**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, 2021or**

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

**For the transition period from _____ to _____Commission file number of the issuing entity: 333-228375-01**

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

**BANK 2019-BNK18**

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

** **

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

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

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

** **

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

**Bank of America, NationalAssociation**

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

** **

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

**Wells Fargo Bank, NationalAssociation**

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

** **

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

**Morgan Stanley Mortgage CapitalHoldings LLC**

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

** **

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

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

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

** **

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

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

**38-4117274**

**38-7221292**

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

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

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

**as Certificate Administrator**

**9062 Old Annapolis Road**

**Columbia, MD**

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

**21045**

**(Zip Code)**

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

**(646) 855-3953**

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

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

 

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

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

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

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

Indicate by check mark whether the registrant has submittedelectronically 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 if asmaller reporting company)                          Smaller reportingcompany                    o

                                                                                                                                                       Emerging growthcompany                    o

If an emerging growth company, indicate by check mark if theregistrant has elected not to use the extended transition period for complyingwith any new or revised financial accounting standards provided pursuant toSection 13(a) of the Exchange Act.  o

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

Indicate by check mark whether the registrant is a shellcompany (as defined in Rule 12b-2 of the Act).  o Yes ⌧ No

State the aggregate market value of the voting and non-votingcommon equity held by non-affiliates computed by reference to the price atwhich the common equity was last sold, or the average bid and asked price ofsuch common equity, as of the last business day of the registrant’s mostrecently completed second fiscal quarter.

Not applicable.

Indicate by check mark whether the registrant has filed alldocuments and reports required to be filed by Section 12, 13 or 15(d) of theSecurities Exchange Act of 1934 subsequent to the distribution of securitiesunder a plan confirmed by a court.  oYes oNo

Not applicable.

Indicate the number of shares outstanding of each of theregistrant’s classes of common stock, as of the latest practicable date.

Not applicable.

**DOCUMENTS INCORPORATED BY REFERENCE**

** **

List hereunder the following documents if incorporated byreference and the Part of the Form 10-K (e.g., Part I, Part II, etc.) intowhich the document is incorporated: (1) Any annual report to security holders;(2) Any proxy or information statement; and (3) Any prospectus filed pursuantto Rule 424(b) or (c) under the Securities Act of 1933. The listed documentsshould be clearly described for identification purposes (e.g., annual report tosecurity holders for fiscal year ended December 24, 1980).

Not applicable.

 

** **

**EXPLANATORY NOTES**

The Alhambra Mortgage Loan, the 350 BushStreet Mortgage Loan, the Ford Factory Mortgage Loan, the Newport CorporateCenter Mortgage Loan, the 9201 West Sunset Boulevard Mortgage Loan, the CentralTower Mortgage Loan and the Westin Atlanta Airport Mortgage Loan, whichconstituted approximately 9.6%, 9.6%, 9.2%, 7.1%, 6.8%, 6.1% and 4.4%,respectively, of the asset pool of the issuing entity as of its cut-off date,are each an asset of the issuing entity and are each part of a loan combinationthat includes (a) with respect to The Alhambra Mortgage Loan, two other *paripassu* loans, which are not assets of the issuing entity, (b) with respectto the 350 Bush Street Mortgage Loan, two other *pari passu* loans, whichare not assets of the issuing entity, (c) with respect to the Ford FactoryMortgage Loan, one other *pari passu* loan, which is not an asset of theissuing entity, (d) with respect to the Newport Corporate Center Mortgage Loan,three other *pari passu* loans and ten subordinate companion loans, eachof which are not assets of the issuing entity, (e) with respect to the 9201West Sunset Boulevard Mortgage Loan, one other *pari passu* loan, which isnot an asset of the issuing entity, (f) with respect to the Central TowerMortgage Loan, one other *pari passu* loan, which is not an asset of theissuing entity and (g) with respect to the Westin Atlanta Airport MortgageLoan, one other *pari passu* loan, which is not an asset of the issuingentity. These loan combinations, including The Alhambra Mortgage Loan, the 350 BushStreet Mortgage Loan, the Ford Factory Mortgage Loan, the Newport CorporateCenter Mortgage Loan, the 9201 West Sunset Boulevard Mortgage Loan, the CentralTower Mortgage Loan and the Westin Atlanta Airport Mortgage Loan, are beingserviced and administered pursuant to the Pooling and Servicing Agreement,which is incorporated by reference as Exhibit 4.1 to this Annual Report on Form10-K. 

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the ILPT Hawaii Portfolio Mortgage Loan, whichconstituted approximately 3.9% of the asset pool of the issuing entity as ofits cut-off date.  The ILPT Hawaii Portfolio Mortgage Loan is an asset ofthe issuing entity and is part of a loan combination that includes the ILPTHawaii Portfolio Mortgage Loan and seventeen other *pari passu* loans,which are not assets of the issuing entity. A *pari passu* portion of theloan combination was securitized in the ILPT Trust 2019-SURF transaction (the “ILPT2019-SURF Transaction”). This loan combination, including the ILPT HawaiiPortfolio Mortgage Loan, is being serviced and administered pursuant to thetrust and servicing agreement for the ILPT 2019-SURF Transaction, which isincorporated by reference as Exhibit 4.2 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Great Wolf Lodge Southern CaliforniaMortgage Loan, which constituted approximately 3.9% of the asset pool of theissuing entity as of its cut-off date.  The Great Wolf Lodge SouthernCalifornia Mortgage Loan is an asset of the issuing entity and is part of aloan combination that includes the Great Wolf Lodge Southern CaliforniaMortgage Loan, three other *pari passu* loans and one subordinatecompanion loan, which are not assets of the issuing entity. A *pari passu*portion of the loan combination was securitized in the Wells Fargo CommercialMortgage Trust 2019-C50 transaction, Commission File Number 333-226486-05 (the“WFCM 2019-C50 Transaction”). This loan combination, including the GreatWolf Lodge Southern California Mortgage Loan, is being serviced andadministered pursuant to the pooling and servicing agreement for the WFCM2019-C50 Transaction, which is incorporated by reference as Exhibit 4.3 to thisAnnual Report on Form 10-K.

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

Wells Fargo Bank, NationalAssociation is the master servicer and certificate administrator of themortgage loans serviced under the Pooling and Servicing Agreement and theprimary servicer of the Great Wolf Lodge Southern California Mortgage Loan. Asa result, Wells Fargo Bank, National Association is a “servicer” as defined inItem 1108(a)(2)(iii) of Regulation AB, in the capacities described above,because it is servicing mortgage loans that constituted 10% or more of theassets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria, accountants’ attestation reportsand servicer compliance statements delivered by Wells Fargo Bank, NationalAssociation in the capacities described above are listed in the Exhibit Index.

Wells Fargo Bank, National Association is the custodian ofthe mortgage loans serviced under the Pooling and Servicing Agreement, theGreat Wolf Lodge Southern California Mortgage Loan and the ILPT HawaiiPortfolio Mortgage Loan.  As a result, Wells Fargo Bank, NationalAssociation is a servicing function participant in the capacities describedabove, because it is servicing mortgage loans that constituted 5% or more ofthe assets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria and accountants’ attestationreports delivered by Wells Fargo Bank, National Association in the capacitiesdescribed above are listed in the Exhibit Index.

RialtoCapital Advisors, LLC is the special servicer of the mortgage loans servicedunder the Pooling and Servicing Agreement and the ILPT Hawaii PortfolioMortgage Loan. As a result, Rialto Capital Advisors, LLC is a “servicer” asdefined in Item 1108(a)(2)(iii) of Regulation AB, in the capacities describedabove, because it is servicing mortgage loans that constituted 10% or more ofthe assets 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 Rialto Capital Advisors, LLC inthe capacities described above are listed in the Exhibit Index.

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

Park Bridge Lender Services LLC is the operating advisor ofthe Great Wolf Lodge Southern California Mortgage Loan and the ILPT HawaiiPortfolio Mortgage Loan.  As a result, Park Bridge Lender Services LLC isa servicing function participant in the capacities described above, because itis servicing 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 byPark Bridge Lender Services LLC in the capacities described above are listed inthe Exhibit Index.

Wells Fargo Bank, NationalAssociation acts as trustee of the ILPT Hawaii Portfolio Mortgage Loan. Pursuant to the trust and servicing agreement for the ILPT 2019-SURFTransaction, the trustee is required to provide an assessment of compliancewith applicable servicing criteria solely with respect to Item 1122(d)(2)(iii)of Regulation AB (regarding advances of funds or guarantees regardingcollections, cash flows or distributions, and any interest or other feescharged for such advances, are made, reviewed and approved as specified in thetransaction agreements). However, during the reporting period, the trustee didnot perform any servicing function with respect to the servicing criteriaspecified in Item 1122(d)(2)(iii) of Regulation AB.  The master serviceror the special servicer, to the extent required, performed the servicingfunction identified with respect to Item 1122(d)(2)(iii) of Regulation AB, andeach such party included Item 1122(d)(2)(iii) of Regulation AB in theassessment of compliance with applicable servicing criteria and accountant’sattestation report for the subject transaction.  As a result, this AnnualReport on Form 10-K does not include an assessment of compliance withapplicable servicing criteria of the trustee. One or more other servicers ofthe ILPT Hawaii Portfolio Mortgage Loan have delivered one or more assessmentsof compliance with respect to Item 1122(d)(2)(iii) of Regulation AB.

Wilmington Trust, NationalAssociation acts as trustee of  the mortgage loans serviced under thePooling and Servicing Agreement and the Great Wolf Lodge Southern CaliforniaMortgage Loan.  Pursuant to the Pooling and Servicing Agreement and thepooling and servicing agreement for the WFCM 2019-C50 Transaction, the trusteeis required to provide an assessment of compliance with applicable servicingcriteria solely with respect to Item 1122(d)(2)(iii) of Regulation AB(regarding advances of funds or guarantees regarding collections, cash flows ordistributions, and any interest or other fees charged for such advances, aremade, reviewed and approved as specified in the transaction agreements).However, during the reporting period, the trustee did not perform any servicingfunction with respect to the servicing criteria specified in Item1122(d)(2)(iii) of Regulation AB.  The master servicer or the specialservicer, to the extent required, performed the servicing function identifiedwith respect to Item 1122(d)(2)(iii) of Regulation AB, and each such partyincluded Item 1122(d)(2)(iii) of Regulation AB in the assessment of compliancewith applicable servicing criteria and accountant’s attestation report for thesubject transaction.  As a result, this Annual Report on Form 10-K doesnot include an assessment of compliance with applicable servicing criteria ofthe trustee. One or more other servicers of  the mortgage loans servicedunder the Pooling and Servicing Agreement and the Great Wolf Lodge SouthernCalifornia Mortgage Loan have delivered one or more assessments of compliancewith respect to Item 1122(d)(2)(iii) of Regulation AB.

This Annual Report on Form 10-Kincludes assessments of compliance with applicable servicing criteria andaccountants’ attestation reports from CoreLogic Solutions, LLC  Thisentity was engaged by the master servicer under the Pooling and ServicingAgreement and the primary servicer of the Great Wolf Lodge Southern CaliforniaMortgage Loan to remit tax payments received from the escrow accounts ofborrowers to local taxing authorities, to report tax amounts due, to verify taxparcel information, and to verify non-escrow tax payments. These servicingfunctions are included within the servicing criteria set forth in Items1122(d)(4)(xi) and 1122(d)(4)(xii) of Regulation AB.  Therefore, under theprinciples-based definition of “servicer” set forth in Item 1101(j) ofRegulation AB that looks to the functions that an entity performs, this vendoris a “servicer” for the purposes of Item 1122 of Regulation AB.  *See*Compliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

This Annual Report on Form 10-Kincludes an assessment of compliance with applicable servicing criteria,accountants’ attestation report and servicer compliance statement fromComputershare Trust Company, National Association (“CTCNA”).  CTCNAwas engaged by Wells Fargo Bank, National Association (“Wells Fargo”),in its capacity as certificate administrator and custodian, to perform certainspecified servicing functions identified in the assessment of compliance withapplicable servicing criteria and accountants’ attestation reports.  WellsFargo engaged CTCNA in connection with the sale of Wells Fargo’s corporatetrust services business to CTCNA and its affiliates.  Further, under theprinciples-based definition of “servicer” set forth in Item 1101(j) of RegulationAB that looks to the functions that an entity performs, this party is a“servicer” for the purposes of Item 1123 of Regulation AB.  See Complianceand Disclosure Interpretations, Section 301.01 (Item 1101(j)).

Theassessments of compliance with applicable servicing criteria, accountants’attestation reports and servicer compliance statements of the certificateadministrator of the ILPT Hawaii Portfolio Mortgage Loan and the Great WolfLodge Southern California Mortgage Loan are omitted from this Annual Report on Form10-K as the certificate administrator pursuant to the related pooling andservicing agreement or trust and servicing agreement does not perform anyactivities that address servicing criteria with respect to the issuing entityand because they are each not a “servicer” that meets the criteria in Item1108(a)(2)(i) through (iii) of Regulation AB.

Withrespect to the *pari passu* loan combination that includes theILPT Hawaii Portfolio Mortgage Loan, (i) the report on assessment ofcompliance with servicing criteria and attestation report on assessment ofcompliance with servicing criteria of Midland Loan Services, a Division of PNCBank, National Association as primary servicer of the ILPT Hawaii PortfolioMortgage Loan, listed on the Exhibit Index are omitted from this Annual Reporton Form 10-K as they are not required to be included on this Annual Report onForm 10-K per Instruction 3 to Item 1122 of Regulation AB because it is a partyperforming activities that address servicing criteria relating to 5% or less ofthe assets of the issuing entity; and (ii) the servicer compliance statement ofMidland Loan Services, a Division of PNC Bank, National Association as primaryservicer of the ILPT Hawaii Portfolio Mortgage Loan, listed on the ExhibitIndex is omitted from this Annual Report on Form 10-K as it is not required byItem 1123 of Regulation AB to be included on this Annual Report on Form 10-Kbecause it is an unaffiliated party that is not a “servicer” that meets thecriteria 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 With Accountantson 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 external creditenhancement or other support for the certificates within this transaction asdescribed under Item 1114(a) of Regulation AB.

**Item 1115(b) of Regulation AB, Certain DerivativesInstruments (Financial Information).**

No entity or group of affiliated entities provides anyderivative instruments or other support for the certificates within thistransaction as described under Item 1115 of Regulation AB.

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

The registrant knows of no material pending legal proceedinginvolving the trust or any party related to the trust, other than routinelitigation incidental to the duties of those respective parties, and thefollowing, with respect to Wells Fargo Bank, National Association, as trustee,as certificate administrator and as custodian.

 

In December 2014, Phoenix LightSF Limited and certain related entities and the National Credit UnionAdministration (NCUA) filed complaints in the United States District Court forthe Southern District of New York against Wells Fargo Bank, alleging claimsagainst Wells Fargo Bank in its capacity as trustee for a number of residentialmortgage-backed securities trusts. Complaints raising similar allegations havebeen filed by Commerzbank AG in the Southern District of New York and by IKBInternational and IKB Deutsche Industriebank in New York state court. In eachcase, the plaintiffs allege that Wells Fargo Bank, as trustee, caused losses toinvestors, and plaintiffs assert causes of action based upon, among otherthings, the trustee’s alleged failure to notify and enforce repurchaseobligations of mortgage loan sellers for purported breaches of representationsand warranties, notify investors of alleged events of default, and abide byappropriate standards of care following alleged events of default. Wells FargoBank previously settled two class action lawsuits with similar allegations thatwere filed in November 2014 and December 2016 by institutional investors in theSouthern District of New York and New York state court, respectively. Inaddition, Park Royal I LLC and Park Royal II LLC have filed complaints in NewYork state court alleging Wells Fargo Bank, N.A., as trustee, failed to takeappropriate actions upon learning of defective mortgage loan documentation. InMarch 2021, the Company entered into an agreement to resolve the case filed bythe NCUA.

 

In addition to the foregoing cases,in August 2014 and August 2015 Nomura Credit & Capital Inc. (“Nomura”)and Natixis Real Estate Holdings, LLC (“Natixis”) filed a total of seventhird-party complaints against Wells Fargo Bank in New York state court. In theunderlying first-party actions, Nomura and Natixis have been sued for allegedbreaches of representations and warranties made in connection with residentialmortgage-backed securities sponsored by them. In the third-party actions,Nomura and Natixis allege that Wells Fargo Bank, as master servicer, primaryservicer or securities administrator, failed to notify Nomura and Natixis oftheir own breaches, failed to properly oversee the primary servicers, andfailed to adhere to accepted servicing practices. Natixis additionally allegesthat Wells Fargo Bank failed to perform default oversight duties. Wells FargoBank has asserted counterclaims alleging that Nomura and Natixis failed toprovide Wells Fargo Bank notice of their representation and warranty breaches.

 

With respect to each of the foregoing litigations, WellsFargo Bank believes plaintiffs' claims are without merit and intends to contestthe claims vigorously, but there can be no assurances as to the outcome of thelitigations or the possible impact of the litigations on Wells Fargo Bank orthe related 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 May 31, 2019 pursuant to Rule 424(b)(2).

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

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

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the ILPT Hawaii Portfolio MortgageLoan, which is being serviced and administered pursuant to the trust andservicing agreement for the ILPT 2019-SURF Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit L to thetrust and servicing agreement for the ILPT 2019-SURF Transaction incorporatedby reference as Exhibit 4.2 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the ILPT2019-SURF Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Great Wolf Lodge SouthernCalifornia Mortgage Loan, which is being serviced and administered pursuant tothe pooling and servicing agreement for the WFCM 2019-C50 Transaction, areattached hereto under Item 15 to this Annual Report on Form 10-K. Attached asExhibit AA to the pooling and servicing agreement for the WFCM 2019-C50Transaction incorporated by reference as Exhibit 4.3 to this Annual Report onForm 10-K is a chart identifying the entities participating in a servicingfunction for the WFCM 2019-C50 Transaction responsible for each applicableservicing criteria set forth in Item 1122(d).

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

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

**PART IV**

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

(a) The followingis a list of documents filed as part of this Annual Report on Form 10-K:

(1) Not applicable

(2) Not applicable

(3) See below

4.1          Pooling and Servicing Agreement, dated as of May 1, 2019,by and among Banc of America Merrill Lynch Commercial Mortgage Inc., asDepositor, Wells Fargo Bank, National Association, as General Master Servicer,Rialto Capital Advisors, LLC, as General Special Servicer, National CooperativeBank, N.A., as NCB Master Servicer and as NCB Special Servicer, Situs Holdings,LLC, as Newport Corporate Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator, Wilmington Trust, NationalAssociation, as Trustee, and Pentalpha Surveillance LLC, as Operating Advisorand Asset Representations Reviewer (filed as Exhibit 4.1 to the registrant’sCurrent Report on Form 8-K filed on May 31, 2019 under Commission File No.333-228375-01 and incorporated by reference herein).

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

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

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

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

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

4.7          Agreement Between Note Holders, dated as of May 16, 2019,by and between Deutsche Bank AG, New York Branch, as Initial Note A-1-A Holder,Initial Note A-1-B Holder, Initial Note A-1-C Holder, Initial Note B-1-AHolder, Initial Note B-1-B Holder, Initial Note C-1-A Holder, Initial NoteC-1-B Holder and Initial Note D-1 Holder, and Wells Fargo Bank, NationalAssociation, Initial Note A-2-A Holder, Initial Note A-2-B Holder, Initial NoteA-2-C Holder, Initial Note B-2-A Holder, Initial Note B-2-B Holder, InitialNote C-2-A Holder, Initial Note C-2-B Holder and Initial Note D-2 Holder (filedas Exhibit 4.7 to the registrant’s Current Report on Form 8-K filed on May 31,2019 under Commission File No. 333-228375-01 and incorporated by referenceherein).

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

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

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

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

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

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

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

33.1        Wells Fargo Bank, National Association, as GeneralMaster Servicer

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

33.3        Rialto Capital Advisors, LLC, as General SpecialServicer

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

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

33.6        Wells Fargo Bank, National Association, asCertificate Administrator

33.7        Wells Fargo Bank, National Association, asCustodian

33.8        Pentalpha Surveillance LLC, as Operating Advisor

33.9        CoreLogic Solutions, LLC, as Servicing FunctionParticipant

33.10      Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator on andafter November 1, 2021

33.11      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021

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

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

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

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

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

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

33.18      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.11)

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

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

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

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

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

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

33.25      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.11)

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

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

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

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

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

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

33.32      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1, 2021(see Exhibit 33.11)

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

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

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

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

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

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

33.39      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.11)

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

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

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

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

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

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

33.46      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.11)

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

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

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

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

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

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

33.53      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.11)

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

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

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

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

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

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

33.60      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.11)

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

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

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

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

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

33.66      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.11)

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

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

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

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

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

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

33.73      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.11)

34           Attestation reportson assessment of compliance with servicing criteria for asset-backedsecurities.

34.1        Wells Fargo Bank, National Association, as GeneralMaster Servicer

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

34.3        Rialto Capital Advisors, LLC, as General SpecialServicer

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

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

34.6        Wells Fargo Bank, National Association, asCertificate Administrator

34.7        Wells Fargo Bank, National Association, asCustodian

34.8        Pentalpha Surveillance LLC, as Operating Advisor

34.9        CoreLogic Solutions, LLC, as Servicing FunctionParticipant

34.10      Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator on andafter November 1, 2021

34.11      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021

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

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

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

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

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

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

34.18      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.11)

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

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

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

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

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

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

34.25      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.11)

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

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

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

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

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

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

34.32      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.11)

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

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

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

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

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

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

34.39      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.11)

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

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

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

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

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

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

34.46      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.11)

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

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

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

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

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

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

34.53      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.11)

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

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

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

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

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

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

34.60      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.11)

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

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

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

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

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

34.66      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.11)

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

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

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

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

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

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

34.73      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.11)

35           Servicer compliance statements.

35.1        Wells Fargo Bank, National Association, as GeneralMaster Servicer

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

35.3        Rialto Capital Advisors, LLC, as General SpecialServicer

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

35.5        Wells Fargo Bank, National Association, asCertificate Administrator

35.6        Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator on andafter November 1, 2021

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

(b)   The exhibits required to be filed by theRegistrant pursuant to Item 601 of Regulation S-K are listed above.

(c)    Not Applicable.

 

**SIGNATURES**

Pursuant to the requirements of Section 13 or 15(d) of theSecurities Exchange Act of 1934, the registrant has duly caused this report tobe signed on its behalf by the undersigned, thereunto duly authorized.

Banc of America Merrill LynchCommercial Mortgage Inc.(Depositor)

/s/ LelandF. Bunch, III

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

(senior officer in charge ofsecuritization of the depositor)

Date: March 15, 2022