**MANAGEMENT’S ASSESSMENT OF COMPLIANCE WITH APPLICABLESERVICING CRITERIA PURSUANT TO ITEM 1122 OF REGULATION AB**

 

 

Management of Berkeley Point Capital LLC d/b/a Newmark is responsiblefor assessing compliance with the applicable servicing criteria set forth inItem 1122(d) of Regulation AB of the Securities and Exchange Commissionrelating to its role in the servicing of commercial mortgage-backed securitiestransactions conducted by Newmark  (the “Platform”) as of and for the yearended December 31, 2021 (the “Reporting Period”).  Appendix A identifiesthe individual asset-backed transactions and securities defined by managementas constituting the Platform. 

 

Newmark’s management has assessed Newmark’s compliance withthe applicable servicing criteria during the Reporting Period.  In makingthis assessment, management used the criteria set forth by the Securities andExchange Commission (“SEC”) in paragraph (d) of Item 1122 of Regulation AB,excluding the criteria set forth in Appendix B, which management has determinedare not applicable to the servicing activities it performs with respect to thePlatform. 

 

With respect to applicable servicing criteria identified inAppendix C, there were no activities performed for the Reporting Period withrespect to the Platform, because there was no occurrence of events that wouldrequire Newmark to perform such activities. 

 

With respect to servicing criteria 1122(d)(1)(v), 1122(d)(2)(vi)and 1122(d)(2)(vii), management has engaged Midland Loan Services, a divisionof PNC Bank, National Association (“Midland”) to perform the activitiesrequired by these servicing criteria.  Newmark management has determinedthat Midland is not a “servicer” as defined in Item 1101(j) of Regulation AB,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&DI”) 200.06, VendorsEngaged by Servicers (C&DI 200.06) (formerly SEC Regulation AB Manual ofPublicly Available Telephone Interpretations, 17.06).  Management haspolicies and procedures in place designed to provide reasonable assurance thatMidland’s activities comply in all material respects with the servicingcriteria applicable to Midland.  Newmark  has not identified and isnot 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 the Platformtaken as a whole.  NKF is solely responsible for determining that it meetsthe SEC requirements to apply C&DI 200.06 for Midland and the relatedcriteria. 

 

Based on such assessment, management believes that withrespect to the Reporting Period, Newmark  has complied in all materialrespects with the servicing criteria set forth in Item 1122(d) of Regulation ABof the SEC, including servicing criteria 1122(d)(1)(v), 1122(d)(2)(vi) and1122(d)(2)(vii) for which compliance is determined based on C&DI 200.06 asdescribed above relating to its role in the servicing of the Platform. 

 

  

Ernst and Young LLP, an independent registered publicaccounting firm, has issued an attestation report with respect to management’sassessment of compliance with the applicable servicing criteria with respect tothe Reporting Period.

 

 

By:  Berkeley Point Capital LLC, 

dba Newmark 

 

/s/ Ronald Steffenino 

Ronald Steffenino

Vice Chairman

 

Date 2/22/2022

 

 

 /s/ Mike Rispoli

Mike Rispoli

Chief Financial Officer

 

Date 2/22/2022

 

 

**Appendix A to Management’s Assessment**

** **

COMM 2014-CCRE 17 Mortgage Trust Commercial MortgagePass-Through Certificates 

COMM 2014-UBS4 Mortgage Trust Commercial MortgagePass-Through Certificates 

COMM 2014-CCRE19 Mortgage Trust Commercial MortgagePass-Through Certificates 

GS Mortgage Securities Trust 2014-GC24 Commercial MortgagePass-Through Certificates Series 2014-GC24 

COMM 2014-CCRE20 Mortgage Trust Commercial MortgagePass-Through Certificates 

COMM 2015-LC19 Mortgage Trust Commercial MortgagePass-Through Certificates 

GS Mortgage Securities Trust 2015-GC28 Commercial MortgagePass-Through Certificates Series 2015-GC28 

GS Mortgage Securities Trust 2015-GC30 Commercial MortgagePass-Through Certificates Series 2015-GC30 

Commercial Mortgage Pass-Through Certificates Series2015-CCRE23 

Commercial Mortgage Pass-Through Certificates Series2015-LC21 

COMM 2015-CCRE24 Mortgage Trust Commercial MortgagePass-Through Certificates 

COMM 2015-CCRE26 Mortgage Trust Commercial MortgagePass-Through Certificates 

COMM 2015 CCRE27 Mortgage Trust Commercial MortgagePass-Through Certificates 

GS Mortgage Securities Trust 2015-GC34 Commercial MortgagePass-Through Certificates Series 2015-GC34 

COMM 2015-LC23 Mortgage Trust Commercial MortgagePass-Through Certificates Series 2015-LC3 

CFCRE 2016-C3 Mortgage Trust Commercial Mortgage Pass-ThroughCertificates, Series 2016-C3 

CFCRE 2016-C4 Mortgage Trust Commercial Mortgage Pass-throughCertificates, Series 2016-C4 

Citigroup Commercial Mortgage Trust 2016-C1, CommercialMortgage Pass-through Certificates, Series 2016-C1 

SG Commercial Mortgage Securities Trust 2016-C5 CommercialMortgage Pass-Through Certificates Series 2016-C5 

Citigroup Commercial Mortgage Trust 2016-C3, Commercial MortgagePass-through Certificates, Series 2016-C3 

CFCRE 2016-C6 Mortgage Trust Commercial Mortgage Pass-ThroughCertificates Series 2016-C6 

CFCRE 2016-C7 Commercial Mortgage Pass-Through Certificates 

CFCRE 2017-C8 Mortgage Trust Commercial Mortgage Pass-ThroughCertificates, Series 2017-C8 

UBS Commercial Mortgage Trust 2017-C4 Commercial MortgagePass-Through Certificates Series 2017-C4 

UBS Commercial Mortgage Trust 2017-C5 Commercial MortgagePass-Through Certificates Series 2017-C5 

UBS Commercial Mortgage Trust 2017-C6 Commercial MortgagePass-Through Certificates Series 2017-C6 

Citigroup Commercial Mortgage Trust 2017-C4 CommercialMortgage Pass-Through Certificates Series 2017-C4 

CCUBS Commercial Mortgage Trust 2017-C1 Commercial MortgagePass-Through Certificates Series 2017-C1 

UBS Commercial Mortgage Trust 2018-C8 Commercial MortgagePass-Through Certificates Series 2018-C8 

UBS Commercial Mortgage Trust 2018-C9 Commercial MortgagePass-Through Certificates, Series 2018-C9 

Benchmark 2018-B3 commercial Mortgage Pass-ThroughCertificates Series 2018-B3 

UBS Commercial Mortgage Trust 2018-C10 Commercial MortgagePass-through Certificates, Series 2018-C10 

UBS Commercial Mortgage Trust 2018-C12 Commercial MortgagePass-Through Certificates, Series 2018-C12 

Morgan Stanley Capital, I Trust 2018-L1 Commercial MortgagePass-Through Certificates, Series 2018-L1 

UBS Commercial Mortgage Trust 2018-C14 Commercial MortgagePass-Through Certificates Series 2018 C14 

Citigroup Commercial Mortgage Trust 2018-C6 CommercialMortgage Pass-Through Certificates Series 2018-C6 

BBCMS Mortgage Trust 2018 C2 Commercial Mortgage Pass-ThroughCertificates, Series 2018-C2 

Morgan Stanley Capital, I Trust 2018 H4 Commercial MortgagePass-Through Series 2018 H4 

Morgan Stanley Capital, I Trust 2019 L2 Commercial MortgagePass-Through Certificates Series 2019-L2 

CF 2019 CF1 Mortgage Trust Commercial Mortgage Pass-ThroughCertificates Series 2019-CF1 

 

 

**Appendix B to Management’s Assessment**

 

**Regulation AB Item 1122(d) criteria determined to be notapplicable:**

 

·1122(d)(1)(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 to Management’s Assessment**

 

Regulation AB Item 1122(d) criteria that Newmark is undercontract to perform the activities required, but for which there were nooccurrences of events for the year ended December 31, 2021 that required themto perform such activities: 

 

·1122(d)(4)(iii) 

 

·1122(d)(4)(vi) 

 

·1122(d)(4)(ix) 

 

·1122(d)(4)(xiv) 

 

 

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