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National Cooperative Bank

 

 

**MANAGEMENT'S ASSERTION ON ASSESSMENT OF**

**COMPLIANCE WITH SEC REGULATION AB SERVICING**

**CRITERIA**

 

1.       Managementof the National Cooperative Bank, N.A., (the “Company”) is responsible forassessing compliance with the servicing criteria applicable to it underparagraph (d) of Item 1122 of Regulation AB of the Securities and ExchangeCommission (“SEC”) relating to the servicing of asset-backed securitiestransactions conducted by the Company (the “Platform”) as of and for the yearended December 31, 2023 (the “Reporting Period”). Appendix A identifies theindividual asset-backed transactions and securities defined by management asconstituting the Platform;

 

2.       Exceptas set forth in paragraph 3 below, the Company used the criteria set forth inparagraph (d) of Item 1122 of Regulation AB to provide an assertion on theCompany’s assessment of compliance with the applicable servicing criteria;

 

3.       Thecriteria listed in the column titled “Inapplicable Servicing Criteria” onAppendix B hereto are inapplicable to the Company based on the activities itperformed with respect to the Platform for the Reporting Period;

 

4.       Duringthe Reporting Period, there were no adjustments to interest rates or rates ofreturn for pool assets with variable rates, therefore the Company did notperform any servicing activities related to criteria 1122(d)(4)(ix) as of andfor the year ended December 31, 2023.

 

5.       Withrespect to servicing criteria 1122(d)(4)(xi), the Company has engaged with avendor to perform the activities required by this servicing criteria.Management has determined that the vendor is not considered a “servicer” asdefined in Item 1101(j) of Regulation AB, and has elected to takeresponsibility for assessing compliance with the servicing criteria applicableto the vendor as permitted by the SEC’s Compliance & DisclosureInterpretation 200.06, Vendors Engaged by Servicers (“C&DI 200.06”),formerly Interpretation 17.06 of the SEC Division of Corporation Finance Manualof Publicly Available Telephone Interpretations. As permitted by C&DI200.06, management asserts that it has policies and procedures in placedesigned to provide reasonable assurance that the vendor’s activities comply inall material respects with the servicing criteria applicable to the vendor.Management is not aware of any material deficiencies in such policies andprocedures or any material instances of non-compliance of the servicingcriteria as relates to the Company by such vendor. Management is solelyresponsible for determining that it meets the SEC requirements to applyC&DI 200.06 for the vendor and related criteria.

 

6.       TheCompany has complied, in all material respects, with the applicable servicingcriteria set forth in Item 1122(d) of Regulation AB, as of December 31, 2023and for the Reporting Period with respect to the Platform taken as a whole;

 

7.       GrantThornton LLP, an independent registered public accounting firm, has issued anattestation report on the Company’s assertion of compliance with the applicableservicing criteria for the Reporting Period.

 

National Cooperative Bank,N.A. 

January 31, 2024

 

 

/s/ Thomas Klump

Thomas Klump

Executive Vice President andChief Operating Officer

 

 

**Appendix A to Management’s Assertion**

** **

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

 

| **Investor #** | **Pool Description**                                  |
|----------------|-------------------------------------------------------|
| **363**        | **CSFB 2000 PS4, final distribution date 12/15/23**   |
| **378**        | **CSFB 2004 C4**                                      |
| **380**        | **CSFB 2005 C3**                                      |
| **383**        | **CSFB 2006 C1**                                      |
| **385**        | **CSMC 2006 C4**                                      |
| **391**        | **WFBRBS 2013 C13, final distribution date 04/17/23** |
| **392**        | **WFBRBS 2013 C15, final distribution date 10/17/23** |
| **393**        | **WFBRBS 2013 C16, final distribution date 09/15/23** |
| **394**        | **WFBRBS 2013 C18, final distribution 12/15/23**      |
| **395**        | **WFBRBS 2014 C19**                                   |
| **396**        | **WFBRBS 2014 C20**                                   |
| **397**        | **WFBRBS 2014 C21**                                   |
| **398**        | **WFBRBS 2014 C22**                                   |
| **399**        | **WFBRBS 2014 C23**                                   |
| **400**        | **WFCM 2014 LC18**                                    |
| **401**        | **WFCM 2015 C26**                                     |
| **402**        | **WFCM 2015 C29**                                     |
| **403**        | **WFCM 2015 C30**                                     |
| **404**        | **WFCM 2015 LC22**                                    |
| **405**        | **WFCM 2015 NXS3**                                    |
| **406**        | **WFCM 2016 C32**                                     |
| **407**        | **WFCM 2016 C33**                                     |
| **408**        | **WFCM 2016 C35**                                     |
| **409**        | **WFCM 2016 LC24**                                    |
| **410**        | **WFCM 2016 C36**                                     |
| **411**        | **WFCM 2016 LC25**                                    |
| **412**        | **WFCM 2017 RC1**                                     |
| **413**        | **BANK 2017 BNK5**                                    |
| **414**        | **BANK 2017 BNK6**                                    |
| **415**        | **BANK 2017 BNK7**                                    |
| **416**        | **BANK 2017 BNK8**                                    |
| **417**        | **BANK 2018 BNK10**                                   |
| **418**        | **BANK 2018 BNK11**                                   |
| **419**        | **BANK 2018 BNK12**                                   |
| **422**        | **BANK 2018 BNK13**                                   |
| **423**        | **BANK 2018 BNK14**                                   |
| **424**        | **BANK 2018 BNK15**                                   |
| **426**        | **BANK 2019 BNK16**                                   |
| **427**        | **BANK 2019 BNK18**                                   |
| **428**        | **BANK 2019 BNK19**                                   |
| **429**        | **BANK 2019 BNK20**                                   |
| **461**        | **BANK 2019 BNK22**                                   |
| **462**        | **BANK 2019 BNK24**                                   |
| **463**        | **BANK 2020 BNK25**                                   |
| **464**        | **BANK 2020 BNK26**                                   |
| **465**        | **BANK 2020 BNK28**                                   |
| **466**        | **BANK 2020 BNK30**                                   |
| **467**        | **BANK 2021 BNK31**                                   |
| **468**        | **BANK 2021 BNK32**                                   |
| **469**        | **BANK 2021 BNK33**                                   |
| **472**        | **BANK 2021 BNK34**                                   |
| **473**        | **BANK 2021 BNK35**                                   |
| **474**        | **BANK 2021 BNK36**                                   |
| **476**        | **BANK 2021 BNK37**                                   |
| **477**        | **BANK 2021 BNK38**                                   |
| **478**        | **BANK 2022 BNK39**                                   |
| **479**        | **BANK 2022 BNK40**                                   |
| **481**        | **BANK 2022 BNK41**                                   |
| **482**        | **BANK 2022 BNK42**                                   |
| **483**        | **BANK 2022 BNK43**                                   |
| **484**        | **BANK 2022 BNK44**                                   |
| **485**        | **BANK 2023 BNK46**                                   |

 

 

**APPENDIX B to Management’s Assertion**

** **

| **SERVICING CRITERIA**                                          | **APPLICABLE SERVICING CRITERIA**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | **INAPPLICABLE SERVICING CRITERIA**                           |
|-----------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------|
| ** **

** **

** **

**Reference**               | ** **

** **

** **

**Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | ** **

** **

**Performed Directly by the Company** | ** **

**Performed by Vendor(s) for which the  Company is the Responsible Party** | **Performed by subservicer(s) or vendor(s) for  which the Company is Not the Responsible Party** | **Not performed by the Company or by  subservicer(s) or vendor(s) retained by the Company** |
| **General Servicing  Considerations**                           |
|  

1122(d)(1)(i)                                           | Policies and procedures are instituted to monitor any  performance or other triggers and events of default in accordance with the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | ** **

**X**                                             |   |   |   |
|  

1122(d)(1)(ii)                                          | If any material servicing activities are outsourced to  third parties, policies and procedures are instituted to monitor the third  party’s performance and compliance with such servicing activities.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | ** **

**X**                                             |   |   |   |
|  

1122(d)(1)(iii)                                         | Any requirements in the transaction agreements to  maintain a back-up servicer for the pool assets are maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                                          |   |   | **X** |
|  

 

1122(d)(1)(iv)                                  | A fidelity bond and errors and omissions policy is in  effect on the party participating in the servicing function throughout the  reporting period in the amount of coverage required by and otherwise in accordance  with the terms of the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                    | ** **

**X**                                             |   |   |   |
|  

1122(d)(1)(v)                                           | Aggregation of information, as applicable, is  mathematically accurate and the information conveyed accurately reflects the  information.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | ** **

**X**                                             |   |   |   |
| **Cash Collection and  Administration**                         |
|  

 

1122(d)(2)(i)                                   | Payments on pool assets are deposited into the  appropriate custodial bank accounts and related bank clearing accounts no  more than two business days of receipt, or such other number of days  specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | ** **

**X**                                             | ** ** | ** ** | ** ** |
|  

1122(d)(2)(ii)                                          | Disbursements made via wire transfer on behalf of an  obligor or to an investor are made only by authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | **X**                                                         | ** ** | ** ** | ** ** |
|  

1122(d)(2)(iii)                                         | Advances of funds or guarantees regarding  collections, cash flows or distributions, and any interest or other fees  charged for such advances, are made, reviewed and approved as specified in  the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | ** **

**X**                                             | ** ** | ** ** | ** ** |
|  

 

1122(d)(2)(iv)                                  | The related accounts for the transaction, such as  cash reserve accounts or accounts established as a form of over  collateralization, are separately maintained (e.g., with respect to  commingling of cash) as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                               | ** **

**X**                                             | ** ** | ** ** | ** ** |
|  

 

 

1122(d)(2)(v)                           | Each custodial account is maintained at a federally  insured depository institution as set forth in the transaction agreements.  For purposes of this criterion, "federally insured depository  institution" with respect to a foreign financial institution means a  foreign financial institution that meets the requirements of

§240.13k-1(b)(1) of this chapter.                                                                                                                                                                                                                                                                                                                                    | ** **

** **

**X**                                 | ** ** | ** ** | ** ** |
|  

1122(d)(2)(vi)                                          | Unissued checks are safeguarded so as to prevent  unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | **X**                                                         | ** ** | ** ** | ** ** |
|  

 

 

 

 

 

1122(d)(2)(vii) | Reconciliations are prepared on a monthly basis for  all asset- backed securities related bank accounts, including custodial  accounts and related bank clearing accounts. These reconciliations: (A) Are  mathematically accurate; (B) Are prepared within 30 calendar days after the  bank statement cutoff date, or such other number of days specified in the  transaction agreements; (C) Are reviewed and approved by someone other than  the person who prepared the reconciliation; and (D) Contain explanations for  reconciling items. These reconciling items are resolved within 90 calendar  days of their original identification, or such other number of days specified  in the transaction agreements. | ** **

** **

** **

** **

**X**         | ** ** | ** ** | ** ** |
| **Investor Remittances and  Reporting**                         |
|  

 

 

 

 

1122(d)(3)(i)           | Reports to investors, including those to be filed with  the Commission, are maintained in accordance with the transaction agreements  and applicable Commission requirements. Specifically, such reports: (A) Are  prepared in accordance with timeframes and other terms set forth in the  transaction agreements; (B) Provide information calculated in accordance with  the terms specified in the transaction agreements; (C) Are filed with the  Commission as required by its rules and regulations; and (D) Agree with  investors’ or the trustee’s records as to the total unpaid principal balance  and number of pool assets serviced by the servicer.                                            |                                                          |   |   | ** **

** **

** **

** **

**X** |
|  

1122(d)(3)(ii)                                          | Amounts due to investors are allocated and remitted  in accordance with timeframes, distribution priority and other terms set  forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |                                                          |   |   | ** **

**X** |
|  

1122(d)(3)(iii)                                         | Disbursements made to an investor are posted within  two business days to the servicer’s investor records, or such other number of  days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |                                                          |   |   | ** **

**X** |
|  

1122(d)(3)(iv)                                          | Amounts remitted to investors per the investor  reports agree with cancelled checks, or other form of payment, or custodial  bank statements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |                                                          |   |   | ** **

**X** |
| **Pool Asset Administration**                                   |
| 1122(d)(4)(i)                                                   | Collateral or security on pool assets is maintained  as required by the transaction agreements or related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | **X**                                                         |   |   |   |
| 1122(d)(4)(ii)                                                  | Pool assets and related documents are safeguarded as  required by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |                                                          |   |   | **X** |
|  

1122(d)(4)(iii)                                         | Any additions, removals or substitutions to the asset  pool are made, reviewed and approved in accordance with any conditions or  requirements in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | ** **

**X**                                             |   |   |   |
|  

 

 

1122(d)(4)(iv)                          | Payments on pool assets, including any payoffs, made  in accordance with the related pool asset documents are posted to the  applicable servicer's obligor records maintained no more than two business  days after receipt, or such other number of days specified in the transaction  agreements, and allocated to principal, interest or other items (e.g.,  escrow) in accordance with the related pool asset documents.                                                                                                                                                                                                                                                                                            | ** **

** **

**X**                                 |   |   |   |
|  

1122(d)(4)(v)                                           | The servicer's records regarding the pool assets  agree with the servicer's records with respect to an obligor's unpaid  principal balance.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | ** **

**X**                                             |   |   |   |
|  

 

1122(d)(4)(vi)                                  | Changes with respect to the terms or status of an  obligor's mortgage loans (e.g., loan modifications or re-aging's) are made,  reviewed and approved by authorized personnel in accordance with the  transaction agreements and related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                          | ** **

**X**                                             |   |   |   |
|  

 

1122(d)(4)(vii)                                 | Loss mitigation or recovery actions (e.g. forbearance  plans, modifications and deeds in lieu of foreclosure, foreclosure and  repossessions, as applicable) are initiated, conducted and concluded in  accordance with the timeframes or other requirements established by the a  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                              | ** **

**X**                                             |   |   |   |
|  

 

 

 

1122(d)(4)(viii)                | Records documenting collection efforts are maintained  during the period a pool asset is delinquent in accordance with the  transaction agreements. Such records are maintained on at least a monthly  basis, or such other period specified in the transaction agreements, and  describe the entity's activities in monitoring delinquent pool assets  including, for example, phone calls, letters and payment rescheduling plans  in cases where delinquency is deemed temporary (e.g., illness or unemployment).                                                                                                                                                                                                    | ** **

** **

** **

**X**                     |   |   |   |
|  

1122(d)(4)(ix)                                          | Adjustments to interest rates or rates of return for  pool assets with variable rates are computed based on the related pool asset  documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | ** **

**X**                                             |   |   |   |
|  

 

 

 

 

1122(d)(4)(x)           | Regarding any funds held in trust for an obligor  (such as escrow accounts) See following: (A) Such funds are analyzed, in  accordance with the obligor's pool asset documents, on at least an annual  basis, or such other period specified in the transaction agreements; (B)  Interest on such funds is paid, or credited, to obligors in accordance with  applicable pool asset documents and state laws; and (C) Such funds are  returned to the obligor within 30 calendar days of full repayment of the  related pool asset, or such other number of days specified in the transaction  agreements.                                                                                                              | ** **

** **

** **

**X**                     |   |   |   |
|  

 

 

1122(d)(4)(xi)                          | Payments made on behalf of an obligor (such as tax or  insurance payments) are made on or before the related penalty or expiration  dates, as indicated on the appropriate bills or notices for such payments,  provided that such support has been received by the servicer at least 30  calendar days prior to these dates, or such other number of days specified in  the transaction agreements.                                                                                                                                                                                                                                                                                                                    | ** **

** **

**X**                                 | ** **

** **

**X** |   |   |
|  

1122(d)(4)(xii)                                         | Any late payment penalties in connection with any  payment to be made on behalf of an obligor are paid from the servicer’s funds  and not charged to the obligor, unless the late payment was due to the  obligor’s error or omission.                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | ** **

**X**                                             |   |   |   |
|  

1122(d)(4)(xiii)                                        | Disbursements made on behalf of an obligor are posted  within two business days to the obligor’s records maintained by the servicer,  or such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | ** **

**X**                                             |   |   |   |
|  

1122(d)(4)(xiv)                                         | Delinquencies, charge-offs and uncollectible accounts  are recognized and recorded in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | ** **

**X**                                             |   |   |   |
|  

1122(d)(4)(xv)                                          | Any external enhancement or other support, identified  in Item 1114(a) (1) through (3) or Item 1115 of this Regulation AB, is  maintained as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |                                                          |   |   | ** **

**X** |