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Report of Independent Registered Public Accounting Firm

 

To the Board of Directors

Principal Global Investors,LLC and Principal Real Estate Investors, LLC

 

We have examined management’sassertion, included in the accompanying Management’s Assessment on Compliancewith Regulation AB Servicing Criteria, that Principal Global Investors, LLC andPrincipal Real Estate Investors, LLC, (the “Companies”) complied with theservicing criteria set forth in Item 1122 (d) of the Securities and ExchangeCommission’s Regulation AB for the commercial mortgage backed securitiesplatform as of and for the year ended December 31, 2023, except for 1122(d)(1)(ii)-(iii), 1122 (d)(3)(i)-(iv), 1122(d)(4)(ix), and 1122(d)(4)(xv),which the Companies have determined are not applicable to the activitiesperformed by them with respect to the servicing platform covered by thisreport. See Attachment A of Management’s Assessment on Compliance WithRegulation AB Criteria for the asset backed transactions covered by thisplatform. Management is responsible for the Companies’ compliance with thoseservicing criteria. Our responsibility is to express an opinion on management’sassertion about the Companies’ compliance with the servicing criteria based onour examination.

 

Our examination was conductedin accordance with attestation standards established by the American Instituteof Certified Public Accountants and the Public Company Accounting OversightBoard (United States) and, accordingly, included examining, on a test basis,evidence about the Companies’ compliance with the applicable servicing criteriaand performing such other procedures as we considered necessary in thecircumstances. Our examination included testing of less than all of theindividual asset backed transactions and securities that comprise the platform,testing of less than all of the servicing activities related to the Platformand determining whether the Companies processed those selected transactions andperformed those selected activities in compliance with the servicing criteriaand as permitted by Regulation AB Compliance and Disclosure Interpretations ofthe Division of Corporation Finance, Section 200.06, “Vendors Engaged byServicers” (C&DI 200.06). Furthermore, our procedures were limited to theselected transactions and servicing activities performed by the Companiesduring the period covered by this report. Our procedures were not designed todetermine whether errors may have occurred either prior to or subsequent to ourtests that may have affected the balances or amounts calculated or reported bythe Companies during the period covered by this report for the selectedtransactions or any other transactions. We believe that the evidence weobtained is sufficient and appropriate to provide a reasonable basis for ouropinion.

 

We are required to beindependent of Principal Global Investors, LLC and Principal Real EstateInvestors, LLC and to meet our other ethical responsibilities, in accordancewith the relevant ethical requirements related to our examination engagement.

Our examination does notprovide a legal determination on the Companies’ compliance with the servicingcriteria.

 

As described in management’sassertion, for servicing criteria 1122 (d)(1)(i) and 1122 (d)(4)(i), theCompanies have engaged various vendors to perform the activities required bythese servicing criteria. The Companies have determined that these vendors arenot considered a “servicer” as defined in Item 1101(j) of Regulation AB, andthe Companies have elected to take responsibility for assessing compliance withthe applicable servicing criteria applicable to each vendor as permitted byC&DI 200.06. As permitted by C&DI 200.06, the Companies have assertedthat they have policies and procedures in place designed to provide reasonableassurance that the vendors’ activities comply in all material respects withservicing criteria applicable to each vendor. The Companies are solelyresponsible for determining that they meet the SEC requirements to applyC&DI 200.06 for the vendors and related criteria as described in theirassertion, and we performed no procedures with respect to the Companies’eligibility to apply C&DI 200.06.

 

In our opinion, management’sassertion that the Companies complied with the servicing criteria set forth inItem 1122 (d) of the Securities and Exchange Commission’s Regulation AB,including servicing criteria 1122 (d)(1)(i) and 1122 (d)(4)(i) for whichcompliance is determined based on C&DI 200.06 as described above, as of andfor the year ended December 31, 2023 for the commercial mortgage backedsecurities platform, is fairly stated, in all material respects.

 

 

/s/ Ernest & Young LLP

 

February 21, 2024

 

 

 

A member firm of Ernst & YoungGlobal Limited