** **

**MANAGEMENT'SASSESSMENT OF COMPLIANCE WITH APPLICABLE SERVICING CRITERIA**

**PURSUANT TO ITEM1122 OF REGULATION AB**

 

 

Managementof Berkeley Point Capital LLC d/b/a Newmark (“Newmark”) is responsible for assessingcompliance with the applicable servicing criteria set forth in Item 1122(d) ofRegulation AB of the Securities and Exchange Commission (“SEC”) relating to itsrole in the servicing of commercial mortgage-backed securities transactionsconducted by Newmark (the "Platform") as of and for the year endedDecember 31, 2022 (the "Reporting Period"). Appendix A identifies theindividual asset-backed transactions and securities defined by management asconstituting the Platform.

 

Newmark'smanagement has assessed Newmark's compliance with the applicable servicingcriteria during the Reporting Period. In making this assessment, managementused the criteria set forth by the "SEC" in paragraph (d) of Item1122 of Regulation AB, excluding the criteria set forth in Appendix B, whichmanagement has determined are not applicable to the servicing activities itperforms with respect to the Platform.

 

Withrespect to applicable servicing criteria identified in Appendix C, there wereno activities performed for the Reporting Period with respect to the Platform,because there was no occurrence of events that would require Newmark to performsuch activities.

 

Withrespect to servicing criteria 1122(d)(1)(v), 1122(d)(2)(vi) and1122(d)(2)(vii), management has engaged Midland Loan Services, a division ofPNC Bank, National Association ("Midland") to perform the activitiesrequired by these servicing criteria. Newmark management has determined thatMidland is not a "servicer" as defined in Item 1101(j) of RegulationAB, and Newmark's management has elected to take responsibility for assessingcompliance with the servicing criteria applicable to Midland as permitted bythe SEC's Compliance and Disclosure Interpretation ("C&D1")200.06, Vendors Engaged by Servicers (C&DI 200.06) 

(formerlySEC Regulation AB Manual of Publicly Available Telephone Interpretations,17.06). Management has policies and procedures in place designed to providereasonable assurance that Midland's activities comply in all material respectswith the servicing criteria applicable to Midland. Newmark has not identifiedand is not aware of any material instances of noncompliance by Midland with theapplicable servicing criteria during the Reporting Period, with respect to thePlatform taken as a whole, nor has it identified any material deficiencies inits policies and procedures to monitor the compliance by Midland with theapplicable servicing criteria during the Reporting Period with respect to thePlatform taken as a whole. Newmark is solely responsible for determining thatit meets the SEC requirements to apply C&DI 200.06 for Midland and therelated criteria.

 

Basedon such assessment, management believes that with respect to the ReportingPeriod, Newmark has complied in all material respects with the servicingcriteria set forth in Item 1122(d) of Regulation AB of the SEC, includingservicing criteria 1122(d)(1)(v),1122(d)(2)(vi) and 1122(d)(2)(vii) for whichcompliance is determined based on C&DI 200.06 as described above relatingto its role in the servicing of the Platform.

 

Ernstand Young LLP, an independent registered public accounting firm, has Issued anattestation report with respect to management's assessment of compliance withthe applicable servicing criteria with respect to the Reporting Period.

 

 

By:Berkeley Point Capital LLC,

dbaNewmark

 

 

/s/Ronald Steffenino

RonaldSteffenino

ViceChairman

 

2/22/2023

Date

 

 

/s/Mike Rispoli

MikeRispoli

ChiefFinancial Officer

 

2/22/2023

Date

 

 

**Appendix A toManagement's Assessment**

** **

COMM2014-CCRE 17 Mortgage Trust Commercial Mortgage Pass-Through Certificates 

COMM2014-UBS4 Mortgage Trust Commercial Mortgage Pass-Through Certificates 

COMM2014-CCRE19 Mortgage Trust Commercial Mortgage Pass-Through Certificates

GSMortgage Securities Trust 2014-GC24 Commercial Mortgage Pass-ThroughCertificates Series 2014-GC24 

COMM2014-CCRE20 Mortgage Trust Commercial Mortgage Pass-Through Certificates

COMM2015-LC19 Mortgage Trust Commercial Mortgage Pass-Through Certificates

GSMortgage Securities Trust 2015-GC28 Commercial Mortgage Pass-ThroughCertificates Series 2015-GC28 

GSMortgage Securities Trust 2015-GC30 Commercial Mortgage Pass-ThroughCertificates Series 2015-GC30 

CommercialMortgage Pass-Through Certificates Series 2015-CCRE23

CommercialMortgage Pass-Through Certificates Series 2015-LC21

COMM2015-CCRE24 Mortgage Trust Commercial Mortgage Pass-Through Certificates 

COMM2015-CCRE26 Mortgage Trust Commercial Mortgage Pass-Through Certificates 

COMM2015 CCRE27 Mortgage Trust Commercial Mortgage Pass-Through Certificates

GSMortgage Securities Trust 2015-GC34 Commercial Mortgage Pass-ThroughCertificates Series 2015-GC34 

COMM2015-LC23 Mortgage Trust Commercial Mortgage Pass-Through Certificates Series2015-LC23 

CFCRE2016-C3 Mortgage Trust Commercial Mortgage Pass-Through Certificates, Series2016-C3

CFCRE2016-C4 Mortgage Trust Commercial Mortgage Pass-through Certificates, Series2016-C4

CitigroupCommercial Mortgage Trust 2016-Cl, Commercial Mortgage Pass-through Certificates,Series 2016-Cl 

SGCommercial Mortgage Securities Trust 2016-CS Commercial Mortgage Pass-ThroughCertificates Series 2016-CS 

CitigroupCommercial Mortgage Trust 2016-C3, Commercial Mortgage Pass-throughCertificates, Series 2016-C3 

CFCRE2016-C6 Mortgage Trust Commercial Mortgage Pass-Through Certificates Series2016-C6

CFCRE2016-C7 Commercial Mortgage Pass-Through Certificates

CFCRE2017-C8 Mortgage Trust Commercial Mortgage Pass-Through Certificates, Series2017-C8

UBSCommercial Mortgage Trust 2017-C4 Commercial Mortgage Pass-Through CertificatesSeries 2017-C4 

UBSCommercial Mortgage Trust 2017-CS Commercial Mortgage Pass-Through CertificatesSeries 2017-CS 

UBSCommercial Mortgage Trust 2017-C6 Commercial Mortgage Pass-Through CertificatesSeries 2017-C6 

CitigroupCommercial Mortgage Trust 2017-C4 Commercial Mortgage Pass-Through CertificatesSeries 2017-C4 

CCUBSCommercial Mortgage Trust 2017-Cl Commercial Mortgage Pass-Through CertificatesSeries 2017-Cl 

CitigroupCommercial Mortgage Trust 2018-C6 Commercial Mortgage Pass-Through CertificatesSeries 2018-C6 

UBSCommercial Mortgage Trust 2018-C8 Commercial Mortgage Pass-Through CertificatesSeries 2018-C8 

Benchmark2018-B3 commercial Mortgage Pass-Through Certificates Series 2018-B3

UBSCommercial Mortgage Trust 2018-Cl0 Commercial Mortgage Pass-throughCertificates, Series 2018-Cl0 

UBSCommercial Mortgage Trust 2018-C12 Commercial Mortgage Pass-ThroughCertificates, Series 2018-C12 

MorganStanley Capital, I Trust 2018-Ll Commercial Mortgage Pass-Through Certificates,Series 2018-Ll 

UBSCommercial Mortgage Trust 2018-Cl4 Commercial Mortgage Pass-ThroughCertificates Series 2018 Cl4 

BBCMSMortgage Trust 2018 C2 Commercial Mortgage Pass-Through Certificates, Series2018-C2

UBSCommercial Mortgage Trust 2018 C9

MorganStanley Capital, I Trust 2018 H4 Commercial Mortgage Pass-Through Series 2018H4

MorganStanley Capital, I Trust 2019 L2 Commercial Mortgage Pass-Through CertificatesSeries 2019-L2 

CF2019 CFl Mortgage Trust Commercial Mortgage Pass-Through Certificates Series2019-CFl

 

 

**Appendix B toManagement's Assessment**

**Regulation AB Item 1122(d)criteria determined to be not applicable:**

** **

 •!•      1122(d)(l)(iii)

 •!•      1122(d)(2)(ii)

 •!•      1122(d)(2)(iii)

 •!•      1122(d)(3)(i)

 •!•      1122(d)(3)(ii)

 •!•      1122(d)(3)(iii)

 •!•      1122(d)(3)(iv)

 •!•      1122(d)(4)(ii)

 •!•       1122(d)(4)(vii)

 •!•      1122{d)(4)(xv)

 

 

**Appendix C toManagement's Assessment**

 

 

RegulationAB Item 1122(d) criteria that Newmark is under contract to perform theactivities required, but for which there were no occurrences of ***events***for the year ended December 31, 2022 that required them to perform suchactivities:

 

❖          1122(d)(4)(iii)

❖          1122(d)(4)(vi)

❖          1122(d)(4)(viii)

❖          1122(d){4)(ix)

❖          1122(d)(4)(xii)

❖          1122(d)(4)(xiv)

 

 

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