided that such support has been received by  the servicer at least 30 calendar days prior to these dates, or such other  number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                    | X                                   | X |   |   |
| 1122(d)(4)(xii)                         | Any late payment penalties  in connection with any payment to be made on behalf of an obligor are paid  from the servicer’s funds and not charged to the obligor, unless the late  payment was due to the obligor’s error or omission.                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | X                                   |   |   |   |
| 1122(d)(4)(xiii)                        | Disbursements made on behalf  of an obligor are posted within two business days to the obligor’s records  maintained by the servicer, or such other number of days specified in the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | X                                   |   |   |   |
| 1122(d)(4)(xiv)                         | Delinquencies, charge-offs  and uncollectible accounts are recognized and recorded in accordance with the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | X                                   |   |   |   |
| 1122(d)(4)(xv)                          | Any external enhancement or  other support, identified in Item 1114(a)(1) through (3) or Item 1115 of this  Regulation AB, is maintained as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |                                |   |   | X |
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