**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: 333-226486-08**

**Central Index Key Number of the issuing entity:0001780678**

**Wells Fargo Commercial MortgageTrust 2019-C52**

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

** **

**Central Index Key Number of the depositor: 0000850779**

**Wells Fargo Commercial MortgageSecurities, Inc.**

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

** **

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

**Wells Fargo Bank, NationalAssociation**

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

** **

**Central Index Key Number of the sponsor: 0001624053**

**Argentic Real Estate Finance LLC**

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

** **

**Central Index Key Number of the sponsor: 0001592182**

**LMF Commercial, LLC**

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

**(formerly known as Rialto MortgageFinance, LLC)**

** **

**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: 0001541468**

**Ladder Capital Finance LLC**

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

** **

**Central Index Key Number of the sponsor: 0001722518**

**BSPRT CMBS Finance, 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)** | **38-4123650**

**38-4123651**

**38-7221355**

**(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:**

**(704) 374-6161**

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

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

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

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

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

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

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

Not applicable.

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

Not applicable.

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

Large acceleratedfiler        o                                                                                                       Acceleratedfiler                                     o

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

                                                                                                                                                       Emerging growthcompany                    o

If an emerging growth company, indicate by check mark if theregistrant has elected not to use the extended transition period for 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 Renaissance Center VI Mortgage Loan, the Mount KembleMortgage Loan and the Del Mar Terrace Apartments Mortgage Loan, whichconstituted approximately 2.5%, 1.9% and 1.1%, 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 the RenaissanceCenter VI Mortgage Loan, the Mount Kemble Mortgage Loan or the Del Mar TerraceApartments Mortgage Loan which are assets of the issuing entity and one other *paripassu* loan, which is not an asset of the issuing entity. These loancombinations, including the Renaissance Center VI Mortgage Loan, the MountKemble Mortgage Loan and the Del Mar Terrace Apartments Mortgage Loan, arebeing serviced and administered pursuant to the Pooling and ServicingAgreement, which is incorporated by reference as Exhibit 4.1 to this AnnualReport on Form 10-K. 

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Moffett Towers II - Buildings 3 & 4Mortgage Loan, which constituted approximately 5.5% 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 *pari passu* portionof the loan combination was securitized in the MFTII 2019-B3B4 Mortgage Trusttransaction (the “MFTII 2019-B3B4 Transaction”). This loan combination,including the Moffett Towers II - Buildings 3 & 4 Mortgage Loan, is beingserviced and administered pursuant to the trust and servicing agreement for theMFTII 2019-B3B4 Transaction, which is incorporated by reference as Exhibit 4.2to 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 El Con Center Mortgage Loan and the ShetlandPark Mortgage Loan, which constituted approximately 2.0% and 1.4%,respectively, of the asset pool of the issuing entity as of its cut-offdate.  The El Con Center Mortgage Loan and the Shetland Park Mortgage Loanare each an asset of the issuing entity and are each part of a loan combinationthat includes the El Con Center Mortgage Loan or the Shetland Park MortgageLoan and one other *pari passu* loan, which is not an asset of the issuingentity. The other *pari passu* portion of each loan combination wassecuritized in the Wells Fargo Commercial Mortgage Trust 2019-C51 transaction,Commission File Number 333-226486-06 (the “WFCM 2019-C51 Transaction”).These loan combinations, including the El Con Center Mortgage Loan and theShetland Park Mortgage Loan, are being serviced and administered pursuant tothe pooling and servicing agreement for the WFCM 2019-C51 Transaction, which isincorporated by reference as Exhibit 4.3 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the SoCal Retail Portfolio Mortgage Loan and theEmbassy Suites at Centennial Olympic Park Mortgage Loan, which constitutedapproximately 4.4% and 4.3%, respectively, of the asset pool of the issuingentity as of its cut-off date.  The SoCal Retail Portfolio Mortgage Loanand the Embassy Suites at Centennial Olympic Park Mortgage Loan are each anasset of the issuing entity and are each part of a loan combination thatincludes (a) with respect to the SoCal Retail Portfolio Mortgage Loan and sevenother *pari passu* loans, which are not assets of the issuing entity or(b) with respect to the Embassy Suites at Centennial Olympic Park Mortgage Loanand two other *pari passu* loans, which are not assets of the issuingentity. A *pari passu* portion of each loan combination was securitized inthe Morgan Stanley Capital I Trust 2019-H7 transaction, Commission File Number333-227446-05 (the “MSC 2019-H7 Transaction”). These loan combinations,including the SoCal Retail Portfolio Mortgage Loan and the Embassy Suites atCentennial Olympic Park Mortgage Loan, are being serviced and administeredpursuant to the pooling and servicing agreement for the MSC 2019-H7Transaction, which is incorporated by reference as Exhibit 4.4 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 188 Spear Street Mortgage Loan, whichconstituted approximately 2.0% of the asset pool of the issuing entity as ofits cut-off date.  The 188 Spear Street Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the 188 SpearStreet Mortgage Loan and two other *pari passu* loans, which are notassets of the issuing entity.This loan combination, including the 188 SpearStreet Mortgage Loan, was serviced under the Pooling and Servicing Agreementfor the issuing entity prior to the closing of the securitization of a *paripassu* portion of the 188 Spear Street loan combination in the BBCMSMortgage Trust 2019-C4 transaction, Commission File Number 333-226850-03 (the “BBCMS2019-C4 Transaction”).  After the closing of the BBCMS 2019-C4Transaction on August 28, 2019, this loan combination, including the 188 SpearStreet Mortgage Loan was, and will continue to be, serviced and administeredpursuant to the pooling and servicing agreement with respect to the BBCMS2019-C4 Transaction, which is incorporated by reference as Exhibit 4.5 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 Smoke Tree Village and Smoke Tree CommonsMortgage Loan, which constituted approximately 1.1% of the asset pool of theissuing entity as of its cut-off date.  The Smoke Tree Village and SmokeTree Commons Mortgage Loan is an asset of the issuing entity and is part of aloan combination that includes the Smoke Tree Village and Smoke Tree CommonsMortgage Loan and two other *pari passu* loans, which are not assets ofthe issuing entity.This loan combination, including the Smoke Tree Village andSmoke Tree Commons Mortgage Loan, was serviced under the Pooling and ServicingAgreement for the issuing entity prior to the closing of the securitization ofa *pari passu* portion of the Smoke Tree Village and Smoke Tree Commonsloan combination in the UBS Commercial Mortgage Trust 2019-C17 transaction,Commission File Number 333-227784-04 (the “UBS 2019-C17 Transaction”). After the closing of the UBS 2019-C17 Transaction on October 15, 2019, thisloan combination, including the Smoke Tree Village and Smoke Tree CommonsMortgage Loan was, and will continue to be, serviced and administered pursuantto the pooling and servicing agreement with respect to the UBS 2019-C17Transaction, which is incorporated by reference as Exhibit 4.6 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 Inland Life Storage Portfolio Mortgage Loan,which constituted approximately 3.5% 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 issuing entity prior to the closingof the securitization of a *pari passu* portion of the Inland Life StoragePortfolio loan combination in the CF 2019-CF2 Mortgage Trust transaction,Commission File Number 333-228697-02 (the “CF 2019-CF2 Transaction”). After the closing of the CF 2019-CF2 Transaction on October 17, 2019, this loancombination, including the Inland Life Storage Portfolio Mortgage Loan was, andwill continue to be, serviced and administered pursuant to the pooling andservicing agreement with respect to the CF 2019-CF2 Transaction, which isincorporated by reference as Exhibit 4.7 to this Annual Report on Form 10-K.

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

Wells Fargo Bank, NationalAssociation is the master servicer and certificate administrator of themortgage loans serviced under the Pooling and Servicing Agreement and theprimary servicer of the 188 Spear Street Mortgage Loan, the El Con CenterMortgage Loan, the Shetland Park Mortgage Loan and the Smoke Tree Village andSmoke Tree Commons Mortgage Loan. As a result, Wells Fargo Bank, NationalAssociation is a “servicer” as defined in Item 1108(a)(2)(iii) of RegulationAB, in the capacities described above, because it is servicing mortgage loansthat constituted 10% or more of the assets of the issuing entity as of itscut-off date. The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby 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 SoCal Retail Portfolio Mortgage Loan, the EmbassySuites at Centennial Olympic Park Mortgage Loan, the 188 Spear Street MortgageLoan, the El Con Center Mortgage Loan, the Shetland Park Mortgage Loan, theSmoke Tree Village and Smoke Tree Commons Mortgage Loan and the Moffett TowersII - Buildings 3 & 4 Mortgage Loan.  As a result, Wells Fargo Bank,National Association 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.

Midland Loan Services, a Divisionof PNC Bank, National Association is the primary servicer of the SoCal RetailPortfolio Mortgage Loan and the Embassy Suites at Centennial Olympic ParkMortgage Loan.  These mortgage loans constitute more than 5%, but lessthan 10%, of the pool assets of the issuing entity.  Therefore, theDepositor included in this Annual Report on Form 10-K an assessment of compliancewith applicable servicing criteria for Midland Loan Services, a Division of PNCBank, National Association and an accountants’ attestation report pursuant toItem 1122 of Regulation AB because Midland Loan Services, a Division of PNCBank, National Association is servicing more than 5% of the pool assets. However, the Depositor is not required to include in this Annual Report on Form10-K a servicer compliance statement pursuant to Item 1123 of Regulation AB ofMidland Loan Services, a Division of PNC Bank, National Association becauseMidland Loan Services, a Division of PNC Bank, National Association is anunaffiliated servicer servicing less than 10% of pool assets.

LNR Partners, LLC is the specialservicer of the mortgage loans serviced under the Pooling and ServicingAgreement, the SoCal Retail Portfolio Mortgage Loan, the Embassy Suites atCentennial Olympic Park Mortgage Loan and the Inland Life Storage PortfolioMortgage Loan. As a result, LNR Partners, LLC is a “servicer” as defined inItem 1108(a)(2)(iii) of Regulation AB, in the capacities described above,because it is servicing mortgage loans that constituted 10% or more of theassets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria, accountants’ attestation reportsand servicer compliance statements delivered by LNR Partners, LLC in thecapacities described above are listed in the Exhibit Index.

Pentalpha Surveillance LLC is theoperating advisor of the mortgage loans serviced under the Pooling andServicing Agreement, the SoCal Retail Portfolio Mortgage Loan, the EmbassySuites at Centennial Olympic Park Mortgage Loan, the El Con Center MortgageLoan, the Shetland Park Mortgage Loan and the Smoke Tree Village and Smoke TreeCommons 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.

KeyBank National Association isthe primary servicer of the Moffett Towers II - Buildings 3 & 4 MortgageLoan and the Inland Life Storage Portfolio Mortgage Loan.  These mortgageloans constitute more than 5%, but less than 10%, of the pool assets of theissuing entity.  Therefore, the Depositor included in this Annual Reporton Form 10-K an assessment of compliance with applicable servicing criteria forKeyBank National Association and an accountants’ attestation report pursuant toItem 1122 of Regulation AB because KeyBank National Association is servicingmore than 5% of the pool assets.  However, the Depositor is not requiredto include in this Annual Report on Form 10-K a servicer compliance statementpursuant to Item 1123 of Regulation AB of KeyBank National Association becauseKeyBank National Association is an unaffiliated servicer servicing less than10% of pool assets.

Park Bridge Lender Services LLC isthe operating advisor of the Inland Life Storage Portfolio Mortgage Loan andthe 188 Spear Street Mortgage Loan.  As a result, Park Bridge LenderServices LLC is a servicing function participant in the capacities describedabove, because it is servicing mortgage loans that constituted 5% or more ofthe assets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria and accountants’ attestationreports delivered by Park Bridge Lender Services LLC in the capacitiesdescribed above are listed in the Exhibit Index.

Wilmington Trust, NationalAssociation acts as trustee of the mortgage loans serviced under the Poolingand Servicing Agreement, the 188 Spear Street Mortgage Loan, the El Con CenterMortgage Loan, the Shetland Park Mortgage Loan and the Smoke Tree Village andSmoke Tree Commons Mortgage Loan.  Pursuant to the Pooling and ServicingAgreement, the pooling and servicing agreement for the WFCM 2019-C51Transaction, the pooling and servicing agreement for the BBCMS 2019-C4Transaction 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 the assessmentof compliance with applicable servicing criteria and accountant’s attestationreport for the subject transaction.  As a result, this Annual Report onForm 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 188 Spear StreetMortgage Loan, the El Con Center Mortgage Loan, the Shetland Park Mortgage Loanand the Smoke Tree Village and Smoke Tree Commons Mortgage Loan have deliveredone or more assessments of compliance with respect to Item 1122(d)(2)(iii) ofRegulation AB.

Wells Fargo Bank, NationalAssociation acts as trustee of the Moffett Towers II - Buildings 3 & 4Mortgage Loan, the SoCal Retail Portfolio Mortgage Loan and the Embassy Suitesat Centennial Olympic Park Mortgage Loan.  Pursuant to the trust andservicing agreement for the MFTII 2019-B3B4 Transaction and the pooling andservicing agreement for the MSC 2019-H7 Transaction, the trustee is required toprovide an assessment of compliance with applicable servicing criteria solelywith respect to Item 1122(d)(2)(iii) of Regulation AB (regarding advances offunds or guarantees regarding collections, cash flows or distributions, and anyinterest or other fees charged for such advances, are made, reviewed andapproved as specified in the transaction agreements). However, during thereporting period, the trustee did not perform any servicing function withrespect to the servicing criteria specified in Item 1122(d)(2)(iii) ofRegulation AB.  The master servicer or the special servicer, to the extentrequired, performed the servicing function identified with respect to Item1122(d)(2)(iii) of Regulation AB, and each such party included Item 1122(d)(2)(iii)of Regulation AB in the assessment of compliance with applicable servicingcriteria and accountant’s attestation report for the Subject Transaction. As a result, this Annual Report on Form 10-K does not include an assessment ofcompliance with applicable servicing criteria of the trustee. One or more otherservicers of the Moffett Towers II - Buildings 3 & 4 Mortgage Loan, theSoCal Retail Portfolio Mortgage Loan and the Embassy Suites at CentennialOlympic Park Mortgage Loan have delivered one or more assessments of compliancewith respect to Item 1122(d)(2)(iii) of Regulation AB.

This Annual Report on Form 10-Kincludes assessments of compliance with applicable servicing criteria andaccountants’ attestation reports from CoreLogic Commercial Real EstateServices, Inc. and National Tax Search, LLC.  These entities were engagedby the master servicer under the Pooling and Servicing Agreement and theprimary servicer of the 188 Spear Street Mortgage Loan, the El Con CenterMortgage Loan, the Shetland Park Mortgage Loan and the Smoke Tree Village andSmoke Tree Commons Mortgage Loan to remit tax payments received from the escrowaccounts of borrowers to local taxing authorities, to report tax amounts due,to verify tax parcel information, and to verify non-escrow tax payments. Theseservicing functions are included within the servicing criteria set forth inItems 1122(d)(4)(xi) and 1122(d)(4)(xii) of Regulation AB.  Therefore,under the principles-based definition of “servicer” set forth in Item 1101(j)of Regulation AB that looks to the functions that an entity performs, thesevendors are “servicers” for the purposes of Item 1122 of Regulation AB.  *See*Compliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

Theassessments of compliance with applicable servicing criteria, accountants’attestation reports and servicer compliance statements of the certificateadministrator of the Moffett Towers II - Buildings 3 & 4 Mortgage Loan, theSoCal Retail Portfolio Mortgage Loan, the Embassy Suites at Centennial OlympicPark Mortgage Loan, the Inland Life Storage Portfolio Mortgage Loan, the 188Spear Street Mortgage Loan, the El Con Center Mortgage Loan, the Shetland ParkMortgage Loan and the Smoke Tree Village and Smoke Tree Commons Mortgage Loan listedon the Exhibit Index are omitted from this Annual Report on Form 10-K as thecertificate administrator pursuant to the related pooling and servicingagreement or trust and servicing agreement does not perform any activities thataddress servicing criteria with respect to the issuing entity and because theyare each not a “servicer” that meets the criteria in Item 1108(a)(2)(i) through(iii) of Regulation AB.

With respect to the *pari passu*loan combination that includes the Moffett Towers II - Buildings 3 & 4Mortgage Loan, the SoCal Retail Portfolio Mortgage Loan, the Embassy Suites atCentennial Olympic Park Mortgage Loan, the Shetland Park Mortgage Loan, theInland Life Storage Portfolio Mortgage Loan, the 188 Spear Street MortgageLoan, the El Con Center Mortgage Loan and the Smoke Tree Village and Smoke TreeCommons Mortgage Loan, (i) the reports on assessment of compliance withservicing criteria and attestation reports on assessment of compliance withservicing criteria of C-III Asset Management LLC as special servicer of the ElCon Center Mortgage Loan and the Shetland Park Mortgage Loan, Rialto CapitalAdvisors, LLC as special servicer of the 188 Spear Street Mortgage Loan and theSmoke Tree Village and Smoke Tree Commons Mortgage Loan and Citibank, N.A. astrustee and custodian of 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 to be included on this Annual Report on Form 10-K perInstruction 3 to Item 1122 of Regulation AB because they are parties performingactivities that address servicing criteria relating to 5% or less of the assetsof the issuing entity; and (ii) the servicer compliance statements of KeyBankNational Association as the primary servicer of the Moffett Towers II -Buildings 3 & 4 Mortgage Loan and the Inland Life Storage PortfolioMortgage Loan, Situs Holdings, LLC as special servicer of the Moffett Towers II- Buildings 3 & 4 Mortgage Loan, C-III Asset Management LLC as specialservicer of the El Con Center Mortgage Loan and the Shetland Park MortgageLoan, Midland Loan Services, a Division of PNC Bank, National Association asprimary servicer of the SoCal Retail Portfolio Mortgage Loan and the EmbassySuites at Centennial Olympic Park Mortgage Loan and Rialto Capital Advisors,LLC as special servicer of the 188 Spear Street Mortgage Loan and the SmokeTree Village and Smoke Tree Commons Mortgage Loan, listed on the Exhibit Indexare omitted from this Annual Report on Form 10-K as they are not required byItem 1123 of Regulation AB to be included on this Annual Report on Form 10-Kbecause they are each an unaffiliated party that is not a “servicer” that meetsthe criteria in Item 1108(a)(2)(i) through (iii) of Regulation AB.

 

**PART I**

**Item 1.  Business.**

Omitted.

**Item 1A.  Risk Factors.**

Omitted.

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

None.

**Item 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 nomaterial pending legal proceeding involving the trust or any party related tothe trust, other than routine litigation incidental to the duties of thoserespective parties, and the following, with respect to Citibank N.A., astrustee and as custodian, and Wells Fargo Bank, National Association, ascertificate administrator, as custodian and as trustee.

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 dismissedall claims 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 on Citibank’smotion to dismiss, Plaintiffs filed an amended complaint on August 5,2016.  On June 27, 2017, the state court issued a decision, dismissing theEvent 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, FirstDepartment, dismissed the claims related to robo-signing and the impliedcovenant of good faith, but allowed plaintiffs’ claim alleging discovery ofbreaches of representations and warranties to proceed.  On June 7, 2019,plaintiffs filed a motion for discontinuance of the action and dismissal ofplaintiffs’ 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 forreconsideration regarding his dismissal of the action.  He deniedreconsideration of his decision on standing, but granted leave to amend thecomplaint by October 9, 2017.  The FDIC subsequently requested anextension of time to file its amended complaint, which was granted. The FDICfiled its amended complaint on December 8, 2017. Defendants’ jointly filed amotion to dismiss the amended complaint and that joint motion was fully briefedas of May 3, 2018.  On March 20, 2019, the Court granted Defendants’ jointmotion to dismiss the amended complaint. The FDIC's deadline to file a noticeof 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.

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 enforce repurchaseobligations of mortgage loan sellers for purported breaches of representationsand warranties, (ii) notify investors of alleged events of default, and (iii)abide by appropriate standards of care following alleged events of default.Relief sought included money damages in an unspecified amount, reimbursement ofexpenses, and equitable relief. In November 2018, Wells Fargo Bank reached anagreement, in which it denied any wrongdoing, to resolve such claims on aclasswide basis for the 271 RMBS trusts at issue.  On May 6, 2019, thecourt entered an order approving the settlement agreement.  Separatelawsuits against Wells Fargo Bank making similar allegations filed by certainother institutional investors concerning several RMBS trusts in New York federaland state court are not covered by the agreement.  With respect to suchlitigations, Wells Fargo Bank believes plaintiffs' claims are without merit andintends to contest the claims vigorously, but there can be no assurances as tothe outcome of the litigations or the possible impact of the litigations onWells Fargo Bank or the RMBS trusts.

**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 20, 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 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 4.2 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 El Con Center Mortgage Loan andthe Shetland Park Mortgage Loan, which are being serviced and administeredpursuant to the pooling and servicing agreement for the WFCM 2019-C51Transaction, 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-C51 Transaction incorporated by reference as Exhibit 4.3 to thisAnnual Report on Form 10-K is a chart identifying the entities participating ina servicing function 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 SoCal Retail Portfolio MortgageLoan and the Embassy Suites at Centennial Olympic Park Mortgage Loan, which arebeing serviced and administered pursuant to the pooling and servicing agreementfor the MSC 2019-H7 Transaction, are attached hereto under Item 15 to thisAnnual Report on Form 10-K. Attached as Exhibit AA to the pooling and servicingagreement for the MSC 2019-H7 Transaction incorporated by reference as Exhibit4.4 to this Annual Report on Form 10-K is a chart identifying the entitiesparticipating in a servicing function for the MSC 2019-H7 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 188 Spear Street Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the BBCMS 2019-C4 Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit AA to the pooling andservicing agreement for the BBCMS 2019-C4 Transaction incorporated by referenceas Exhibit 4.5 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the BBCMS 2019-C4Transaction 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 Smoke Tree Village and Smoke TreeCommons Mortgage Loan, which is being serviced and administered pursuant to thepooling and servicing agreement for the UBS 2019-C17 Transaction, are attachedhereto under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit Zto the pooling and servicing agreement for the UBS 2019-C17 Transactionincorporated by reference as Exhibit 4.6 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theUBS 2019-C17 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 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 4.7 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, by and 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 Asset Representations Reviewer (filed as Exhibit 4.1 tothe registrant’s Current Report on Form 8-K filed on August 20, 2019 underCommission File No. 333-226486-08 and incorporated by reference herein). 

4.2          Trustand Servicing Agreement, dated as of July 11, 2019, by and among BarclaysCommercial Mortgage Securities LLC, as Depositor, KeyBank National Association,as Servicer, Situs Holdings, LLC, as Special Servicer, Wells Fargo Bank,National Association, as Certificate Administrator and Custodian, Wells FargoBank, National Association, as Trustee (filed as Exhibit 99.7 to theregistrant’s Current Report on Form 8-K filed on August 20, 2019 underCommission File No. 333-226486-08 and incorporated by reference herein).

4.3          Poolingand Servicing Agreement, dated as of July 1, 2019, by and among Wells FargoCommercial Mortgage 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 Administratorand Custodian, Wilmington Trust, National Association, as Trustee, andPentalpha Surveillance LLC, as Operating Advisor and Asset RepresentationsReviewer (filed as Exhibit 99.9 to the registrant’s Current Report on Form 8-Kfiled on August 20, 2019 under Commission File No. 333-226486-08 andincorporated by reference herein).

4.4          Poolingand Servicing Agreement, dated as of July 1, 2019, by and among Morgan StanleyCapital I Inc., as Depositor, Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer, LNR Partners, LLC, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administratorand Trustee, and Pentalpha Surveillance LLC, as Operating Advisor and AssetRepresentations Reviewer (filed as Exhibit 99.8 to the registrant’s CurrentReport on Form 8-K filed on August 20, 2019 under Commission File No.333-226486-08 and incorporated by reference herein).

4.5          Poolingand Servicing Agreement, dated as of August 1, 2019, by and among BarclaysCommercial Mortgage Securities LLC, as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, Rialto Capital Advisors, LLC, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administratorand Custodian, Wilmington Trust, National Association, as Trustee, and ParkBridge Lender Services LLC, as Operating Advisor and Asset RepresentationsReviewer (filed as Exhibit 99.1 to the registrant’s Current Report on Form 8-Kfiled on September 3, 2019 under Commission File No. 333-226486-08 and incorporatedby reference herein).

4.6          Poolingand Servicing Agreement, dated as of October 1, 2019, by and among UBSCommercial Mortgage Securitization Corp., as Depositor, Wells Fargo Bank,National Association, as Master Servicer, Rialto Capital Advisors, LLC, asSpecial Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator, Wilmington Trust, National Association, as Trustee, andPentalpha Surveillance LLC, as Operating Advisor and Asset RepresentationsReviewer (filed as Exhibit 99.1 to the registrant’s Current Report on Form 8-Kfiled on October 21, 2019 under Commission File No. 333-226486-08 andincorporated by reference herein).

4.7          Poolingand Servicing Agreement, dated as of October 1, 2019, by and among CCRECommercial Mortgage Securities, L.P., as Depositor, KeyBank NationalAssociation, as Master Servicer and as a Special Servicer solely with respectto The Stanwix Whole Loan, LNR Partners, LLC, as a Special Servicer, Citibank,N.A., as Trustee, Citibank, N.A., as Certificate Administrator, Paying Agent andCustodian, Park Bridge Lender Services LLC, as Operating Advisor, and ParkBridge Lender LLC, as Asset Representations Reviewer (filed as Exhibit 99.1 tothe registrant’s Current Report on Form 8-K filed on October 23, 2019 underCommission File No. 333-226486-08 and incorporated by reference herein).

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

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

33.1        Wells Fargo Bank, NationalAssociation, as Master Servicer

33.2        LNR Partners, LLC, asSpecial 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        Pentalpha SurveillanceLLC, 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        Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Renaissance Center VI Mortgage Loan(see Exhibit 33.1)

33.10      LNR Partners, LLC, asSpecial Servicer of the Renaissance Center VI Mortgage Loan (see Exhibit 33.2)

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

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

33.13      Pentalpha SurveillanceLLC, as Operating Advisor of the Renaissance Center VI Mortgage Loan (seeExhibit 33.6)

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

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

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

33.17      LNR Partners, LLC, asSpecial Servicer of the Mount Kemble Mortgage Loan (see Exhibit 33.2)

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

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

33.20      Pentalpha SurveillanceLLC, as Operating Advisor of the Mount Kemble Mortgage Loan (see Exhibit 33.6)

33.21      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Mount KembleMortgage Loan (see Exhibit 33.7)

33.22      National Tax Search, LLC,as Servicing Function Participant of the Mount Kemble Mortgage Loan (seeExhibit 33.8)

33.23      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Del Mar Terrace Apartments MortgageLoan (see Exhibit 33.1)

33.24      LNR Partners, LLC, asSpecial Servicer of the Del Mar Terrace Apartments Mortgage Loan (see Exhibit33.2)

33.25      Wilmington Trust, National Association, as Trustee of the Del Mar TerraceApartments Mortgage Loan (Omitted. See Explanatory Notes.)

33.26      Wells Fargo Bank, NationalAssociation, as Custodian of the Del Mar Terrace Apartments Mortgage Loan (seeExhibit 33.5)

33.27      Pentalpha SurveillanceLLC, as Operating Advisor of the Del Mar Terrace Apartments Mortgage Loan (seeExhibit 33.6)

33.28      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Del Mar TerraceApartments Mortgage Loan (see Exhibit 33.7)

33.29      National Tax Search, LLC,as Servicing Function Participant of the Del Mar Terrace Apartments MortgageLoan (see Exhibit 33.8)

33.30      KeyBank NationalAssociation, as Primary Servicer of the Moffett Towers II – Buildings 3 & 4Mortgage Loan

33.31      Situs Holdings, LLC, asSpecial Servicer of the Moffett Towers II – Buildings 3 & 4 Mortgage Loan

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

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

33.34      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the El Con Center Mortgage Loan (seeExhibit 33.1)

33.35      C-III Asset Management LLC, as Special Servicer of the El Con Center MortgageLoan (Omitted. See Explanatory Notes.)

33.36      Wilmington Trust, National Association, as Trustee of the El Con CenterMortgage Loan (Omitted. See Explanatory Notes.)

33.37      Wells Fargo Bank, NationalAssociation, as Custodian of the El Con Center Mortgage Loan (see Exhibit 33.5)

33.38      Pentalpha SurveillanceLLC, as Operating Advisor of the El Con Center Mortgage Loan (see Exhibit 33.6)

33.39      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the El Con CenterMortgage Loan (see Exhibit 33.7)

33.40      National Tax Search, LLC,as Servicing Function Participant of the El Con Center Mortgage Loan (seeExhibit 33.8)

33.41      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Shetland Park Mortgage Loan (seeExhibit 33.1)

33.42      C-III Asset Management LLC, as Special Servicer of the Shetland Park MortgageLoan (Omitted. See Explanatory Notes.)

33.43      Wilmington Trust, National Association, as Trustee of the Shetland ParkMortgage Loan (Omitted. See Explanatory Notes.)

33.44      Wells Fargo Bank, NationalAssociation, as Custodian of the Shetland Park Mortgage Loan (see Exhibit 33.5)

33.45      Pentalpha SurveillanceLLC, as Operating Advisor of the Shetland Park Mortgage Loan (see Exhibit 33.6)

33.46      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Shetland ParkMortgage Loan (see Exhibit 33.7)

33.47      National Tax Search, LLC,as Servicing Function Participant of the Shetland Park Mortgage Loan (seeExhibit 33.8)

33.48      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the SoCalRetail Portfolio Mortgage Loan

33.49      LNR Partners, LLC, asSpecial Servicer of the SoCal Retail Portfolio Mortgage Loan (see Exhibit 33.2)

33.50      Wells Fargo Bank, National Association, as Trustee of the SoCal RetailPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.51      Wells Fargo Bank, NationalAssociation, as Custodian of the SoCal Retail Portfolio Mortgage Loan (seeExhibit 33.5)

33.52      Pentalpha SurveillanceLLC, as Operating Advisor of the SoCal Retail Portfolio Mortgage Loan (seeExhibit 33.6)

33.53      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the EmbassySuites at Centennial Olympic Park Mortgage Loan (see Exhibit 33.48)

33.54      LNR Partners, LLC, asSpecial Servicer of the Embassy Suites at Centennial Olympic Park Mortgage Loan(see Exhibit 33.2)

33.55      Wells Fargo Bank, National Association, as Trustee of the Embassy Suites atCentennial Olympic Park Mortgage Loan (Omitted. See Explanatory Notes.)

33.56      Wells Fargo Bank, NationalAssociation, as Custodian of the Embassy Suites at Centennial Olympic ParkMortgage Loan (see Exhibit 33.5)

33.57      Pentalpha SurveillanceLLC, as Operating Advisor of the Embassy Suites at Centennial Olympic ParkMortgage Loan (see Exhibit 33.6)

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

33.59      Rialto Capital Advisors, LLC, as Special Servicer of the 188 Spear StreetMortgage Loan (Omitted. See Explanatory Notes.)

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

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

33.62      Park Bridge Lender ServicesLLC, as Operating Advisor of the 188 Spear Street Mortgage Loan

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

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

33.65      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Smoke Tree Village and Smoke TreeCommons Mortgage Loan (see Exhibit 33.1)

33.66      Rialto Capital Advisors, LLC, as Special Servicer of the Smoke Tree Village andSmoke Tree Commons Mortgage Loan (Omitted. See Explanatory Notes.)

33.67      Wilmington Trust, National Association, as Trustee of the Smoke Tree Villageand Smoke Tree Commons Mortgage Loan (Omitted. See Explanatory Notes.)

33.68      Wells Fargo Bank, NationalAssociation, as Custodian of the Smoke Tree Village and Smoke Tree CommonsMortgage Loan (see Exhibit 33.5)

33.69      Pentalpha SurveillanceLLC, as Operating Advisor of the Smoke Tree Village and Smoke Tree CommonsMortgage Loan (see Exhibit 33.6)

33.70      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Smoke TreeVillage and Smoke Tree Commons Mortgage Loan (see Exhibit 33.7)

33.71      National Tax Search, LLC,as Servicing Function Participant of the Smoke Tree Village and Smoke TreeCommons Mortgage Loan (see Exhibit 33.8)

33.72      KeyBank NationalAssociation, as Primary Servicer of the Inland Life Storage Portfolio MortgageLoan (see Exhibit 33.30)

33.73      LNR Partners, LLC, asSpecial Servicer of the Inland Life Storage Portfolio Mortgage Loan (seeExhibit 33.2)

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

33.75      Park Bridge LenderServices LLC, as Operating Advisor of the Inland Life Storage PortfolioMortgage Loan (see Exhibit 33.62)

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

34.1        Wells Fargo Bank, NationalAssociation, as Master Servicer

34.2        LNR Partners, LLC, asSpecial 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        Pentalpha SurveillanceLLC, 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        Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Renaissance Center VI Mortgage Loan(see Exhibit 34.1)

34.10      LNR Partners, LLC, asSpecial Servicer of the Renaissance Center VI Mortgage Loan (see Exhibit 34.2)

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

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

34.13      Pentalpha SurveillanceLLC, as Operating Advisor of the Renaissance Center VI Mortgage Loan (seeExhibit 34.6)

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

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

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

34.17      LNR Partners, LLC, asSpecial Servicer of the Mount Kemble Mortgage Loan (see Exhibit 34.2)

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

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

34.20      Pentalpha SurveillanceLLC, as Operating Advisor of the Mount Kemble Mortgage Loan (see Exhibit 34.6)

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

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

34.23      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Del Mar Terrace Apartments MortgageLoan (see Exhibit 34.1)

34.24      LNR Partners, LLC, asSpecial Servicer of the Del Mar Terrace Apartments Mortgage Loan (see Exhibit34.2)

34.25      Wilmington Trust, National Association, as Trustee of the Del Mar TerraceApartments Mortgage Loan (Omitted. See Explanatory Notes.)

34.26      Wells Fargo Bank, NationalAssociation, as Custodian of the Del Mar Terrace Apartments Mortgage Loan (seeExhibit 34.5)

34.27      Pentalpha SurveillanceLLC, as Operating Advisor of the Del Mar Terrace Apartments Mortgage Loan (seeExhibit 34.6)

34.28      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Del Mar TerraceApartments Mortgage Loan (see Exhibit 34.7)

34.29      National Tax Search, LLC,as Servicing Function Participant of the Del Mar Terrace Apartments MortgageLoan (see Exhibit 34.8)

34.30      KeyBank NationalAssociation, as Primary Servicer of the Moffett Towers II – Buildings 3 & 4Mortgage Loan

34.31      Situs Holdings, LLC, asSpecial Servicer of the Moffett Towers II – Buildings 3 & 4 Mortgage Loan

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

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

34.34      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the El Con Center Mortgage Loan (seeExhibit 34.1)

34.35      C-III Asset Management LLC, as Special Servicer of the El Con Center MortgageLoan (Omitted. See Explanatory Notes.)

34.36      Wilmington Trust, National Association, as Trustee of the El Con CenterMortgage Loan (Omitted. See Explanatory Notes.)

34.37      Wells Fargo Bank, NationalAssociation, as Custodian of the El Con Center Mortgage Loan (see Exhibit 34.5)

34.38      Pentalpha SurveillanceLLC, as Operating Advisor of the El Con Center Mortgage Loan (see Exhibit 34.6)

34.39      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the El Con CenterMortgage Loan (see Exhibit 34.7)

34.40      National Tax Search, LLC,as Servicing Function Participant of the El Con Center Mortgage Loan (seeExhibit 34.8)

34.41      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Shetland Park Mortgage Loan (seeExhibit 34.1)

34.42      C-III Asset Management LLC, as Special Servicer of the Shetland Park MortgageLoan (Omitted. See Explanatory Notes.)

34.43      Wilmington Trust, National Association, as Trustee of the Shetland ParkMortgage Loan (Omitted. See Explanatory Notes.)

34.44      Wells Fargo Bank, NationalAssociation, as Custodian of the Shetland Park Mortgage Loan (see Exhibit 34.5)

34.45      Pentalpha SurveillanceLLC, as Operating Advisor of the Shetland Park Mortgage Loan (see Exhibit 34.6)

34.46      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Shetland ParkMortgage Loan (see Exhibit 34.7)

34.47      National Tax Search, LLC,as Servicing Function Participant of the Shetland Park Mortgage Loan (see Exhibit34.8)

34.48      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the SoCalRetail Portfolio Mortgage Loan

34.49      LNR Partners, LLC, asSpecial Servicer of the SoCal Retail Portfolio Mortgage Loan (see Exhibit 34.2)

34.50      Wells Fargo Bank, National Association, as Trustee of the SoCal RetailPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.51      Wells Fargo Bank, NationalAssociation, as Custodian of the SoCal Retail Portfolio Mortgage Loan (seeExhibit 34.5)

34.52      Pentalpha SurveillanceLLC, as Operating Advisor of the SoCal Retail Portfolio Mortgage Loan (seeExhibit 34.6)

34.53      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the EmbassySuites at Centennial Olympic Park Mortgage Loan (see Exhibit 34.48)

34.54      LNR Partners, LLC, asSpecial Servicer of the Embassy Suites at Centennial Olympic Park Mortgage Loan(see Exhibit 34.2)

34.55      Wells Fargo Bank, National Association, as Trustee of the Embassy Suites at CentennialOlympic Park Mortgage Loan (Omitted. See Explanatory Notes.)

34.56      Wells Fargo Bank, NationalAssociation, as Custodian of the Embassy Suites at Centennial Olympic ParkMortgage Loan (see Exhibit 34.5)

34.57      Pentalpha SurveillanceLLC, as Operating Advisor of the Embassy Suites at Centennial Olympic ParkMortgage Loan (see Exhibit 34.6)

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

34.59      Rialto Capital Advisors, LLC, as Special Servicer of the 188 Spear StreetMortgage Loan (Omitted. See Explanatory Notes.)

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

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

34.62      Park Bridge LenderServices LLC, as Operating Advisor of the 188 Spear Street Mortgage Loan

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

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

34.65      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Smoke Tree Village and Smoke TreeCommons Mortgage Loan (see Exhibit 34.1)

34.66      Rialto Capital Advisors, LLC, as Special Servicer of the Smoke Tree Village andSmoke Tree Commons Mortgage Loan (Omitted. See Explanatory Notes.)

34.67      Wilmington Trust, National Association, as Trustee of the Smoke Tree Villageand Smoke Tree Commons Mortgage Loan (Omitted. See Explanatory Notes.)

34.68      Wells Fargo Bank, NationalAssociation, as Custodian of the Smoke Tree Village and Smoke Tree CommonsMortgage Loan (see Exhibit 34.5)

34.69      Pentalpha Surveillance LLC,as Operating Advisor of the Smoke Tree Village and Smoke Tree Commons MortgageLoan (see Exhibit 34.6)

34.70      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Smoke Tree Villageand Smoke Tree Commons Mortgage Loan (see Exhibit 34.7)

34.71      National Tax Search, LLC,as Servicing Function Participant of the Smoke Tree Village and Smoke TreeCommons Mortgage Loan (see Exhibit 34.8)

34.72      KeyBank NationalAssociation, as Primary Servicer of the Inland Life Storage Portfolio MortgageLoan (see Exhibit 34.30)

34.73      LNR Partners, LLC, asSpecial Servicer of the Inland Life Storage Portfolio Mortgage Loan (seeExhibit 34.2)

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

34.75      Park Bridge LenderServices LLC, as Operating Advisor of the Inland Life Storage PortfolioMortgage Loan (see Exhibit 34.62)

35           Servicer compliance statements.

35.1        Wells Fargo Bank, NationalAssociation, as Master Servicer

35.2        LNR Partners, LLC, asSpecial Servicer

35.3        Wells Fargo Bank, NationalAssociation, as Certificate Administrator

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

35.5        LNR Partners, LLC, asSpecial Servicer of the Renaissance Center VI Mortgage Loan (see Exhibit 35.2)

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

35.7        LNR Partners, LLC, asSpecial Servicer of the Mount Kemble Mortgage Loan (see Exhibit 35.2)

35.8        Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Del Mar Terrace Apartments MortgageLoan (see Exhibit 35.1)

35.9        LNR Partners, LLC, asSpecial Servicer of the Del Mar Terrace Apartments Mortgage Loan (see Exhibit35.2)

35.10      KeyBank National Association, as Primary Servicer of the Moffett Towers II –Buildings 3 & 4 Mortgage Loan (Omitted. See Explanatory Notes.)

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

35.12      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the El Con Center Mortgage Loan (seeExhibit 35.1)

35.13      C-III Asset Management LLC, as Special Servicer of the El Con Center MortgageLoan (Omitted. See Explanatory Notes.)

35.14      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Shetland Park Mortgage Loan (seeExhibit 35.1)

35.15      C-III Asset Management LLC, as Special Servicer of the Shetland Park MortgageLoan (Omitted. See Explanatory Notes.)

35.16      Midland Loan Services, a Division of PNC Bank, National Association, as PrimaryServicer of the SoCal Retail Portfolio Mortgage Loan (Omitted. See ExplanatoryNotes.)

35.17      LNR Partners, LLC, asSpecial Servicer of the SoCal Retail Portfolio Mortgage Loan (see Exhibit 35.2)

35.18      Midland Loan Services, a Division of PNC Bank, National Association, as PrimaryServicer of the Embassy Suites at Centennial Olympic Park Mortgage Loan(Omitted. See Explanatory Notes.)

35.19      LNR Partners, LLC, asSpecial Servicer of the Embassy Suites at Centennial Olympic Park Mortgage Loan(see Exhibit 35.2)

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

35.21      Rialto Capital Advisors, LLC, as Special Servicer of the 188 Spear StreetMortgage Loan (Omitted. See Explanatory Notes.)

35.22      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Smoke Tree Village and Smoke TreeCommons Mortgage Loan (see Exhibit 35.1)

35.23      Rialto Capital Advisors, LLC, as Special Servicer of the Smoke Tree Village andSmoke Tree Commons Mortgage Loan (Omitted. See Explanatory Notes.)

35.24      KeyBank National Association, as Primary Servicer of the Inland Life StoragePortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

35.25      LNR Partners, LLC, asSpecial Servicer of the Inland Life Storage Portfolio Mortgage Loan (seeExhibit 35.2)

99.1        MortgageLoan Purchase Agreement, dated as of August 5, 2019, between Wells FargoCommercial Mortgage Securities, Inc. and Wells Fargo Bank, National Association(filed as Exhibit 99.6 to the registrant’s Current Report on Form 8-K filed onAugust 20, 2019 under Commission File No. 333-226486-08 and incorporated byreference herein)

99.2        MortgageLoan Purchase Agreement, dated as of August 5, 2019, between Wells FargoCommercial Mortgage Securities, Inc. and Argentic Real Estate Finance LLC(filed as Exhibit 99.1 to the registrant’s Current Report on Form 8-K filed onAugust 20, 2019 under Commission File No. 333-226486-08 and incorporated byreference herein)

99.3        MortgageLoan Purchase Agreement, dated as of August 5, 2019, between Wells FargoCommercial Mortgage Securities, Inc. and Rialto Mortgage Finance, LLC (filed asExhibit 99.2 to the registrant’s Current Report on Form 8-K filed on August 20,2019 under Commission File No. 333-226486-08 and incorporated by referenceherein)

99.4        MortgageLoan Purchase Agreement, dated as of August 5, 2019, between Wells FargoCommercial Mortgage Securities, Inc., Barclays Capital Real Estate Inc. andBarclays Capital Holdings Inc. (filed as Exhibit 99.3 to the registrant’sCurrent Report on Form 8-K filed on August 20, 2019 under Commission File No.333-226486-08 and incorporated by reference herein)

99.5        MortgageLoan Purchase Agreement, dated as of August 5, 2019, among Wells FargoCommercial Mortgage Securities, Inc., Ladder Capital Finance LLC, LadderCapital Finance Holdings LLLP, Series REIT of Ladder Capital Finance HoldingsLLLP, Series TRS of Ladder Capital Finance Holdings LLLP (filed as Exhibit 99.4to the registrant’s Current Report on Form 8-K filed on August 20, 2019 underCommission File No. 333-226486-08 and incorporated by reference herein)

99.6        MortgageLoan Purchase Agreement, dated as of August 5, 2019, between Wells FargoCommercial Mortgage Securities, Inc., BSPRT CMBS Finance, LLC and BenefitStreet Partners Realty Trust, Inc. (filed as Exhibit 99.5 to the registrant’sCurrent Report on Form 8-K filed on August 20, 2019 under Commission File No.333-226486-08 and incorporated by reference herein)

99.10      Co-LenderAgreement, dated as of July 11, 2019, by and among Barclays Bank PLC, as NoteA-1-A Holder and Note B-1 Holder, Barclays Capital Real Estate Inc., as InitialNote A-1-B Holder, Initial Note A-1-D Holder and Initial Note A-1-E Holder,Bank of America, N.A., as Note A-1-C Holder, Deutsche Bank AG, New York Branch,as Initial Note A-2-A Holder, Initial Note A-2-B Holder, Initial Note A-2-CHolder and Initial Note B-2 Holder, and Goldman Sachs Bank USA, as Initial NoteA-3-A Holder, Initial Note A-3-B Holder, Initial Note A-3-C Holder, and InitialNote B-3 Holder (filed as Exhibit 99.10 to the registrant’s Current Report onForm 8-K filed on August 20, 2019 under Commission File No. 333-226486-08 andincorporated by reference herein)

99.11      AgreementBetween Note Holders, dated as of June 19, 2019, by and between Argentic RealEstate Finance LLC, as Initial Note A-1 Holder, Argentic Real Estate FinanceLLC, as Initial Note A-2 Holder, Argentic Real Estate Finance LLC, as InitialNote A-3 Holder, Argentic Real Estate Finance LLC, as Initial Note A-4 Holder,Argentic Real Estate Finance LLC, as Initial Note A-5 Holder, Argentic RealEstate Finance LLC, as Initial Note A-6 Holder, Argentic Real Estate FinanceLLC, as Initial Note A-7 Holder, and Argentic Real Estate Finance LLC, asInitial Note A-8 Holder (filed as Exhibit 99.11 to the registrant’s CurrentReport on Form 8-K filed on August 20, 2019 under Commission File No.333-226486-08 and incorporated by reference herein)

99.12      Co-LenderAgreement, dated as of July 6, 2019, by and between SPREF WH II LLC, as InitialNote A-1 Holder, SPREF WH II LLC, as Initial Note A-2 Holder, SPREF WH II LLC,as Initial Note A-3 Holder, SPREF WH II LLC, as Initial Note A-4 Holder, SPREFWH II LLC, as Initial Note A-5 Holder, and SPREF WH II LLC, as Initial Note A-6Holder (filed as Exhibit 99.12 to the registrant’s Current Report on Form 8-Kfiled on August 20, 2019 under Commission File No. 333-226486-08 andincorporated by reference herein) 

99.13      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 and InitialNote A-1-C Holder, and Barclays Capital Real Estate Inc., as Initial Note A-2-AHolder and Initial Note A-2-B Holder (filed as Exhibit 99.13 to theregistrant’s Current Report on Form 8-K filed on August 20, 2019 underCommission File No. 333-226486-08 and incorporated by reference herein) 

99.14      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 99.14 to the registrant’s Current Report on Form 8-Kfiled on August 20, 2019 under Commission File No. 333-226486-08 andincorporated by reference herein) 

99.15      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 99.15 to the registrant’s CurrentReport on Form 8-K filed on August 20, 2019 under Commission File No. 333-226486-08and incorporated by reference herein)

99.16      Co-LenderAgreement, dated as of May 1, 2019, between Rialto Mortgage Finance, LLC, asInitial Note A-1 Holder, and Rialto Mortgage Finance, LLC, as Initial Note A-2Holder (filed as Exhibit 99.16 to the registrant’s Current Report on Form 8-Kfiled on August 20, 2019 under Commission File No. 333-226486-08 andincorporated by reference herein)

99.17      Co-LenderAgreement, dated as of July 25, 2019, between BSPRT Finance Sub-Lender II, LLC,as Note A-1 Holder, and BSPRT Finance Sub-Lender II, LLC, as Note A-2 Holder(filed as Exhibit 99.17 to the registrant’s Current Report on Form 8-K filed onAugust 20, 2019 under Commission File No. 333-226486-08 and incorporated byreference herein)

99.18      Co-LenderAgreement, dated as of May 1, 2019, between Rialto Mortgage Finance, LLC, asInitial Note A-1 Holder, and Rialto Mortgage Finance, LLC, as Initial Note A-2Holder (filed as Exhibit 99.18 to the registrant’s Current Report on Form 8-Kfiled on August 20, 2019 under Commission File No. 333-226486-08 and incorporatedby reference herein)

99.19      Amendedand Restated Co-Lender Agreement, dated as of September 6, 2019, between RialtoMortgage Finance, LLC, as Initial Note A-1 Holder, Rialto Mortgage Finance,LLC, as Initial Note A-2 Holder and Wilmington Trust, National Association, asTrustee for the Benefit of the Registered Holders of Wells Fargo CommercialMortgage Trust 2019-C52, Commercial Mortgage Pass Through Certificates, Series2019-C52 (filed as Exhibit 99.19 to the registrant’s Current Report on Form8-K/A filed on October 1, 2019 under Commission File No. 333-226486-08 andincorporated by reference herein)

 99.20     Co-LenderAgreement, dated as of August 20, 2019, by and between BSPRT CMBS Finance, LLC,as Note A-1 Holder, and BSPRT CMBS Finance, LLC, as Note A-2 Holder (filed asExhibit 99.20 to the registrant’s Current Report on Form 8-K filed on August20, 2019 under Commission File No. 333-226486-08 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 tobe signed on its behalf by the undersigned, thereunto duly authorized.

Wells Fargo Commercial MortgageSecurities, Inc.(Depositor)

/s/ AnthonySfarra

AnthonySfarra, President

(senior officer in charge ofsecuritization of the depositor)

Date: March 23, 2020