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Report of Independent Registered PublicAccounting Firm

 

To the Board of Directors

Principal Global Investors, LLC andPrincipal Real Estate Investors, LLC

 

We have examined management’s assertion,included in the accompanying Management’s Assessment on Compliance with SECRegulation AB Servicing Criteria, that Principal Global Investors, LLC andPrincipal Real Estate Investors, LLC, (the “Companies”) complied with theservicing criteria set forth in Item 1122 (d) of the Securities and ExchangeCommission’s Regulation AB for the commercial mortgage backed securitiesplatform as of and for the year ended December 31, 2021, except for 1122(d)(1)(ii)-(iii), 1122 (d)(3)(i)-(iv), 1122(d)(4)(ix), and 1122(d)(4)(xv),which the Companies have determined are not applicable to the activitiesperformed by them with respect to the servicing platform covered by thisreport. See Attachment A of Management’s Assessment on Compliance WithRegulation AB Criteria for the asset backed transactions covered by thisplatform. Management is responsible for the Companies’ compliance with thoseservicing criteria. Our responsibility is to express an opinion on management’sassertion about the Companies’ compliance with the servicing criteria based onour examination.

 

Our examination was conducted inaccordance with attestation standards established by the American Institute ofCertified Public Accountants and the Public Company Accounting Oversight Board(United States) and, accordingly, included examining, on a test basis, evidenceabout the Companies’ compliance with the applicable servicing criteria and performingsuch other procedures as we considered necessary in the circumstances. Ourexamination included testing of less than all of the individual asset backedtransactions and securities that comprise the platform, testing of less thanall of the servicing activities related to the Platform and determining whetherthe Companies processed those selected transactions and performed thoseselected activities in compliance with the servicing criteria and as permittedby Regulation AB Compliance and Disclosure Interpretations of the Division ofCorporation Finance, Section 200.06, “Vendors Engaged by Servicers” (C&DI200.06). Furthermore, our procedures were limited to the selected transactionsand servicing activities performed by the Companies during the period coveredby this report. Our procedures were not designed to determine whether errorsmay have occurred either prior to or subsequent to our tests that may haveaffected the balances or amounts calculated or reported by the Companies duringthe period covered by this report for the selected transactions or any othertransactions. We believe that the evidence we obtained is sufficient andappropriate to provide a reasonable basis for our opinion.

 

Our examination does not provide a legaldetermination on the Companies’ compliance with the servicing criteria.

 

As described in management’s assertion,for servicing criteria 1122 (d)(1)(i) and 1122 (d)(4)(i), the Companies haveengaged various vendors to perform the activities required by these servicingcriteria. The Companies have determined that these vendors are not considered a“servicer” as defined in Item 1101(j) of Regulation AB, and the Companies haveelected to take responsibility for assessing compliance with the applicableservicing criteria applicable to each vendor as permitted by C&DI 200.06.As permitted by C&DI 200.06, the Companies have asserted that they havepolicies and procedures in place designed to provide reasonable assurance thatthe vendors’ activities comply in all material respects with servicing criteriaapplicable to each vendor. The Companies are solely responsible for determiningthat they meet the SEC requirements to apply C&DI 200.06 for the vendorsand related criteria as described in their assertion, and we performed no procedureswith respect to the Companies’ eligibility to apply C&DI 200.06.

 

In our opinion, management’s assertionthat the Companies complied with the aforementioned servicing criteriaincluding servicing criteria 1122 (d)(1)(i) and 1122 (d)(4)(i) for which complianceis determined based on C&DI 200.06 as described above, as of and for theyear ended December 31, 2021 for the commercial mortgage backed securitiesplatform, is fairly stated, in all material respects.

 

/s/ Ernest & Young LLP

 

February 17, 2022

 

 

A member firm of Ernst & Young GlobalLimited