**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, 2023or**

**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: 333-226123-03**

**Central Index Key Number of the issuing entity:0001775756**

**Benchmark 2019-B11 Mortgage Trust**

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

** **

**Central Index Key Number of the depositor: 0001013611**

**J.P. Morgan Chase CommercialMortgage Securities Corp.**

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

** **

**Central Index Key Number of the sponsor: 0000835271**

**JPMorgan Chase Bank, NationalAssociation**

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

** **

**Central Index Key Number of the sponsor: 0001541294**

**German American Capital Corporation**

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

** **

**Central Index Key Number of the sponsor: 0001701238**

**Citi Real Estate Funding Inc.**

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

** **

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

**the issuing entity)** | **38-4117359**

**38-4117360**

**38-7221329**

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

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

**c/o Computershare Trust Company, National Association, as agent for**

**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:**

**(212) 834-5467**

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 every Interactive Data File required to be submitted pursuant toRule 405 of Regulation S-T (Section 232.405 of this chapter) during thepreceding 12 months (or for such shorter period that the registrant wasrequired to submit such files).

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                                                                                                       Accelerated filer                                     o

Non-acceleratedfiler          ⌧                                                                                                      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

If securities are registered pursuant to Section 12(b) of theAct, indicate by check mark whether the financial statements of the registrantincluded in the filing reflect the correction of an error to previously issuedfinancial statements. o

Indicate by check mark whether any of those error correctionsare restatements that required a recovery analysis of incentive-basedcompensation received by any of the registrant’s executive officers during therelevant recovery period pursuant to §240.10D-1(b). 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 Green Hills Corporate Center Mortgage Loan, the WesternDigital R&D Campus Mortgage Loan and the Greenleaf at Howell Mortgage Loan,which constituted approximately 4.5%, 3.5% and 2.4%, respectively, of the assetpool of the issuing entity as of its cut-off date, are each an asset of theissuing entity and are each part of a loan combination that includes the GreenHills Corporate Center Mortgage Loan, the Western Digital R&D CampusMortgage Loan or the Greenleaf at Howell Mortgage Loan and one other *paripassu* loan, which is not an asset of the issuing entity. These loancombinations, including the Green Hills Corporate Center Mortgage Loan, theWestern Digital R&D Campus Mortgage Loan and the Greenleaf at HowellMortgage Loan, are being serviced and administered pursuant to the Pooling andServicing Agreement, which is incorporated by reference as Exhibit 4.1 to thisAnnual Report on Form 10-K. 

The Exhibit Index describes exhibits provided by certainparties (in their capacities indicated on the Exhibit Index) with respect tothe ILPT Hawaii Portfolio Mortgage Loan, which constituted approximately 7.1%of the asset pool of the issuing entity as of its cut-off date.  The ILPTHawaii Portfolio Mortgage Loan is an asset of the issuing entity and is part ofa loan combination that includes the ILPT Hawaii Portfolio Mortgage Loan andfifteen other *pari passu* loans, which are not assets of the issuingentity. A *pari passu* portion of the loan combination was securitized inthe ILPT Trust 2019-SURF transaction (the “ILPT 2019-SURF Transaction”).This loan combination, including the ILPT Hawaii Portfolio Mortgage Loan, isbeing serviced and administered pursuant to the trust and servicing agreementfor the ILPT 2019-SURF Transaction, which is incorporated by reference asExhibit 4.2 to this Annual Report on Form 10-K.

The Exhibit Index describes exhibits provided by certainparties (in their capacities indicated on the Exhibit Index) with respect tothe 101 California Mortgage Loan, which constituted approximately 4.5% of theasset pool of the issuing entity as of its cut-off date.  The 101California Mortgage Loan is an asset of the issuing entity and is part of aloan combination that includes the 101 California Mortgage Loan, seven other *paripassu* loans and two subordinate companion loans, which are not assets ofthe issuing entity. A *pari passu* portion of the loan combination wassecuritized in the CALI Mortgage Trust 2019-101C transaction (the “CALI2019-101C Transaction”). This loan combination, including the 101California Mortgage Loan, is being serviced and administered pursuant to thetrust and servicing agreement for the CALI 2019-101C Transaction, which isincorporated by reference as Exhibit 4.3 to this Annual Report on Form 10-K.

The Exhibit Index describes exhibits provided by certainparties (in their capacities indicated on the Exhibit Index) with respect tothe 3 Columbus Circle Mortgage Loan, which constituted approximately 9.1% ofthe asset pool of the issuing entity as of its cut-off date.  The 3Columbus Circle Mortgage Loan is an asset of the issuing entity and is part ofa loan combination that includes the 3 Columbus Circle Mortgage Loan, thirteenother *pari passu* loans and two subordinate companion loans, which arenot assets of the issuing entity. A *pari passu* portion of the loancombination was securitized in the Benchmark 2019-B10 Mortgage Trusttransaction, Commission File Number 333-226943-02 (the “Benchmark 2019-B10Transaction”). This loan combination, including the 3 Columbus CircleMortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the Benchmark 2019-B10 Transaction, which isincorporated by reference as Exhibit 4.4 to this Annual Report on Form 10-K.

The Heartland Dental Medical Office Portfolio Mortgage Loan,previously an asset of the issuing entity, was not an asset of the issuingentity during the reporting period and is omitted from this Annual Report onForm 10-K and will be omitted from subsequent Annual Reports on Form 10-K.

The Exhibit Index describes exhibits provided by certainparties (in their capacities indicated on the Exhibit Index) with respect tothe 59 Maiden Lane Mortgage Loan, the Arbor Hotel Portfolio Mortgage Loan, theMoffett Towers II - Building V Mortgage Loan and the Lakeside ApartmentsMortgage Loan, which constituted approximately 6.8%, 4.5%, 3.9% and 3.2%,respectively, of the asset pool of the issuing entity as of its cut-offdate.  The 59 Maiden Lane Mortgage Loan, the Arbor Hotel PortfolioMortgage Loan, the Moffett Towers II - Building V Mortgage Loan and theLakeside Apartments Mortgage Loan are each an asset of the issuing entity andare each part of a loan combination that includes (a) with respect to the 59 MaidenLane Mortgage Loan, two other *pari passu* loans, which are not assets ofthe issuing entity, (b) with respect to the Arbor Hotel Portfolio MortgageLoan, one other *pari passu* loan, which is not an asset of the issuingentity, (c) with respect to the Moffett Towers II - Building V Mortgage Loan,three other *pari passu* loans and four subordinate companion loans, whichare not assets of the issuing entity or (d) with respect to the LakesideApartments Mortgage Loan, one other *pari passu* loan, which is not anasset of the issuing entity. A *pari passu* portion of each loancombination was securitized in the GS Mortgage Securities Trust 2019-GC39transaction, Commission File Number 333-226082-02 (the “GSMS 2019-GC39Transaction”). These loan combinations, including the 59 Maiden LaneMortgage Loan, the Arbor Hotel Portfolio Mortgage Loan, the Moffett Towers II -Building V Mortgage Loan and the Lakeside Apartments Mortgage Loan, are beingserviced and administered pursuant to the pooling and servicing agreement forthe GSMS 2019-GC39 Transaction, which is incorporated by reference as Exhibit4.5 to this Annual Report on Form 10-K.

The Exhibit Index describes exhibits provided by certainparties (in their capacities indicated on the Exhibit Index) with respect to theNewport Corporate Center Mortgage Loan and the Central Tower Office MortgageLoan, which constituted approximately 3.7% and 3.1%, respectively, of the assetpool of the issuing entity as of its cut-off date.  The Newport CorporateCenter Mortgage Loan and the Central Tower Office Mortgage Loan are each anasset of the issuing entity and are each part of a loan combination thatincludes (a) with respect to the Newport Corporate Center Mortgage Loan, threeother *pari passu* loans and ten subordinate companion loans, which arenot assets of the issuing entity or (b) with respect to the Central TowerOffice Mortgage Loan, one other *pari passu* loan, which is not an assetof the issuing entity. A *pari passu* portion of each loan combination wassecuritized in the BANK 2019-BNK18 transaction, Commission File Number333-228375-01 (the “BANK 2019-BNK18 Transaction”). These loancombinations, including the Newport Corporate Center Mortgage Loan and theCentral Tower Office Mortgage Loan, are being serviced and administeredpursuant to the pooling and servicing agreement for the BANK 2019-BNK18Transaction, which is incorporated by reference as Exhibit 4.6 to this AnnualReport on Form 10-K.

The Exhibit Index describes exhibits provided by certainparties (in their capacities indicated on the Exhibit Index) with respect tothe SWVP Portfolio Mortgage Loan, which constituted approximately 4.5% of theasset pool of the issuing entity as of its cut-off date.  The SWVPPortfolio Mortgage Loan is an asset of the issuing entity and is part of a loancombination that includes the SWVP Portfolio Mortgage Loan and eight other *paripassu* loans, which are not assets of the issuing entity. A *pari passu*portion of the loan combination was securitized in the BBCMS Mortgage Trust2019-C3 transaction, Commission File Number 333-226850-02 (the “BBCMS2019-C3 Transaction”). This loan combination, including the SWVP PortfolioMortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the BBCMS 2019-C3 Transaction, which is incorporated byreference as Exhibit 4.7 to this Annual Report on Form 10-K.

The Exhibit Index describes exhibits provided by certainparties (in their capacities indicated on the Exhibit Index) with respect tothe 57 East 11th Street Mortgage Loan, which constituted approximately 1.8% ofthe asset pool of the issuing entity as of its cut-off date.  The 57 East11th Street Mortgage Loan is an asset of the issuing entity and is part of aloan combination that includes the 57 East 11th Street Mortgage Loan and twoother *pari passu* loans, which are not assets of the issuing entity. Thisloan combination, including the 57 East 11th Street Mortgage Loan, was servicedunder the pooling and servicing agreement for the GSMS 2019-GC39 Transactionprior to the closing of the securitization of a *pari passu* portion ofthe 57 East 11th Street loan combination in the GS Mortgage Securities Trust2019-GC40 transaction, Commission File Number 333-226082-03 (the “GSMS2019-GC40 Transaction”).  After the closing of the GSMS 2019-GC40Transaction on July 11, 2019, this loan combination, including the 57 East 11thStreet Mortgage Loan was, and will continue to be, serviced and administeredpursuant to the pooling and servicing agreement with respect to the GSMS2019-GC40 Transaction, which is incorporated by reference as Exhibit 4.8 tothis Annual Report on Form 10-K.

The master servicer of a pooling and servicing agreement ortrust and servicing agreement also functions as the primary servicer of therelated mortgage loans serviced and administered pursuant to such agreementunless a separate primary servicer is identified herein.  If this reportdoes not identify a separate primary servicer, the servicer compliancestatement provided by the master servicer under any such agreement alsoencompasses its responsibilities as primary servicer of the related mortgageloan or mortgage loans.

Midland Loan Services, a Division of PNC Bank, NationalAssociation is the master servicer of the mortgage loans serviced under thePooling and Servicing Agreement, the primary servicer of the 3 Columbus CircleMortgage Loan, the ILPT Hawaii Portfolio Mortgage Loan, the 59 Maiden LaneMortgage Loan, the Arbor Hotel Portfolio Mortgage Loan, the SWVP PortfolioMortgage Loan, the Moffett Towers II - Building V Mortgage Loan and the 57 East11th Street Mortgage Loan, the primary servicer and special servicer of the 101California Mortgage Loan and the special servicer of the SWVP PortfolioMortgage Loan prior to May 10, 2023. As a result, Midland Loan Services, aDivision of PNC Bank, National Association is a “servicer” as defined in Item1108(a)(2)(iii) of Regulation AB, in the capacities described above, because itis servicing mortgage loans that constituted 10% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria, accountants’ attestation reports and servicercompliance statements delivered by Midland Loan Services, a Division of PNCBank, National Association in the capacities described above are listed in theExhibit Index.

Rialto Capital Advisors, LLC is the special servicer of the mortgageloans serviced under the Pooling and Servicing Agreement, the ILPT HawaiiPortfolio Mortgage Loan and the Central Tower Office Mortgage Loan. As aresult, Rialto Capital Advisors, LLC is a “servicer” as defined in Item1108(a)(2)(iii) of Regulation AB, in the capacities described above, because itis servicing mortgage loans that constituted 10% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria, accountants’ attestation reports and servicercompliance statements delivered by Rialto Capital Advisors, LLC in thecapacities described above are listed in the Exhibit Index.

Wells Fargo Bank, National Association is the certificateadministrator of the mortgage loans serviced under the Pooling and ServicingAgreement and the primary servicer of the Newport Corporate Center MortgageLoan and the Central Tower Office Mortgage Loan. As a result, Wells Fargo Bank,National Association is a “servicer” as defined in Item 1108(a)(2)(iii) ofRegulation AB, in the capacities described above, because it is servicingmortgage loans that constituted 10% or more of the assets of the issuing entityas of its cut-off date. The assessments of compliance with applicable servicingcriteria, accountants’ attestation reports and servicer compliance statementsdelivered by Wells Fargo Bank, National Association in the capacities describedabove are listed in the Exhibit Index.

Wells Fargo Bank, National Association is the custodian ofthe mortgage loans serviced under the Pooling and Servicing Agreement, the 3Columbus Circle Mortgage Loan, the ILPT Hawaii Portfolio Mortgage Loan, the 59Maiden Lane Mortgage Loan, the SWVP Portfolio Mortgage Loan, the 101 CaliforniaMortgage Loan, the Arbor Hotel Portfolio Mortgage Loan, the Moffett Towers II -Building V Mortgage Loan, the Newport Corporate Center Mortgage Loan, theLakeside Apartments Mortgage Loan, the Central Tower Office Mortgage Loan andthe 57 East 11th Street Mortgage Loan.  As a result, Wells Fargo Bank,National Association is a servicing function participant in the capacitiesdescribed above, because it is servicing mortgage loans that constituted 5% ormore of the assets of the issuing entity as of its cut-off date. Theassessments of compliance with applicable servicing criteria and accountants’attestation reports delivered by Wells Fargo Bank, National Association in thecapacities described above are listed in the Exhibit Index.

Pentalpha Surveillance LLC is the operating advisor of themortgage loans serviced under the Pooling and Servicing Agreement, the 3Columbus Circle Mortgage Loan, the SWVP Portfolio Mortgage Loan, the 101California Mortgage Loan, the Newport Corporate Center Mortgage Loan, theCentral Tower Office Mortgage Loan and the 57 East 11th Street MortgageLoan.  As a result, Pentalpha Surveillance LLC is a servicing functionparticipant in the capacities described above, because it is servicing mortgageloans that constituted 5% or more of the assets of the issuing entity as of itscut-off date. The assessments of compliance with applicable servicing criteriaand accountants’ attestation reports delivered by Pentalpha Surveillance LLC inthe capacities described above are listed in the Exhibit Index.

Park Bridge Lender Services LLC is the operating advisor ofthe ILPT Hawaii Portfolio Mortgage Loan, the 59 Maiden Lane Mortgage Loan, theArbor Hotel Portfolio Mortgage Loan, the Moffett Towers II - Building VMortgage Loan and the Lakeside Apartments Mortgage Loan.  As a result,Park Bridge Lender Services LLC is a servicing function participant in thecapacities described above, because it is servicing mortgage loans thatconstituted 5% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria andaccountants’ attestation reports delivered by Park Bridge Lender Services LLCin the capacities described above are listed in the Exhibit Index.

LNR Partners, LLC is the special servicer of the 3 ColumbusCircle Mortgage Loan and the 57 East 11th Street Mortgage Loan. As a result,LNR Partners, LLC is a “servicer” as defined in Item 1108(a)(2)(iii) ofRegulation AB, in the capacities described above, because it is servicingmortgage loans that constituted 10% or more of the assets of the issuing entityas of its cut-off date. The assessments of compliance with applicable servicingcriteria, accountants’ attestation reports and servicer compliance statementsdelivered by LNR Partners, LLC in the capacities described above are listed inthe Exhibit Index.

KeyBank National Association is the special servicer of the59 Maiden Lane Mortgage Loan, the Arbor Hotel Portfolio Mortgage Loan, theMoffett Towers II - Building V Mortgage Loan and the Lakeside Apartments MortgageLoan. As a result, KeyBank 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 KeyBank National Association inthe capacities described above are listed in the Exhibit Index.

Wells Fargo Bank, National Association acts as trustee of theGreen Hills Corporate Center Mortgage Loan, the Western Digital R&D CampusMortgage Loan, the Greenleaf at Howell Mortgage Loan, the ILPT Hawaii PortfolioMortgage Loan, the 101 California Mortgage Loan, the 3 Columbus Circle MortgageLoan, the 59 Maiden Lane Mortgage Loan, the Arbor Hotel Portfolio MortgageLoan, the Moffett Towers II - Building V Mortgage Loan, the Lakeside ApartmentsMortgage Loan, the SWVP Portfolio Mortgage Loan and the 57 East 11th StreetMortgage Loan.  Pursuant to the Pooling and Servicing Agreement, the trustand servicing agreement for the ILPT 2019-SURF Transaction, the trust andservicing agreement for the CALI 2019-101C Transaction, the pooling and servicingagreement for the Benchmark 2019-B10 Transaction, the pooling and servicingagreement for the GSMS 2019-GC39 Transaction, the pooling and servicingagreement for the BBCMS 2019-C3 Transaction and the pooling and servicingagreement for the GSMS 2019-GC40 Transaction, the trustee is required toprovide an assessment of compliance with applicable servicing criteria solelywith respect to Item 1122(d)(2)(iii) of Regulation AB (regarding advances offunds or guarantees regarding collections, cash flows or distributions, and anyinterest or other fees charged for such advances, are made, reviewed andapproved as specified in the transaction agreements). However, during thereporting period, the trustee did not perform any servicing function withrespect to the servicing criteria specified in Item 1122(d)(2)(iii) ofRegulation AB.  The master servicer or the special servicer, to the extentrequired, performed the servicing function identified with respect to Item1122(d)(2)(iii) of Regulation AB, and each such party included Item1122(d)(2)(iii) of Regulation AB in the assessment of compliance withapplicable 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 Green Hills Corporate CenterMortgage Loan, the Western Digital R&D Campus Mortgage Loan, the Greenleafat Howell Mortgage Loan, the ILPT Hawaii Portfolio Mortgage Loan, the 101California Mortgage Loan, the 3 Columbus Circle Mortgage Loan, the 59 MaidenLane Mortgage Loan, the Arbor Hotel Portfolio Mortgage Loan, the Moffett TowersII - Building V Mortgage Loan, the Lakeside Apartments Mortgage Loan, the SWVPPortfolio Mortgage Loan and the 57 East 11th Street Mortgage Loan havedelivered one or more assessments of compliance with respect to Item1122(d)(2)(iii) of Regulation AB.

Wilmington Trust, National Association acts as trustee of theNewport Corporate Center Mortgage Loan and the Central Tower Office MortgageLoan.  Pursuant to the pooling and servicing agreement for the BANK2019-BNK18 Transaction, the trustee is required to provide an assessment ofcompliance with applicable servicing criteria solely with respect to Item1122(d)(2)(iii) of Regulation AB (regarding advances of funds or guaranteesregarding collections, cash flows or distributions, and any interest or otherfees charged for such advances, are made, reviewed and approved as specified inthe transaction agreements). However, during the reporting period, the trusteedid not 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 of theNewport Corporate Center Mortgage Loan and the Central Tower Office MortgageLoan have delivered one or more assessments of compliance with respect to Item1122(d)(2)(iii) of Regulation AB.

This Annual Report on Form 10-K includes assessments ofcompliance with applicable servicing criteria and accountants’ attestationreports from CoreLogic Solutions, LLC.  This entity was engaged by theprimary servicer of the Newport Corporate Center Mortgage Loan and the CentralTower Office Mortgage Loan to remit tax payments received from the escrowaccounts of borrowers to local taxing authorities, to report tax amounts due,to verify tax parcel information, and to verify non-escrow tax payments. Theseservicing functions are included within the servicing criteria set forth inItems 1122(d)(4)(xi) and 1122(d)(4)(xii) of Regulation AB.  Therefore,under the principles-based definition of “servicer” set forth in Item 1101(j)of Regulation AB that looks to the functions that an entity performs, thisvendor is 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) ofRegulation AB that looks to the functions that an entity performs, this partyis a “servicer” for the purposes of Item 1123 of Regulation AB.  *See*Compliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

The assessments of compliance with applicable servicingcriteria, accountants’ attestation reports and servicer compliance statementsof the certificate administrator of the ILPT Hawaii Portfolio Mortgage Loan,the 101 California Mortgage Loan, the 3 Columbus Circle Mortgage Loan, the 59Maiden Lane Mortgage Loan, the Arbor Hotel Portfolio Mortgage Loan, the MoffettTowers II - Building V Mortgage Loan, the Lakeside Apartments Mortgage Loan,the Newport Corporate Center Mortgage Loan, the Central Tower Office MortgageLoan, the SWVP Portfolio Mortgage Loan and the 57 East 11th Street MortgageLoan are omitted from this Annual Report on Form 10-K as the certificateadministrator pursuant to the related pooling and servicing agreement or trustand servicing agreement does not perform any activities that address servicingcriteria with respect to the issuing entity and because they are each not a“servicer” that meets the criteria in Item 1108(a)(2)(i) through (iii) ofRegulation AB.

With respect to the *pari passu* loan combinations thatinclude the Lakeside Apartments Mortgage Loan, the Newport Corporate CenterMortgage Loan and the SWVP Portfolio Mortgage Loan, (i) the reports onassessment of compliance with servicing criteria and attestation reports onassessment of compliance with servicing criteria of Berkadia CommercialMortgage LLC as primary servicer of the Lakeside Apartments Mortgage Loan,Situs Holdings, LLC as special servicer of the Newport Corporate CenterMortgage Loan and K-Star Asset Management LLC as special servicer of the SWVPPortfolio Mortgage Loan on and after May 10, 2023, listed on the Exhibit Indexare omitted from this Annual Report on Form 10-K as they are not required to beincluded on this Annual Report on Form 10-K per Instruction 3 to Item 1122 ofRegulation AB because they are parties performing activities that addressservicing criteria relating to 5% or less of the assets of the issuing entity; and(ii) the servicer compliance statements of Berkadia Commercial Mortgage LLC asprimary servicer of the Lakeside Apartments Mortgage Loan, Situs Holdings, LLCas special servicer of the Newport Corporate Center Mortgage Loan and K-StarAsset Management LLC as special servicer of the SWVP Portfolio Mortgage Loan onand after May 10, 2023, listed on the Exhibit Index are omitted from thisAnnual Report on Form 10-K as they are not required by Item 1123 of RegulationAB to be included on this Annual Report on Form 10-K because they are each anunaffiliated party that is not a “servicer” that meets the criteria in Item1108(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 1C.  Cybersecurity.**

Omitted.

**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.  [Reserved]**

**Item 7.  Management’s Discussion and Analysis ofFinancial Condition and Results of Operations.**

Omitted.

**Item 7A.  Quantitative and Qualitative DisclosuresAbout Market Risk.**

Omitted.

**Item 8.  Financial Statements and Supplementary Data.**

Omitted.

**Item 9.  Changes in and Disagreements WithAccountants on Accounting and Financial Disclosure.**

Omitted.

**Item 9A.  Controls and Procedures.**

Omitted.

**Item 9B.  Other Information.**

None.

**Item 9C.  Disclosure Regarding Foreign Jurisdictionsthat Prevent Inspections.**

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 Accountant 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 assets heldby 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, ascertificate administrator, as trustee and as custodian.

In December 2014, Phoenix Light SF Limited (Phoenix Light)and certain related entities filed a complaint in the United States DistrictCourt for the Southern District of New York alleging claims against Wells FargoBank, N.A., in its capacity as trustee for a number of residentialmortgage-backed securities (RMBS) trusts. Complaints raising similarallegations have been filed by Commerzbank AG in the Southern District of NewYork, IKB International and IKB Deutsche Industriebank (together, IKB) in NewYork state court, and Park Royal I LLC and Park Royal II LLC in New York statecourt. In each case, the plaintiffs allege that Wells Fargo Bank, N.A., astrustee, caused losses to investors, and plaintiffs assert causes of actionbased upon, among other things, the trustee’s alleged failure to notify andenforce repurchase obligations of mortgage loan sellers for purported breachesof representations and warranties, notify investors of alleged events ofdefault, and abide by appropriate standards of care following alleged events ofdefault. In July 2022, the district court dismissed Phoenix Light’s claims andcertain of the claims asserted by Commerzbank AG, and subsequently enteredjudgment in each case in favor of Wells Fargo Bank, N.A. In August 2022,Phoenix Light and Commerzbank AG each appealed the district court’s decision tothe United States Court of Appeals for the Second Circuit. Phoenix Lightdismissed its appeal in May 2023, terminating its case. In November 2023, WellsFargo Bank, N.A. entered into an agreement with IKB to resolve IKB’s claims.Wells Fargo Bank, N.A. previously settled two class actions filed byinstitutional investors and an action filed by the National Credit UnionAdministration with similar allegations. 

**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 June 17, 2019 pursuant to Rule 424(b)(2).

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

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

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the 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 101 California Mortgage Loan,which is being serviced and administered pursuant to the trust and servicingagreement for the CALI 2019-101C Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit L to the trust andservicing agreement for the CALI 2019-101C Transaction incorporated byreference as Exhibit 4.3 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the CALI2019-101C 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 3 Columbus Circle Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the Benchmark 2019-B10 Transaction, are attached hereto underItem 15 to this Annual Report on Form 10-K. Attached as Schedule II to thepooling and servicing agreement for the Benchmark 2019-B10 Transactionincorporated by reference as Exhibit 4.4 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theBenchmark 2019-B10 Transaction responsible for each applicable servicingcriteria 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 59 Maiden Lane Mortgage Loan, theArbor Hotel Portfolio Mortgage Loan, the Moffett Towers II - Building VMortgage Loan and the Lakeside Apartments Mortgage Loan, which are beingserviced and administered pursuant to the pooling and servicing agreement forthe GSMS 2019-GC39 Transaction, are attached hereto under Item 15 to thisAnnual Report on Form 10-K. Attached as Exhibit AA to the pooling and servicingagreement for the GSMS 2019-GC39 Transaction incorporated by reference as Exhibit4.5 to this Annual Report on Form 10-K is a chart identifying the entitiesparticipating in a servicing function for the GSMS 2019-GC39 Transactionresponsible for each applicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Newport Corporate Center MortgageLoan and the Central Tower Office Mortgage Loan, which are being serviced andadministered pursuant to the pooling and servicing agreement for the BANK2019-BNK18 Transaction, are attached hereto under Item 15 to this Annual Reporton Form 10-K. Attached as Exhibit Z to the pooling and servicing agreement forthe BANK 2019-BNK18 Transaction incorporated by reference as Exhibit 4.6 tothis Annual Report on Form 10-K is a chart identifying the entitiesparticipating in a servicing function for the BANK 2019-BNK18 Transactionresponsible for each applicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the SWVP Portfolio Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the BBCMS 2019-C3 Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit AA to the pooling andservicing agreement for the BBCMS 2019-C3 Transaction incorporated by referenceas Exhibit 4.7 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the BBCMS 2019-C3Transaction responsible for each applicable servicing criteria set forth inItem 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the 57 East 11th Street MortgageLoan, which is being serviced and administered pursuant to the pooling andservicing agreement for the GSMS 2019-GC40 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit AA to thepooling and servicing agreement for the GSMS 2019-GC40 Transaction incorporatedby reference as Exhibit 4.8 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the GSMS2019-GC40 Transaction responsible for each applicable servicing criteria setforth 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. Exhibit and Financial Statement Schedules**

(a) The following is a list of documents filed as part ofthis Annual Report on Form 10-K:

(1) Not applicable

(2) Not applicable

(3) See below

4.1          Pooling and Servicing Agreement, dated as of June 1,2019, by and among J.P. Morgan Chase Commercial Mortgage Securities Corp., asDepositor, Midland Loan Services, a Division of PNC Bank, National Association,as Master Servicer, Rialto Capital Advisors, LLC, as Special Servicer, WellsFargo Bank, National Association, as Certificate Administrator, Wells FargoBank, National Association, as Trustee, and Pentalpha Surveillance LLC, asOperating Advisor and Asset Representations Reviewer (filed as Exhibit 4.1 tothe registrant’s Current Report on Form 8-K filed on June 17, 2019 underCommission File No. 333-226123-03 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 Trustee, and ParkBridge Lender Services LLC, as Operating Advisor (filed as Exhibit 4.3 to theregistrant’s Current Report on Form 8-K filed on June 17, 2019 under CommissionFile No. 333-226123-03 and incorporated by reference herein).

4.3          Trust and Servicing Agreement, dated as of March 6, 2019,by and among GS Mortgage Securities Corporation II, as Depositor, Midland LoanServices, a Division of PNC Bank, National Association, as Servicer, MidlandLoan Services, a Division of PNC Bank, National Association, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administrator,Custodian and Trustee, and Pentalpha Surveillance LLC, as Operating Advisor(filed as Exhibit 4.5 to the registrant’s Current Report on Form 8-K filed onJune 17, 2019 under Commission File No. 333-226123-03 and incorporated byreference herein).

4.4          Pooling and Servicing Agreement, dated as of April 1,2019, by and among Deutsche Mortgage & Asset Receiving Corporation, asDepositor, KeyBank National Association, as Master Servicer, LNR Partners, LLC,as Special Servicer, Wells Fargo Bank, National Association, as Trustee,Certificate Administrator, Paying Agent and Custodian, and PentalphaSurveillance LLC, as Operating Advisor and Asset Representations Reviewer(filed as Exhibit 4.2 to the registrant’s Current Report on Form 8-K filed onJune 17, 2019 under Commission File No. 333-226123-03 and incorporated byreference herein).

4.5          Pooling and Servicing Agreement, dated as of May 1, 2019,by and among GS Mortgage Securities Corporation II, as Depositor, Midland LoanServices, a Division of PNC Bank, National Association, as Master Servicer,KeyBank National Association, as Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator and as Trustee, and Park BridgeLender Services LLC, as Operating Advisor and as Asset Representations Reviewer(filed as Exhibit 4.4 to the registrant’s Current Report on Form 8-K filed onJune 17, 2019 under Commission File No. 333-226123-03 and incorporated byreference herein).

4.6          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 NCB Special Servicer, Situs Holdings,LLC, as Newport Corporate Center 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 4.7 to the registrant’sCurrent Report on Form 8-K filed on June 17, 2019 under Commission File No.333-226123-03 and incorporated by reference herein).

4.7          Pooling and Servicing Agreement, dated as of June 1,2019, by and among Barclays Commercial Mortgage Securities LLC, as Depositor,Midland Loan Services, a Division of PNC Bank, National Association, as MasterServicer, Midland Loan Services, a Division of PNC Bank, National Association,as Special Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator, Wells Fargo Bank, National Association, as Trustee, andPentalpha Surveillance LLC, as Operating Advisor and Asset RepresentationsReviewer (filed as Exhibit 4.6 to the registrant’s Current Report on Form 8-Kfiled on June 17, 2019 under Commission File No. 333-226123-03 and incorporatedby reference herein).

4.8          Pooling and Servicing Agreement, dated as of July 1,2019, by and among GS Mortgage Securities Corporation II, as Depositor, MidlandLoan Services, a Division of PNC Bank, National Association, as Master Servicerand Special Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator and 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 July 12, 2019 under Commission File No.333-226123-03 and incorporated by reference herein).

4.9          Agreement Between Noteholders, dated as of March 13,2019, by and between, JPMorgan Chase Bank, National Association, as InitialNote A-1-1 Holder, Initial Note A-1-2 Holder, Initial Note A-1-3 Holder,Initial Note A-1-4 Holder, Initial Note A-1-5 Holder, Initial Note A-1-6Holder, Initial Note A-1-7 Holder and Initial Note A-1-8 Holder, Deutsche BankAG, acting through its New York Branch, as Note A-2-1 Holder, Note A-2-2Holder, Note A-2-3 Holder, Note A-2-4 Holder and Note A-2-5 Holder, JPMorganChase Bank, National Association, as Initial Note B-1 Holder, and Deutsche BankAG, acting through its New York Branch, as Note B-2 Holder (filed as Exhibit4.9 to the registrant’s Current Report on Form 8-K filed on June 17, 2019 underCommission File No. 333-226123-03 and incorporated by reference herein).

4.10         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, JPMorgan Chase Bank, NationalAssociation, as Initial Note A-4 Holder, Initial Note A-8-1 Holder and InitialNote A-8-2 Holder (filed as Exhibit 4.10 to the registrant’s Current Report onForm 8-K filed on June 17, 2019 under Commission File No. 333-226123-03 andincorporated by reference herein).

4.11         Agreement Between Note Holders, dated as of April 11,2019, by and between Citi Real Estate Funding Inc., as Initial Note A-1 Holder,Citi Real Estate Funding Inc., as Initial Note A-2 Holder, and Citi Real EstateFunding Inc., as Initial Note A-3 Holder (filed as Exhibit 4.11 to theregistrant’s Current Report on Form 8-K filed on June 17, 2019 under CommissionFile No. 333-226123-03 and incorporated by reference herein).

4.12         Amended and Restated Co-Lender Agreement, dated as of May3, 2019, by and among, Wells Fargo Bank, National Association, as Trustee forthe Benefit of the Registered Holders of the CALI 2019-101C Mortgage Trust,Commercial Mortgage Pass-Through Certificates, Series 2019-101C, as Note A-1Holder, Note A-2 Holder, Note B-1 Holder and Note B-2 Holder, Wells Fargo Bank,National Association, as Trustee for the Benefit of the Registered Holders ofthe Benchmark 2019-B10 Mortgage Trust, Commercial Mortgage Pass-ThroughCertificates, Series 2019-B10, as Note A-8 Holder and Note A-9 Holder, GoldmanSachs Mortgage Company, as Initial Note A-3 Holder, Initial Note A-4 Holder andInitial Note A-5 Holder, and JPMorgan Chase Bank, National Association, asInitial Note A-6 Holder and Initial Note A-7 Holder (filed as Exhibit 4.12 tothe registrant’s Current Report on Form 8-K filed on June 17, 2019 underCommission File No. 333-226123-03 and incorporated by reference herein).

4.13         Co-Lender Agreement, dated as of June 11, 2019, by andbetween Societe Generale Financial Corporation and JPMorgan Chase Bank,National Association (filed as Exhibit 4.13 to the registrant’s Current Reporton Form 8-K filed on June 17, 2019 under Commission File No. 333-226123-03 andincorporated by reference herein).

4.14         Co-Lender Agreement, dated as of April 17, 2019, by andbetween Citi Real Estate Funding Inc., as Initial Note A-1 Holder, and CitiReal Estate Funding Inc., as Initial Note A-2 Holder (filed as Exhibit 4.14 tothe registrant’s Current Report on Form 8-K filed on June 17, 2019 underCommission File No. 333-226123-03 and incorporated by reference herein).

4.15         Co-Lender Agreement, dated as of June 17, 2019, by andbetween Citi Real Estate Funding Inc., as Initial Note A-1 Holder, and CitiReal Estate Funding Inc., as Initial Note A-2 Holder (filed as Exhibit 4.15 tothe registrant’s Current Report on Form 8-K filed on June 17, 2019 underCommission File No. 333-226123-03 and incorporated by reference herein).

4.16         Agreement Between Noteholders, dated as of March 8, 2019,by and between Goldman Sachs Bank USA, as Initial Note A-2 Holder, Initial NoteA-3 Holder, Initial Note A-4 Holder, Initial Note B-2 Holder and Initial NoteC-2 Holder, and Deutsche Bank AG, New York Branch, as Initial Note A-1 Holder,Initial Note B-1 Holder and Initial Note C-1 Holder (filed as Exhibit 4.16 tothe registrant’s Current Report on Form 8-K filed on June 17, 2019 underCommission File No. 333-226123-03 and incorporated by reference herein).

4.17         Agreement Between Noteholders, 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, as Initial Note A-2-A Holder, Initial Note A-2-B Holder, InitialNote A-2-C Holder, Initial Note B-2-A Holder, Initial Note B-2-B Holder,Initial Note C-2-A Holder, Initial Note C-2-B Holder and Initial Note D-2 Holder(filed as Exhibit 4.17 to the registrant’s Current Report on Form 8-K filed onJune 17, 2019 under Commission File No. 333-226123-03 and incorporated byreference herein).

4.18         Co-Lender Agreement, dated as of June 17, 2019, by andbetween Citi Real Estate Funding Inc., as Initial Note A-1 Holder, and CitiReal Estate Funding Inc., as Initial Note A-2 Holder (filed as Exhibit 4.18 tothe registrant’s Current Report on Form 8-K filed on June 17, 2019 underCommission File No. 333-226123-03 and incorporated by reference herein).

4.19         Co-Lender Agreement, dated as of March 1, 2019, by andbetween Citi Real Estate Funding Inc., as Initial Note A-1 Holder, and CitiReal Estate Funding Inc., as Initial Note A-2 Holder (filed as Exhibit 4.19 tothe registrant’s Current Report on Form 8-K filed on June 17, 2019 underCommission File No. 333-226123-03 and incorporated by reference herein).

4.20         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 Exhibit4.20 to the registrant’s Current Report on Form 8-K filed on June 17, 2019under Commission File No. 333-226123-03 and incorporated by reference herein).

4.21         Co-Lender Agreement, dated as of June 17, 2019, by andbetween JPMorgan Chase Bank, National Association, as Initial Note A-1 Holder,and JPMorgan Chase Bank, National Association, as Initial Note A-2 Holder(filed as Exhibit 4.21 to the registrant’s Current Report on Form 8-K filed onJune 17, 2019 under Commission File No. 333-226123-03 and incorporated byreference herein).

4.22         Co-Lender Agreement, dated as of May 15, 2019, by andbetween Citi Real Estate Funding Inc., as Initial Note A-1 Holder, Citi RealEstate Funding Inc., as Initial Note A-2 Holder, and Citi Real Estate FundingInc., as Initial Note A-3 Holder (filed as Exhibit 4.22 to the registrant’sCurrent Report on Form 8-K filed on June 17, 2019 under Commission File No.333-226123-03 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        Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer

33.2        Rialto Capital Advisors, LLC, as Special Servicer

33.3        Wells Fargo Bank, National Association, as Trusteeand Certificate Administrator

33.4        Wells Fargo Bank, National Association, asCustodian

33.5        Pentalpha Surveillance LLC, as Operating Advisor

33.6        Situs Real LLC, as EU Reporting Administrator

33.7        Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator

33.8        Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian

33.9        Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Green Hills Corporate CenterMortgage Loan (see Exhibit 33.1)

33.10      Rialto Capital Advisors, LLC, as Special Servicerof the Green Hills Corporate Center Mortgage Loan (see Exhibit 33.2)

33.11      Wells Fargo Bank, National Association, as Trustee of the Green Hills CorporateCenter Mortgage Loan (Omitted. See Explanatory Notes.)

33.12      Wells Fargo Bank, National Association, asCustodian of the Green Hills Corporate Center Mortgage Loan (see Exhibit 33.4)

33.13      Pentalpha Surveillance LLC, as Operating Advisor ofthe Green Hills Corporate Center Mortgage Loan (see Exhibit 33.5)

33.14      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.8)

33.15      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Western Digital R&D CampusMortgage Loan (see Exhibit 33.1)

33.16      Rialto Capital Advisors, LLC, as Special Servicerof the Western Digital R&D Campus Mortgage Loan (see Exhibit 33.2)

33.17      Wells Fargo Bank, National Association, as Trustee of the Western DigitalR&D Campus Mortgage Loan (Omitted. See Explanatory Notes.)

33.18      Wells Fargo Bank, National Association, asCustodian of the Western Digital R&D Campus Mortgage Loan (see Exhibit33.4)

33.19      Pentalpha Surveillance LLC, as Operating Advisor ofthe Western Digital R&D Campus Mortgage Loan (see Exhibit 33.5)

33.20      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.8)

33.21      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Greenleaf at Howell MortgageLoan (see Exhibit 33.1)

33.22      Rialto Capital Advisors, LLC, as Special Servicerof the Greenleaf at Howell Mortgage Loan (see Exhibit 33.2)

33.23      Wells Fargo Bank, National Association, as Trustee of the Greenleaf at HowellMortgage Loan (Omitted. See Explanatory Notes.)

33.24      Wells Fargo Bank, National Association, asCustodian of the Greenleaf at Howell Mortgage Loan (see Exhibit 33.4)

33.25      Pentalpha Surveillance LLC, as Operating Advisor ofthe Greenleaf at Howell Mortgage Loan (see Exhibit 33.5)

33.26      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.8)

33.27      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the ILPT Hawaii Portfolio MortgageLoan (see Exhibit 33.1)

33.28      Rialto Capital Advisors, LLC, as Special Servicerof the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 33.2)

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

33.30      Wells Fargo Bank, National Association, asCustodian of the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 33.4)

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

33.32      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.8)

33.33      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 101 California Mortgage Loan(see Exhibit 33.1)

33.34      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the 101 California Mortgage Loan(see Exhibit 33.1)

33.35      Wells Fargo Bank, National Association, as Trustee of the 101 CaliforniaMortgage Loan (Omitted. See Explanatory Notes.)

33.36      Wells Fargo Bank, National Association, asCustodian of the 101 California Mortgage Loan (see Exhibit 33.4)

33.37      Pentalpha Surveillance LLC, as Operating Advisor ofthe 101 California Mortgage Loan (see Exhibit 33.5)

33.38      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.8)

33.39      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 3 Columbus Circle MortgageLoan (see Exhibit 33.1)

33.40      LNR Partners, LLC, as Special Servicer of the 3Columbus Circle Mortgage Loan

33.41      Wells Fargo Bank, National Association, as Trustee of the 3 Columbus CircleMortgage Loan (Omitted. See Explanatory Notes.)

33.42      Wells Fargo Bank, National Association, asCustodian of the 3 Columbus Circle Mortgage Loan (see Exhibit 33.4)

33.43      Pentalpha Surveillance LLC, as Operating Advisor ofthe 3 Columbus Circle Mortgage Loan (see Exhibit 33.5)

33.44      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.8)

33.45       Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 59 Maiden Lane Mortgage Loan(see Exhibit 33.1)

33.46      KeyBank National Association, as Special Servicerof the 59 Maiden Lane Mortgage Loan

33.47      Wells Fargo Bank, National Association, as Trustee of the 59 Maiden LaneMortgage Loan (Omitted. See Explanatory Notes.)

33.48      Wells Fargo Bank, National Association, asCustodian of the 59 Maiden Lane Mortgage Loan (see Exhibit 33.4)

33.49      Park Bridge Lender Services LLC, as OperatingAdvisor of the 59 Maiden Lane Mortgage Loan (see Exhibit 33.31)

33.50      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.8)

33.51      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Arbor Hotel Portfolio MortgageLoan (see Exhibit 33.1)

33.52      KeyBank National Association, as Special Servicerof the Arbor Hotel Portfolio Mortgage Loan (see Exhibit 33.46)

33.53      Wells Fargo Bank, National Association, as Trustee of the Arbor Hotel PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.54      Wells Fargo Bank, National Association, asCustodian of the Arbor Hotel Portfolio Mortgage Loan (see Exhibit 33.4)

33.55      Park Bridge Lender Services LLC, as OperatingAdvisor of the Arbor Hotel Portfolio Mortgage Loan (see Exhibit 33.31)

33.56      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.8)

33.57      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Moffett Towers II - Building VMortgage Loan (see Exhibit 33.1)

33.58      KeyBank National Association, as Special Servicerof the Moffett Towers II - Building V Mortgage Loan (see Exhibit 33.46)

33.59      Wells Fargo Bank, National Association, as Trustee of the Moffett Towers II -Building V Mortgage Loan (Omitted. See Explanatory Notes.)

33.60      Wells Fargo Bank, National Association, asCustodian of the Moffett Towers II - Building V Mortgage Loan (see Exhibit33.4)

33.61      Park Bridge Lender Services LLC, as OperatingAdvisor of the Moffett Towers II - Building V Mortgage Loan (see Exhibit 33.31)

33.62      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.8)

33.63      Berkadia Commercial Mortgage LLC, as Primary Servicer of the LakesideApartments Mortgage Loan (Omitted. See Explanatory Notes.) 

33.64      KeyBank National Association, as Special Servicerof the Lakeside Apartments Mortgage Loan (see Exhibit 33.46)

33.65      Wells Fargo Bank, National Association, as Trustee of the Lakeside ApartmentsMortgage Loan (Omitted. See Explanatory Notes.)

33.66      Wells Fargo Bank, National Association, asCustodian of the Lakeside Apartments Mortgage Loan (see Exhibit 33.4)

33.67      Park Bridge Lender Services LLC, as OperatingAdvisor of the Lakeside Apartments Mortgage Loan (see Exhibit 33.31)

33.68      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.8)

33.69      Wells Fargo Bank, National Association, as PrimaryServicer of the Newport Corporate Center Mortgage Loan

33.70      Situs Holdings, LLC, as Special Servicer of the Newport Corporate CenterMortgage Loan (Omitted. See Explanatory Notes.)

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

33.72      Wells Fargo Bank, National Association, asCustodian of the Newport Corporate Center Mortgage Loan (see Exhibit 33.4)

33.73      Pentalpha Surveillance LLC, as Operating Advisor ofthe Newport Corporate Center Mortgage Loan (see Exhibit 33.5)

33.74      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Newport Corporate Center Mortgage Loan

33.75      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.8)

33.76      Wells Fargo Bank, National Association, as PrimaryServicer of the Central Tower Office Mortgage Loan (see Exhibit 33.69)

33.77      Rialto Capital Advisors, LLC, as Special Servicerof the Central Tower Office Mortgage Loan (see Exhibit 33.2)

33.78      Wilmington Trust, National Association, as Trustee of the Central Tower OfficeMortgage Loan (Omitted. See Explanatory Notes.)

33.79      Wells Fargo Bank, National Association, asCustodian of the Central Tower Office Mortgage Loan (see Exhibit 33.4)

33.80      Pentalpha Surveillance LLC, as Operating Advisor ofthe Central Tower Office Mortgage Loan (see Exhibit 33.5)

33.81      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Central Tower Office Mortgage Loan (see Exhibit 33.74)

33.82      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.8)

33.83      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the SWVP Portfolio Mortgage Loan(see Exhibit 33.1)

33.84      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the SWVP Portfolio Mortgage Loanprior to May 10, 2023 (see Exhibit 33.1)

33.85      K-Star Asset Management LLC, as Special Servicer of the SWVP Portfolio MortgageLoan on and after May 10, 2023 (Omitted. See Explanatory Notes.)

33.86      Wells Fargo Bank, National Association, as Trustee of the SWVP PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.87      Wells Fargo Bank, National Association, asCustodian of the SWVP Portfolio Mortgage Loan (see Exhibit 33.4)

33.88      Pentalpha Surveillance LLC, as Operating Advisor ofthe SWVP Portfolio Mortgage Loan (see Exhibit 33.5)

33.89      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.8)

33.90      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 57 East 11th Street MortgageLoan (see Exhibit 33.1)

33.91      LNR Partners, LLC, as Special Servicer of the 57East 11th Street Mortgage Loan (see Exhibit 33.40)

33.92      Wells Fargo Bank, National Association, as Trustee of the 57 East 11th StreetMortgage Loan (Omitted. See Explanatory Notes.)

33.93      Wells Fargo Bank, National Association, asCustodian of the 57 East 11th Street Mortgage Loan (see Exhibit 33.4)

33.94      Pentalpha Surveillance LLC, as Operating Advisor ofthe 57 East 11th Street Mortgage Loan (see Exhibit 33.5)

33.95      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.8)

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

34.1        Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer

34.2        Rialto Capital Advisors, LLC, as Special Servicer

34.3        Wells Fargo Bank, National Association, as Trusteeand Certificate Administrator

34.4        Wells Fargo Bank, National Association, asCustodian

34.5        Pentalpha Surveillance LLC, as Operating Advisor

34.6        Situs Real LLC, as EU Reporting Administrator

34.7        Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator

34.8        Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian

34.9        Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Green Hills Corporate CenterMortgage Loan (see Exhibit 34.1)

34.10      Rialto Capital Advisors, LLC, as Special Servicerof the Green Hills Corporate Center Mortgage Loan (see Exhibit 34.2)

34.11      Wells Fargo Bank, National Association, as Trustee of the Green Hills CorporateCenter Mortgage Loan (Omitted. See Explanatory Notes.)

34.12      Wells Fargo Bank, National Association, asCustodian of the Green Hills Corporate Center Mortgage Loan (see Exhibit 34.4)

34.13      Pentalpha Surveillance LLC, as Operating Advisor ofthe Green Hills Corporate Center Mortgage Loan (see Exhibit 34.5)

34.14      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.8)

34.15      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Western Digital R&D CampusMortgage Loan (see Exhibit 34.1)

34.16      Rialto Capital Advisors, LLC, as Special Servicerof the Western Digital R&D Campus Mortgage Loan (see Exhibit 34.2)

34.17      Wells Fargo Bank, National Association, as Trustee of the Western DigitalR&D Campus Mortgage Loan (Omitted. See Explanatory Notes.)

34.18      Wells Fargo Bank, National Association, asCustodian of the Western Digital R&D Campus Mortgage Loan (see Exhibit34.4)

34.19      Pentalpha Surveillance LLC, as Operating Advisor ofthe Western Digital R&D Campus Mortgage Loan (see Exhibit 34.5)

34.20      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.8)

34.21      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Greenleaf at Howell MortgageLoan (see Exhibit 34.1)

34.22      Rialto Capital Advisors, LLC, as Special Servicerof the Greenleaf at Howell Mortgage Loan (see Exhibit 34.2)

34.23      Wells Fargo Bank, National Association, as Trustee of the Greenleaf at HowellMortgage Loan (Omitted. See Explanatory Notes.)

34.24      Wells Fargo Bank, National Association, asCustodian of the Greenleaf at Howell Mortgage Loan (see Exhibit 34.4)

34.25      Pentalpha Surveillance LLC, as Operating Advisor ofthe Greenleaf at Howell Mortgage Loan (see Exhibit 34.5)

34.26      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.8)

34.27      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the ILPT Hawaii Portfolio MortgageLoan (see Exhibit 34.1)

34.28      Rialto Capital Advisors, LLC, as Special Servicerof the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 34.2)

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

34.30      Wells Fargo Bank, National Association, asCustodian of the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 34.4)

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

34.32      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.8)

34.33      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 101 California Mortgage Loan(see Exhibit 34.1)

34.34      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the 101 California Mortgage Loan(see Exhibit 34.1)

34.35      Wells Fargo Bank, National Association, as Trustee of the 101 CaliforniaMortgage Loan (Omitted. See Explanatory Notes.)

34.36      Wells Fargo Bank, National Association, as Custodianof the 101 California Mortgage Loan (see Exhibit 34.4)

34.37      Pentalpha Surveillance LLC, as Operating Advisor ofthe 101 California Mortgage Loan (see Exhibit 34.5)

34.38      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.8)

34.39      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 3 Columbus Circle MortgageLoan (see Exhibit 34.1)

34.40      LNR Partners, LLC, as Special Servicer of the 3Columbus Circle Mortgage Loan

34.41      Wells Fargo Bank, National Association, as Trustee of the 3 Columbus CircleMortgage Loan (Omitted. See Explanatory Notes.)

34.42      Wells Fargo Bank, National Association, asCustodian of the 3 Columbus Circle Mortgage Loan (see Exhibit 34.4)

34.43      Pentalpha Surveillance LLC, as Operating Advisor ofthe 3 Columbus Circle Mortgage Loan (see Exhibit 34.5)

34.44      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.8)

34.45      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 59 Maiden Lane Mortgage Loan(see Exhibit 34.1)

34.46      KeyBank National Association, as Special Servicerof the 59 Maiden Lane Mortgage Loan

34.47      Wells Fargo Bank, National Association, as Trustee of the 59 Maiden LaneMortgage Loan (Omitted. See Explanatory Notes.)

34.48      Wells Fargo Bank, National Association, asCustodian of the 59 Maiden Lane Mortgage Loan (see Exhibit 34.4)

34.49      Park Bridge Lender Services LLC, as OperatingAdvisor of the 59 Maiden Lane Mortgage Loan (see Exhibit 34.31)

34.50      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.8)

34.51      Midland Loan Services, a Division of PNC Bank, NationalAssociation, as Primary Servicer of the Arbor Hotel Portfolio Mortgage Loan(see Exhibit 34.1)

34.52      KeyBank National Association, as Special Servicerof the Arbor Hotel Portfolio Mortgage Loan (see Exhibit 34.46)

34.53      Wells Fargo Bank, National Association, as Trustee of the Arbor Hotel PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.54      Wells Fargo Bank, National Association, asCustodian of the Arbor Hotel Portfolio Mortgage Loan (see Exhibit 34.4)

34.55      Park Bridge Lender Services LLC, as OperatingAdvisor of the Arbor Hotel Portfolio Mortgage Loan (see Exhibit 34.31)

34.56      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.8)

34.57      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Moffett Towers II - Building VMortgage Loan (see Exhibit 34.1)

34.58      KeyBank National Association, as Special Servicerof the Moffett Towers II - Building V Mortgage Loan (see Exhibit 34.46)

34.59      Wells Fargo Bank, National Association, as Trustee of the Moffett Towers II -Building V Mortgage Loan (Omitted. See Explanatory Notes.)

34.60      Wells Fargo Bank, National Association, asCustodian of the Moffett Towers II - Building V Mortgage Loan (see Exhibit34.4)

34.61      Park Bridge Lender Services LLC, as OperatingAdvisor of the Moffett Towers II - Building V Mortgage Loan (see Exhibit 34.31)

34.62      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.8)

34.63      Berkadia Commercial Mortgage LLC, as Primary Servicer of the LakesideApartments Mortgage Loan (Omitted. See Explanatory Notes.) 

34.64      KeyBank National Association, as Special Servicerof the Lakeside Apartments Mortgage Loan (see Exhibit 34.46)

34.65      Wells Fargo Bank, National Association, as Trustee of the Lakeside ApartmentsMortgage Loan (Omitted. See Explanatory Notes.)

34.66      Wells Fargo Bank, National Association, asCustodian of the Lakeside Apartments Mortgage Loan (see Exhibit 34.4)

34.67      Park Bridge Lender Services LLC, as OperatingAdvisor of the Lakeside Apartments Mortgage Loan (see Exhibit 34.31)

34.68      Computershare Trust Company, National Association, asServicing Function Participant for the Custodian (see Exhibit 34.8)

34.69      Wells Fargo Bank, National Association, as PrimaryServicer of the Newport Corporate Center Mortgage Loan

34.70      Situs Holdings, LLC, as Special Servicer of the Newport Corporate CenterMortgage Loan (Omitted. See Explanatory Notes.)

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

34.72      Wells Fargo Bank, National Association, asCustodian of the Newport Corporate Center Mortgage Loan (see Exhibit 34.4)

34.73      Pentalpha Surveillance LLC, as Operating Advisor ofthe Newport Corporate Center Mortgage Loan (see Exhibit 34.5)

34.74      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Newport Corporate Center Mortgage Loan

34.75      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.8)

34.76      Wells Fargo Bank, National Association, as PrimaryServicer of the Central Tower Office Mortgage Loan (see Exhibit 34.69)

34.77      Rialto Capital Advisors, LLC, as Special Servicerof the Central Tower Office Mortgage Loan (see Exhibit 34.2)

34.78      Wilmington Trust, National Association, as Trustee of the Central Tower OfficeMortgage Loan (Omitted. See Explanatory Notes.)

34.79      Wells Fargo Bank, National Association, asCustodian of the Central Tower Office Mortgage Loan (see Exhibit 34.4)

34.80      Pentalpha Surveillance LLC, as Operating Advisor ofthe Central Tower Office Mortgage Loan (see Exhibit 34.5)

34.81      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Central Tower Office Mortgage Loan (see Exhibit 34.74)

34.82      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.8)

34.83      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the SWVP Portfolio Mortgage Loan(see Exhibit 34.1)

34.84      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the SWVP Portfolio Mortgage Loanprior to May 10, 2023 (see Exhibit 34.1)

34.85      K-Star Asset Management LLC, as Special Servicer of the SWVP Portfolio MortgageLoan on and after May 10, 2023 (Omitted. See Explanatory Notes.)

34.86      Wells Fargo Bank, National Association, as Trustee of the SWVP PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.87      Wells Fargo Bank, National Association, asCustodian of the SWVP Portfolio Mortgage Loan (see Exhibit 34.4)

34.88      Pentalpha Surveillance LLC, as Operating Advisor ofthe SWVP Portfolio Mortgage Loan (see Exhibit 34.5)

34.89      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.8)

34.90      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 57 East 11th Street MortgageLoan (see Exhibit 34.1)

34.91      LNR Partners, LLC, as Special Servicer of the 57East 11th Street Mortgage Loan (see Exhibit 34.40)

34.92      Wells Fargo Bank, National Association, as Trustee of the 57 East 11th StreetMortgage Loan (Omitted. See Explanatory Notes.)

34.93      Wells Fargo Bank, National Association, asCustodian of the 57 East 11th Street Mortgage Loan (see Exhibit 34.4)

34.94      Pentalpha Surveillance LLC, as Operating Advisor ofthe 57 East 11th Street Mortgage Loan (see Exhibit 34.5)

34.95      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.8)

35           Servicer compliance statements.

35.1        Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer

35.2        Rialto Capital Advisors, LLC, as Special Servicer

35.3        Wells Fargo Bank, National Association, asCertificate Administrator

35.4        Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator

35.5        Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Green Hills Corporate CenterMortgage Loan (see Exhibit 35.1)

35.6        Rialto Capital Advisors, LLC, as Special Servicerof the Green Hills Corporate Center Mortgage Loan (see Exhibit 35.2)

35.7        Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Western Digital R&D CampusMortgage Loan (see Exhibit 35.1)

35.8        Rialto Capital Advisors, LLC, as Special Servicerof the Western Digital R&D Campus Mortgage Loan (see Exhibit 35.2)

35.9        Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Greenleaf at Howell MortgageLoan (see Exhibit 35.1)

35.10      Rialto Capital Advisors, LLC, as Special Servicerof the Greenleaf at Howell Mortgage Loan (see Exhibit 35.2)

35.11      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the ILPT Hawaii Portfolio MortgageLoan (see Exhibit 35.1)

35.12      Rialto Capital Advisors, LLC, as Special Servicerof the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 35.2)

35.13      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 101 California Mortgage Loan(see Exhibit 35.1)

35.14      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the 101 California Mortgage Loan(see Exhibit 35.1)

35.15      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 3 Columbus Circle MortgageLoan (see Exhibit 35.1)

35.16      LNR Partners, LLC, as Special Servicer of the 3Columbus Circle Mortgage Loan

35.17      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 59 Maiden Lane Mortgage Loan(see Exhibit 35.1)

35.18      KeyBank National Association, as Special Servicerof the 59 Maiden Lane Mortgage Loan

35.19      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Arbor Hotel Portfolio MortgageLoan (see Exhibit 35.1)

35.20      KeyBank National Association, as Special Servicerof the Arbor Hotel Portfolio Mortgage Loan (see Exhibit 35.18)

35.21      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Moffett Towers II - Building VMortgage Loan (see Exhibit 35.1)

35.22      KeyBank National Association, as Special Servicerof the Moffett Towers II - Building V Mortgage Loan (see Exhibit 35.18)

35.23      Berkadia Commercial Mortgage LLC, as Primary Servicer of the LakesideApartments Mortgage Loan (Omitted. See Explanatory Notes.)  

35.24      KeyBank National Association, as Special Servicerof the Lakeside Apartments Mortgage Loan (see Exhibit 35.18)

35.25      Wells Fargo Bank, National Association, as GeneralMaster Servicer of the Newport Corporate Center Mortgage Loan

35.26      Situs Holdings, LLC, as Special Servicer of the Newport Corporate CenterMortgage Loan (Omitted. See Explanatory Notes.)

35.27      Wells Fargo Bank, National Association, as PrimaryServicer of the Central Tower Office Mortgage Loan (see Exhibit 35.25)

35.28      Rialto Capital Advisors, LLC, as Special Servicerof the Central Tower Office Mortgage Loan (see Exhibit 35.2)

35.29      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the SWVP Portfolio Mortgage Loan(see Exhibit 35.1)

35.30      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the SWVP Portfolio Mortgage Loanprior to May 10, 2023 (see Exhibit 35.1)

35.31      K-Star Asset Management LLC, as Special Servicer of the SWVP Portfolio MortgageLoan on and after May 10, 2023 (Omitted. See Explanatory Notes.)

35.32      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 57 East 11th Street MortgageLoan (see Exhibit 35.1)

35.33      LNR Partners, LLC, as Special Servicer of the 57East 11th Street Mortgage Loan (see Exhibit 35.16)

99.1        Mortgage Loan Purchase Agreement, dated as of June 17,2019, between J.P. Morgan Chase Commercial Mortgage Securities Corp. andJPMorgan Chase Bank, National Association (filed as Exhibit 99.1 to theregistrant’s Current Report on Form 8-K filed on June 17, 2019 under CommissionFile No. 333-226123-03 and incorporated by reference herein).

99.2         Mortgage Loan Purchase Agreement, dated as of June 17,2019, between J.P. Morgan Chase Commercial Mortgage Securities Corp. and GermanAmerican Capital Corporation (filed as Exhibit 99.2 to the registrant’s CurrentReport on Form 8-K filed on June 17, 2019 under Commission File No.333-226123-03 and incorporated by reference herein).

99.3         Mortgage Loan Purchase Agreement, dated as of June 17,2019, between J.P. Morgan Chase Commercial Mortgage Securities Corp. and CitiReal Estate Funding Inc. (filed as Exhibit 99.3 to the registrant’s CurrentReport on Form 8-K filed on June 17, 2019 under Commission File No.333-226123-03 and incorporated by reference herein).

99.4         Primary Servicing Agreement, dated as of May 1, 2019,between Wells Fargo Bank, National Association, as Master Servicer, and MidlandLoan Services, a Division of PNC Bank, National Association, as PrimaryServicer (filed as Exhibit 99.4 to the registrant’s Current Report on Form8-K/A filed on February 11, 2020 under Commission File No. 333-226123-03 andincorporated by reference herein).

(b)          The exhibits required to be filed by the Registrant pursuant to Item 601 ofRegulation 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.

J.P. Morgan Chase CommercialMortgage Securities Corp.(Depositor)

/s/ KunalK. Singh

Kunal K.Singh, President and Chief Executive Officer

(senior officer in charge ofsecuritization of the depositor)

Date: March 13, 2024