**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, 2021or**

**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 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 and posted on its corporate Web site, if any, every InteractiveData File required to be submitted and posted pursuant to Rule 405 ofRegulation S-T (Section 232.405 of this chapter) during the preceding 12 months(or for such shorter period that the registrant was required to submit and postsuch files).

Not applicable.

Indicate by check mark if disclosure of delinquent filerspursuant to Item 405 of Regulation S-K (Section 229.405 of this chapter) is notcontained herein, and will not be contained, to the best of registrant’sknowledge, in definitive proxy or information statements incorporated byreference in Part III of this Form 10-K or any amendment to this Form10-K.   

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                                                                                                       Acceleratedfiler                                     o

Non-acceleratedfiler          ⌧  (Do not check ifa smaller reporting company)                          Smaller reporting company                    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 complying withany new or revised financial accounting standards provided pursuant to Section13(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

Indicate by check mark whether the registrant is a shell company(as defined in Rule 12b-2 of the Act).  oYes ⌧ 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 MortgageLoan, the Western Digital R&D Campus Mortgage Loan and the Greenleaf atHowell Mortgage Loan, which constituted approximately 4.5%, 3.5% and 2.4%,respectively, of the asset pool of the issuing entity as of its cut-off date,are each an asset of the issuing entity and are each part of a loan combinationthat includes the Green Hills Corporate Center Mortgage Loan, the WesternDigital R&D Campus Mortgage Loan or the Greenleaf at Howell Mortgage Loanand one other *pari passu* loan, which is not an asset of the issuingentity. These loan combinations, including the Green Hills Corporate CenterMortgage Loan, the Western Digital R&D Campus Mortgage Loan and theGreenleaf at Howell Mortgage Loan, are being serviced and administered pursuantto the Pooling and Servicing Agreement, which is incorporated by reference asExhibit 4.1 to this Annual Report on Form 10-K. 

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the ILPT Hawaii Portfolio Mortgage Loan, whichconstituted approximately 7.1% of the asset pool of the issuing entity as ofits cut-off date.  The ILPT Hawaii Portfolio Mortgage Loan is an asset ofthe issuing entity and is part of a loan combination that includes the ILPTHawaii Portfolio Mortgage Loan and fifteen other *pari passu* loans, whichare not assets of the issuing entity. A *pari passu* portion of the loancombination was securitized in the ILPT Trust 2019-SURF transaction (the “ILPT2019-SURF Transaction”). This loan combination, including the ILPT HawaiiPortfolio Mortgage Loan, is being serviced and administered pursuant to thetrust and servicing agreement for the ILPT 2019-SURF Transaction, which isincorporated by reference as Exhibit 4.2 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the 101 California Mortgage Loan, whichconstituted approximately 4.5% of the asset pool of the issuing entity as ofits cut-off date.  The 101 California Mortgage Loan is an asset of the issuingentity and is part of a loan combination that includes the 101 CaliforniaMortgage Loan, seven other *pari passu* loans and two subordinatecompanion loans, which are not assets of the issuing entity. A *pari passu*portion of the loan combination was securitized in the CALI Mortgage Trust2019-101C transaction (the “CALI 2019-101C Transaction”). This loancombination, including the 101 California Mortgage Loan, is being serviced andadministered pursuant to the trust and servicing agreement for the CALI2019-101C Transaction, which is incorporated by reference as Exhibit 4.3 tothis Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the 3 Columbus Circle Mortgage Loan, whichconstituted approximately 9.1% of the asset pool of the issuing entity as ofits cut-off date.  The 3 Columbus Circle Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the 3 ColumbusCircle Mortgage Loan, thirteen other *pari passu* loans and twosubordinate companion loans, which are not assets of the issuing entity. A *paripassu* portion of the loan combination was securitized in the Benchmark 2019-B10Mortgage Trust transaction, Commission File Number 333-226943-02 (the “Benchmark2019-B10 Transaction”). This loan combination, including the 3 ColumbusCircle Mortgage Loan, is being serviced and administered pursuant to thepooling and servicing agreement for the Benchmark 2019-B10 Transaction, whichis incorporated by reference as Exhibit 4.4 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Heartland Dental Medical Office PortfolioMortgage Loan, which constituted approximately 1.8% of the asset pool of theissuing entity as of its cut-off date.  The Heartland Dental MedicalOffice Portfolio Mortgage Loan is an asset of the issuing entity and is part ofa loan combination that includes the Heartland Dental Medical Office PortfolioMortgage Loan and ten other *pari passu* loans, which are not assets ofthe issuing entity. A *pari passu* portion of the loan combination wassecuritized in the Wells Fargo Commercial Mortgage Trust 2019-C50 transaction,Commission File Number 333-226486-05 (the “WFCM 2019-C50 Transaction”).This loan combination, including the Heartland Dental Medical Office PortfolioMortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the WFCM 2019-C50 Transaction, which is incorporated byreference as Exhibit 4.5 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the 59 Maiden Lane Mortgage Loan, the ArborHotel Portfolio Mortgage Loan, the Moffett Towers II - Building V Mortgage Loanand the Lakeside Apartments Mortgage Loan, which constituted approximately6.8%, 4.5%, 3.9% and 3.2%, respectively, of the asset pool of the issuingentity as of its cut-off date.  The 59 Maiden Lane Mortgage Loan, theArbor Hotel Portfolio Mortgage Loan, the Moffett Towers II - Building VMortgage Loan and the Lakeside Apartments Mortgage Loan are each an asset ofthe issuing entity and are each part of a loan combination that includes (a)with respect to the 59 Maiden Lane Mortgage Loan, two other *pari passu*loans, which are not assets of the issuing entity, (b) with respect to theArbor Hotel Portfolio Mortgage Loan, one other *pari passu* loan, which isnot an asset of the issuing entity, (c) with respect to the Moffett Towers II -Building V Mortgage Loan, three other *pari passu* loans and foursubordinate companion loans, which are not assets of the issuing entity or (d)with respect to the Lakeside Apartments Mortgage Loan, one other *pari passu*loan, which is not an asset of the issuing entity. A *pari passu* portionof each loan combination was securitized in the GS Mortgage Securities Trust2019-GC39 transaction, Commission File Number 333-226082-02 (the “GSMS2019-GC39 Transaction”). These loan combinations, including the 59 MaidenLane Mortgage Loan, the Arbor Hotel Portfolio Mortgage Loan, the Moffett TowersII - Building V Mortgage Loan and the Lakeside Apartments Mortgage Loan, arebeing serviced and administered pursuant to the pooling and servicing agreementfor the GSMS 2019-GC39 Transaction, which is incorporated by reference asExhibit 4.6 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Newport Corporate Center Mortgage Loan andthe Central Tower Office Mortgage Loan, which constituted approximately 3.7%and 3.1%, respectively, of the asset pool of the issuing entity as of itscut-off date.  The Newport Corporate Center Mortgage Loan and the CentralTower Office Mortgage Loan are each an asset of the issuing entity and are eachpart of a loan combination that includes (a) with respect to the NewportCorporate Center Mortgage Loan, three other *pari passu* loans and tensubordinate companion loans, which are not assets of the issuing entity or (b)with respect to the Central Tower Office Mortgage Loan, one other *pari passu*loan, which is not an asset of the issuing entity. A *pari passu* portionof each loan combination was securitized in the BANK 2019-BNK18 transaction,Commission File Number 333-228375-01 (the “BANK 2019-BNK18 Transaction”).These loan combinations, including the Newport Corporate Center Mortgage Loanand the Central 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 4.7 to this AnnualReport on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the SWVP Portfolio Mortgage Loan, whichconstituted approximately 4.5% of the asset pool of the issuing entity as ofits cut-off date.  The SWVP Portfolio Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the SWVPPortfolio Mortgage Loan and eight other *pari passu* loans, which are notassets of the issuing entity. A *pari passu* portion of the loancombination was securitized in the BBCMS Mortgage Trust 2019-C3 transaction,Commission File Number 333-226850-02 (the “BBCMS 2019-C3 Transaction”).This loan combination, including the SWVP Portfolio Mortgage Loan, is beingserviced and administered pursuant to the pooling and servicing agreement forthe BBCMS 2019-C3 Transaction, which is incorporated by reference as Exhibit4.8 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the 57 East 11th Street Mortgage Loan, whichconstituted approximately 1.8% of the asset pool of the issuing entity as ofits cut-off date.  The 57 East 11th Street Mortgage Loan is an asset ofthe issuing entity and is part of a loan combination that includes the 57 East11th Street Mortgage Loan, two other *pari passu* loans, which are notassets of the issuing entity.  This loan combination, including the 57East 11th Street Mortgage Loan, was serviced under the pooling and servicingagreement for the GSMS 2019-GC39 Transaction prior to the closing of thesecuritization of a *pari passu* portion of the 57 East 11th Street loancombination in the GS Mortgage Securities Trust 2019-GC40 transaction,Commission File Number 333-226082-03 (the “GSMS 2019-GC40 Transaction”). After the closing of the GSMS 2019-GC40 Transaction on July 11, 2019, this loancombination, including the 57 East 11th Street Mortgage Loan was, and willcontinue to be, serviced and administered pursuant to the pooling and servicingagreement with respect to the GSMS 2019-GC40 Transaction, which is incorporatedby reference as Exhibit 4.9 to this Annual Report on Form 10-K.

The master servicer of a poolingand servicing agreement or trust and servicing agreement also functions as theprimary servicer of the related mortgage loans serviced and administeredpursuant to such agreement unless a separate primary servicer is identifiedherein.  If this report does not identify a separate primary servicer, theservicer compliance statement provided by the master servicer under any suchagreement also encompasses its responsibilities as primary servicer of therelated mortgage loan or mortgage loans.

Midland Loan Services, a Divisionof PNC Bank, National Association is the master servicer of the mortgage loansserviced under the Pooling and Servicing Agreement, the primary servicer of the57 East 11th Street Mortgage Loan, the 3 Columbus Circle Mortgage Loan, theILPT Hawaii Portfolio Mortgage Loan, the 59 Maiden Lane Mortgage Loan, theArbor Hotel Portfolio Mortgage Loan, the Moffett Towers II - Building VMortgage Loan and the Heartland Dental Medical Office Portfolio Mortgage Loan,the primary servicer and special servicer of the SWVP Portfolio Mortgage Loan,the 101 California Mortgage Loan and the special servicer of the 57 East 11thStreet Mortgage Loan prior to July 19, 2021. As a result, Midland LoanServices, a Division of PNC Bank, National Association is a “servicer” asdefined in Item 1108(a)(2)(iii) of Regulation AB, in the capacities describedabove, because it is servicing mortgage loans that constituted 10% or more ofthe assets 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 Midland Loan Services, aDivision of PNC Bank, National Association in the capacities described aboveare listed in the Exhibit Index.

LNR Partners, LLC is the specialservicer of the 3 Columbus Circle Mortgage Loan and the 57 East 11th StreetMortgage Loan, which constituted approximately 9.1% and 1.8%, respectively, ofthe asset pool of the issuing entity as of its cut-off date. In accordance withthe Compliance and Disclosure Interpretations, Section 200.03 (Rules 13a-18 and15d-18, Servicer’s Assessment of Compliance), this percentage must be reduced *prorata*because it was only acting as special servicer of the 57 East 11thStreet Mortgage Loan from July 19, 2021 to December 31, 2021. As a result, LNRPartners, LLC is an unaffiliated party that, as a result of such *pro rata*reduction of such percentage, is not a “servicer” that meets the criteria inItem 1108(a)(2)(i) through (iii) of Regulation AB and so no servicer compliancestatement is required.

Rialto Capital Advisors, LLC isthe special servicer of the mortgage loans serviced under the Pooling andServicing Agreement, the ILPT Hawaii Portfolio Mortgage Loan, the Central TowerOffice Mortgage Loan and the Heartland Dental Medical Office Portfolio MortgageLoan. As a result, Rialto Capital Advisors, LLC 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 Rialto Capital Advisors, LLC inthe capacities described above are listed in the Exhibit Index.

Wells Fargo Bank, NationalAssociation is the certificate administrator of the mortgage loans servicedunder the Pooling and Servicing Agreement and the primary servicer of theNewport Corporate Center Mortgage Loan and the Central Tower Office MortgageLoan. As a result, Wells Fargo Bank, National Association is a “servicer” asdefined in Item 1108(a)(2)(iii) of Regulation AB, in the capacities describedabove, because it is servicing mortgage loans that constituted 10% or more ofthe assets 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 Wells Fargo Bank, NationalAssociation in the capacities described above 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, the57 East 11th Street Mortgage Loan and the Heartland Dental Medical OfficePortfolio Mortgage Loan.  As a result, Wells Fargo Bank, NationalAssociation is a servicing function participant in the capacities describedabove, because it is servicing mortgage loans that constituted 5% or more ofthe assets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria and accountants’ attestationreports delivered by Wells Fargo Bank, National Association in the capacitiesdescribed 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, the Lakeside Apartments Mortgage Loan and the Heartland DentalMedical Office Portfolio Mortgage Loan.  As a result, Park Bridge LenderServices LLC is a servicing function participant in the capacities describedabove, because it is servicing mortgage loans that constituted 5% or more ofthe assets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria and accountants’ attestationreports delivered by Park Bridge Lender Services LLC in the capacitiesdescribed above are listed in the Exhibit Index.

KeyBank National Association isthe special servicer of the 59 Maiden Lane Mortgage Loan, the Arbor HotelPortfolio Mortgage Loan, the Moffett Towers II - Building V Mortgage Loan andthe Lakeside Apartments Mortgage Loan. As a result, KeyBank NationalAssociation is a “servicer” as defined in Item 1108(a)(2)(iii) of RegulationAB, in the capacities described above, because it is servicing mortgage loansthat constituted 10% or more of the assets of the issuing entity as of itscut-off date. The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby KeyBank National Association in the capacities described above are listed inthe Exhibit Index.

Wells Fargo Bank, NationalAssociation acts as trustee of the Green Hills Corporate Center Mortgage Loan,the Western Digital R&D Campus Mortgage Loan, the Greenleaf at HowellMortgage Loan, the ILPT Hawaii Portfolio Mortgage Loan, the 101 CaliforniaMortgage Loan, the 3 Columbus Circle Mortgage Loan, the 59 Maiden Lane MortgageLoan, the Arbor Hotel Portfolio Mortgage Loan, the Moffett Towers II - BuildingV Mortgage Loan, the Lakeside Apartments Mortgage Loan, the SWVP PortfolioMortgage Loan and the 57 East 11th Street Mortgage Loan.  Pursuant to thePooling and Servicing Agreement, the trust and servicing agreement for the ILPT2019-SURF Transaction, the trust and servicing agreement for the CALI 2019-101CTransaction, the pooling and servicing agreement for the Benchmark 2019-B10Transaction, the pooling and servicing agreement for the GSMS 2019-GC39Transaction, the pooling and servicing agreement for the BBCMS 2019-C3Transaction and the pooling and servicing agreement for the GSMS 2019-GC40Transaction, the trustee is required to provide an assessment of compliancewith applicable servicing criteria solely with respect to Item 1122(d)(2)(iii)of Regulation AB (regarding advances of funds or guarantees regarding collections,cash flows or distributions, and any interest or other fees charged for suchadvances, are made, reviewed and approved as specified in the transactionagreements). However, during the reporting period, the trustee did not performany servicing function with respect to the servicing criteria specified in Item1122(d)(2)(iii) of Regulation AB.  The master servicer or the specialservicer, to the extent required, performed the servicing function identifiedwith respect to Item 1122(d)(2)(iii) of Regulation AB, and each such partyincluded Item 1122(d)(2)(iii) of Regulation AB in the assessment of compliancewith applicable 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, NationalAssociation acts as trustee of the Heartland Dental Medical Office PortfolioMortgage Loan, the Newport Corporate Center Mortgage Loan and the Central TowerOffice Mortgage Loan.  Pursuant to the pooling and servicing agreement forthe WFCM 2019-C50 Transaction and the pooling and servicing agreement for theBANK 2019-BNK18 Transaction, the trustee is required to provide an assessmentof compliance 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 ofthe Heartland Dental Medical Office Portfolio Mortgage Loan, the NewportCorporate Center Mortgage Loan and the Central Tower Office Mortgage Loan havedelivered one or more assessments of compliance with respect to Item1122(d)(2)(iii) of Regulation AB.

This Annual Report on Form 10-Kincludes assessments of compliance with applicable servicing criteria and accountants’attestation reports from CoreLogic Solutions, LLC  This entity was engagedby the primary servicer of the Newport Corporate Center Mortgage Loan and theCentral Tower Office Mortgage Loan to remit tax payments received from theescrow accounts of borrowers to local taxing authorities, to report tax amountsdue, to verify tax parcel information, and to verify non-escrow tax payments.These servicing functions are included within the servicing criteria set forthin Items 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.  SeeCompliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

Theassessments of compliance with applicable servicing criteria, accountants’attestation reports and servicer compliance statements of the certificateadministrator of the ILPT Hawaii Portfolio Mortgage Loan, the 101 CaliforniaMortgage Loan, the 3 Columbus Circle Mortgage Loan, the Heartland DentalMedical Office Portfolio Mortgage Loan, the 59 Maiden Lane Mortgage Loan, theArbor Hotel Portfolio Mortgage Loan, the Moffett Towers II - Building VMortgage Loan, the Lakeside Apartments Mortgage Loan, the Newport CorporateCenter Mortgage Loan, the Central Tower Office Mortgage Loan, the SWVPPortfolio Mortgage Loan and the 57 East 11th Street Mortgage Loan are omittedfrom this Annual Report on Form 10-K as the certificate administrator pursuantto the related pooling and servicing agreement or trust and servicing agreementdoes not perform any activities that address servicing criteria with respect tothe issuing entity and because they are each not a “servicer” that meets thecriteria in Item 1108(a)(2)(i) through (iii) of Regulation AB.

Withrespect to the *pari passu* loan combinations that include theLakeside Apartments Mortgage Loan, the Newport Corporate Center MortgageLoan, the 3 Columbus Circle Mortgage Loan andthe 57 East 11th Street Mortgage Loan, (i) thereports on assessment of compliance with servicing criteria and attestationreports on assessment of compliance with servicing criteria of BerkadiaCommercial Mortgage LLC as primary servicer of the Lakeside Apartments MortgageLoan and Situs Holdings, LLC as special servicer of the Newport CorporateCenter Mortgage Loan, listed on the Exhibit Index are omitted from this AnnualReport on Form 10-K as they are not required to be included on this Annual Reporton Form 10-K per Instruction 3 to Item 1122 of Regulation AB because they areparties performing activities that address servicing criteria relating to 5% orless of the assets of the issuing entity; and (ii) the servicer compliancestatements of Berkadia Commercial Mortgage LLC as primary servicer of theLakeside Apartments Mortgage Loan and Situs Holdings, LLC as special servicerof the Newport Corporate Center Mortgage Loan, listed on the Exhibit Index areomitted from this Annual Report on Form 10-K as they are not required by Item1123 of Regulation AB to be included on this Annual Report on Form 10-K becausethey are each an unaffiliated party that is not a “servicer” that meets thecriteria in Item 1108(a)(2)(i) through (iii) of Regulation AB, and the servicercompliance statement of LNR Partners, LLC as special servicer of the 3 ColumbusCircle Mortgage Loan and the 57 East 11th Street Mortgage Loan on and afterJuly 19, 2021 listed on the Exhibit Index is omitted from this Annual Report onFrom 10-K for the reasons set forth in the Explanatory Notes above.

**PART I**

**Item 1.  Business.**

Omitted.

**Item 1A.  Risk Factors.**

Omitted.

**Item 1B.  Unresolved Staff Comments.**

None.

**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.  Selected Financial Data.**

Omitted.

**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.

**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 Accounting 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 assetsheld by 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, as Trustee,Certificate Administrator and Custodian.

 

In December 2014, Phoenix LightSF Limited and certain related entities and the National Credit UnionAdministration (NCUA) filed complaints in the United States District Court forthe Southern District of New York against Wells Fargo Bank, alleging claimsagainst Wells Fargo Bank in its capacity as trustee for a number of residentialmortgage-backed securities trusts. Complaints raising similar allegations havebeen filed by Commerzbank AG in the Southern District of New York and by IKBInternational and IKB Deutsche Industriebank in New York state court. In eachcase, the plaintiffs allege that Wells Fargo Bank, as trustee, caused losses toinvestors, and plaintiffs assert causes of action based upon, among otherthings, the trustee’s alleged failure to notify and enforce repurchaseobligations of mortgage loan sellers for purported breaches of representationsand warranties, notify investors of alleged events of default, and abide byappropriate standards of care following alleged events of default. Wells FargoBank previously settled two class action lawsuits with similar allegations thatwere filed in November 2014 and December 2016 by institutional investors in theSouthern District of New York and New York state court, respectively. Inaddition, Park Royal I LLC and Park Royal II LLC have filed complaints in NewYork state court alleging Wells Fargo Bank, N.A., as trustee, failed to takeappropriate actions upon learning of defective mortgage loan documentation. InMarch 2021, the Company entered into an agreement to resolve the case filed bythe NCUA.

 

In addition to the foregoing cases,in August 2014 and August 2015 Nomura Credit & Capital Inc. (“Nomura”)and Natixis Real Estate Holdings, LLC (“Natixis”) filed a total of seventhird-party complaints against Wells Fargo Bank in New York state court. In theunderlying first-party actions, Nomura and Natixis have been sued for allegedbreaches of representations and warranties made in connection with residentialmortgage-backed securities sponsored by them. In the third-party actions,Nomura and Natixis allege that Wells Fargo Bank, as master servicer, primaryservicer or securities administrator, failed to notify Nomura and Natixis oftheir own breaches, failed to properly oversee the primary servicers, andfailed to adhere to accepted servicing practices. Natixis additionally alleges thatWells Fargo Bank failed to perform default oversight duties. Wells Fargo Bankhas asserted counterclaims alleging that Nomura and Natixis failed to provideWells Fargo Bank notice of their representation and warranty breaches.

 

With respect to each of the foregoing litigations, WellsFargo Bank believes plaintiffs' claims are without merit and intends to contestthe claims vigorously, but there can be no assurances as to the outcome of thelitigations or the possible impact of the litigations on Wells Fargo Bank orthe related RMBS trusts.

**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 servicing criteriafor asset-backed securities and related attestation reports on such assessmentsof compliance with respect to the 3 Columbus Circle Mortgage Loan, which isbeing serviced and administered pursuant to the pooling and servicing agreementfor the Benchmark 2019-B10 Transaction, are attached hereto under Item 15 tothis Annual Report on Form 10-K. Attached as Schedule II to the pooling andservicing agreement for the Benchmark 2019-B10 Transaction incorporated byreference as Exhibit 4.4 to this Annual Report on Form 10-K is a chartidentifying 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 Heartland Dental Medical OfficePortfolio Mortgage Loan, which is being serviced and administered pursuant tothe pooling and servicing agreement for the WFCM 2019-C50 Transaction, areattached hereto under Item 15 to this Annual Report on Form 10-K. Attached asExhibit AA to the pooling and servicing agreement for the WFCM 2019-C50Transaction incorporated by reference as Exhibit 4.5 to this Annual Report onForm 10-K is a chart identifying the entities participating in a servicingfunction for the WFCM 2019-C50 Transaction responsible for each applicableservicing 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 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 asExhibit 4.6 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the GSMS 2019-GC39Transaction 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 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 4.7 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 4.8 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 4.9 to this Annual Report on Form 10-K is a chart identifyingthe entities participating in a servicing function for the GSMS 2019-GC40Transaction responsible for each applicable servicing criteria set forth inItem 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. Exhibits, 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 Master Servicer,Rialto Capital 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 (filedas Exhibit 4.2 to the registrant’s Current Report on Form 8-K filed on June 17,2019 under Commission File No. 333-226123-03 and incorporated by referenceherein).

4.5          Pooling and Servicing Agreement, dated as of May 1, 2019,by and among Wells Fargo Commercial Mortgage Securities, Inc., as Depositor,Wells Fargo Bank, National Association, as Master Servicer, Rialto CapitalAdvisors, LLC, as Special Servicer, Wells Fargo Bank, National Association, asCertificate Administrator, Wilmington Trust, National Association, as Trustee,and Park Bridge Lender Services LLC, as Operating Advisor and AssetRepresentations Reviewer (filed as Exhibit 99.4 to the registrant’s CurrentReport on Form 8-K/A filed on February 11, 2020 under Commission File No.333-226123-03 and incorporated by reference herein).

4.6          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).

4.7          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,National Cooperative Bank, N.A., as NCB Master Servicer, Rialto CapitalAdvisors, LLC, as Special Servicer, National Cooperative Bank, N.A., as NCBSpecial Servicer, Situs Holdings, LLC, as Newport Corporate Center SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administratorand Custodian, Wilmington Trust, National Association, as Trustee, andPentalpha Surveillance LLC, as Operating Advisor and Asset RepresentationsReviewer (filed as Exhibit 4.7 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 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).

4.9          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).

4.10         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).

4.11         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).

4.12         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).

4.13         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).

4.14         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).

4.15         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 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).

4.16         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).

4.17         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).

4.18         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-2Holder (filed as Exhibit 4.17 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).

4.19         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).

4.20         Co-Lender Agreement, dated as of March 1, 2019, by and betweenCiti Real Estate Funding Inc., as Initial Note A-1 Holder, and Citi Real EstateFunding Inc., as Initial Note A-2 Holder (filed as Exhibit 4.19 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).

4.21         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).

4.22         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).

4.23         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).

4.24         Agreement Between Note Holders, dated as of December 12,2018, by and between UBS AG, by and through its branch office at 1285 Avenue ofthe Americas, New York, New York, as Initial Note A-1 Holder, Initial Note A-2Holder, Initial Note A-3 Holder, Initial Note A-4 Holder, Initial Note A-5Holder, Initial Note A-6 Holder, Initial Note A-7 Holder, Initial Note A-8 Holder,Initial Note A-9 Holder and Initial Note A-10 Holder (filed as Exhibit 4.23 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).

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 Trustee and Certificate Administratoron and after November 1, 2021

33.8        Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021

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 on and after November 1,2021 (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 on and after November 1,2021 (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 on and after November 1,2021 (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 on and after November 1,2021 (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 on and after November 1,2021 (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 on and after November 1,2021 (see Exhibit 33.8)

33.45      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Heartland Dental MedicalOffice Portfolio Mortgage Loan (see Exhibit 33.1)

33.46      Rialto Capital Advisors, LLC, as Special Servicerof the Heartland Dental Medical Office Portfolio Mortgage Loan (see Exhibit33.2)

33.47      Wilmington Trust, National Association, as Trustee of the Heartland DentalMedical Office Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.48      Wells Fargo Bank, National Association, asCustodian of the Heartland Dental Medical Office Portfolio Mortgage Loan (seeExhibit 33.4)

33.49      Park Bridge Lender Services LLC, as OperatingAdvisor of the Heartland Dental Medical Office Portfolio Mortgage Loan (see Exhibit33.31)

33.50      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

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

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

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

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

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

33.56      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

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

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

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

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

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

33.62      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

33.63      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)

33.64      KeyBank National Association, as Special Servicerof the Moffett Towers II - Building V Mortgage Loan (see Exhibit 33.52)

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

33.66      Wells Fargo Bank, National Association, as Custodianof the Moffett Towers II - Building V Mortgage Loan (see Exhibit 33.4)

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

33.68      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

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

33.70      KeyBank National Association, as Special Servicerof the Lakeside Apartments Mortgage Loan (see Exhibit 33.52)

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

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

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

33.74      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

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

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

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

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

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

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

33.81      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

33.82      Wells Fargo Bank, National Association, as PrimaryServicer of the Central Tower Office Mortgage Loan (see Exhibit 33.75)

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

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

33.85      Wells Fargo Bank, National Association, as Custodianof the Central Tower Office Mortgage Loan (see Exhibit 33.4)

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

33.87      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Central Tower Office Mortgage Loan (see Exhibit 33.80)

33.88      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

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

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

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

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

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

33.94      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

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

33.96      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the 57 East 11th Street MortgageLoan prior to July 19, 2021 (see Exhibit 33.1)

33.97      LNR Partners, LLC, as Special Servicer of the 57East 11th Street Mortgage Loan on and after July 19, 2021 (see Exhibit 33.40)

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

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

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

33.101    Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (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 Trustee andCertificate 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 Trustee and Certificate Administratoron and after November 1, 2021

34.8        Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021

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 on and after November 1,2021 (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 on and after November 1,2021 (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 on and after November 1,2021 (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 on and after November 1,2021 (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, asCustodian of 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 on and after November 1,2021 (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 on and after November 1,2021 (see Exhibit 34.8)

34.45      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Heartland Dental MedicalOffice Portfolio Mortgage Loan (see Exhibit 34.1)

34.46      Rialto Capital Advisors, LLC, as Special Servicerof the Heartland Dental Medical Office Portfolio Mortgage Loan (see Exhibit34.2)

34.47      Wilmington Trust, National Association, as Trustee of the Heartland DentalMedical Office Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.48      Wells Fargo Bank, National Association, asCustodian of the Heartland Dental Medical Office Portfolio Mortgage Loan (seeExhibit 34.4)

34.49      Park Bridge Lender Services LLC, as OperatingAdvisor of the Heartland Dental Medical Office Portfolio Mortgage Loan (seeExhibit 34.31)

34.50      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

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

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

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

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

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

34.56      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

34.57      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Arbor Hotel Portfolio MortgageLoan (see Exhibit 34.1)

34.58      KeyBank National Association, as Special Servicer ofthe Arbor Hotel Portfolio Mortgage Loan (see Exhibit 34.52)

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

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

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

34.62      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

34.63      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)

34.64      KeyBank National Association, as Special Servicerof the Moffett Towers II - Building V Mortgage Loan (see Exhibit 34.52)

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

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

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

34.68      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

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

34.70      KeyBank National Association, as Special Servicerof the Lakeside Apartments Mortgage Loan (see Exhibit 34.52)

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

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

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

34.74      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

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

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

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

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

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

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

34.81      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

34.82      Wells Fargo Bank, National Association, as PrimaryServicer of the Central Tower Office Mortgage Loan (see Exhibit 34.75)

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

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

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

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

34.87      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Central Tower Office Mortgage Loan (see Exhibit 34.80)

34.88      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

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

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

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

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

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

34.94      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

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

34.96      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the 57 East 11th Street MortgageLoan prior to July 19, 2021 (see Exhibit 34.1)

34.97      LNR Partners, LLC, as Special Servicer of the 57East 11th Street Mortgage Loan on and after July 19, 2021 (see Exhibit 34.40)

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

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

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

34.101    Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (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, as CertificateAdministrator

35.4        Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator on andafter November 1, 2021

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, NationalAssociation, as Primary Servicer of the 101 California Mortgage Loan (seeExhibit 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 3 Columbus Circle Mortgage Loan(Omitted. See Explanatory Notes.)

35.17      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Heartland Dental MedicalOffice Portfolio Mortgage Loan (see Exhibit 35.1)

35.18      Rialto Capital Advisors, LLC, as Special Servicerof the Heartland Dental Medical Office Portfolio Mortgage Loan (see Exhibit35.2)

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

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

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

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

35.23      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)

35.24      KeyBank National Association, as Special Servicerof the Moffett Towers II - Building V Mortgage Loan (see Exhibit 35.20)

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

35.26      KeyBank National Association, as Special Servicerof the Lakeside Apartments Mortgage Loan (see Exhibit 35.20)

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

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

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

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

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

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

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

35.34      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the 57 East 11th Street MortgageLoan prior to July 19, 2021 (see Exhibit 35.1)

35.35      LNR Partners, LLC, as Special Servicer of the 57 East 11th Street Mortgage Loanon and after July 19, 2021 (Omitted. See Explanatory Notes.)

99.1         Mortgage Loan Purchase Agreement, dated as of June 17, 2019,between J.P. Morgan Chase Commercial Mortgage Securities Corp. and JPMorganChase Bank, National Association (filed as Exhibit 99.1 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).

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 theRegistrant pursuant to Item 601 of Regulation 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 16, 2022