**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: 333-226486-08**

**Central Index Key Number of the issuing entity:0001780678**

**Wells Fargo Commercial MortgageTrust 2019-C52**

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

** **

**Central Index Key Number of the depositor: 0000850779**

**Wells Fargo Commercial MortgageSecurities, Inc.**

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

** **

**Central Index Key Number of the sponsor: 0000740906**

**Wells Fargo Bank, NationalAssociation**

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

** **

**Central Index Key Number of the sponsor: 0001624053**

**Argentic Real Estate Finance LLC**

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

** **

**Central Index Key Number of the sponsor: 0001592182**

**LMF Commercial, LLC**

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

**(formerly known as RialtoMortgage Finance, LLC)**

** **

**Central Index Key Number of the sponsor: 0001549574**

**Barclays Capital Real Estate Inc.**

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

** **

**Central Index Key Number of the sponsor: 0001541468**

**Ladder Capital Finance LLC**

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

** **

**Central Index Key Number of the sponsor: 0001722518**

**BSPRT CMBS Finance, LLC**

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

** **

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

**the issuing entity)** | **38-4123650**

**38-4123651**

**38-7221355**

**(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:**

**(704) 374-6161**

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 complyingwith any new or revised financial accounting standards provided pursuant toSection 13(a) of the Exchange Act.  o

Indicate by check mark whether the registrant has filed areport on and attestation to its management’s assessment of the effectivenessof its internal control over financial reporting under Section 404(b) of theSarbanes-Oxley Act (15 U.S.C. 7262(b)) by the registered public accounting firmthat prepared or issued its audit report. o

Indicate by check mark whether the registrant is a shellcompany (as defined in Rule 12b-2 of the Act).  o Yes ⌧ No

State the aggregate market value of the voting and non-votingcommon equity held by non-affiliates computed by reference to the price atwhich the common equity was last sold, or the average bid and asked price ofsuch common equity, as of the last business day of the registrant’s mostrecently completed second fiscal quarter.

Not applicable.

Indicate by check mark whether the registrant has filed alldocuments and reports required to be filed by Section 12, 13 or 15(d) of theSecurities Exchange Act of 1934 subsequent to the distribution of securitiesunder a plan confirmed by a court.  oYes oNo

Not applicable.

Indicate the number of shares outstanding of each of theregistrant’s classes of common stock, as of the latest practicable date.

Not applicable.

**DOCUMENTS INCORPORATED BY REFERENCE**

** **

List hereunder the following documents if incorporated byreference and the Part of the Form 10-K (e.g., Part I, Part II, etc.) intowhich the document is incorporated: (1) Any annual report to security holders;(2) Any proxy or information statement; and (3) Any prospectus filed pursuantto Rule 424(b) or (c) under the Securities Act of 1933. The listed documentsshould be clearly described for identification purposes (e.g., annual report tosecurity holders for fiscal year ended December 24, 1980).

Not applicable.

 

** **

**EXPLANATORY NOTES**

The Renaissance Center VI Mortgage Loan, theMount Kemble Mortgage Loan and the Del Mar Terrace Apartments Mortgage Loan,which constituted approximately 2.5%, 1.9% and 1.1%, respectively, of the assetpool of the issuing entity as of its cut-off date, are each an asset of theissuing entity and are each part of a loan combination that includes theRenaissance Center VI Mortgage Loan, the Mount Kemble Mortgage Loan or the DelMar Terrace Apartments Mortgage Loan and one other *pari passu* loan, eachof which is not an asset of the issuing entity. These loan combinations,including the Renaissance Center VI Mortgage Loan, the Mount Kemble MortgageLoan and the Del Mar Terrace Apartments Mortgage Loan, are being serviced andadministered pursuant to the Pooling and Servicing Agreement, which isincorporated by reference as Exhibit 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 Moffett Towers II - Buildings 3 & 4Mortgage Loan, which constituted approximately 5.5% of the asset pool of theissuing entity as of its cut-off date.  The Moffett Towers II - Buildings3 & 4 Mortgage Loan is an asset of the issuing entity and is part of a loancombination that includes the Moffett Towers II - Buildings 3 & 4 MortgageLoan, ten other *pari passu* loans and three subordinate companion loans,which are not assets of the issuing entity. A *pari passu* portion of theloan combination was securitized in the MFTII 2019-B3B4 Mortgage Trusttransaction (the “MFTII 2019-B3B4 Transaction”). This loan combination,including the Moffett Towers II - Buildings 3 & 4 Mortgage Loan, is beingserviced and administered pursuant to the trust and servicing agreement for theMFTII 2019-B3B4 Transaction, which is incorporated by reference as Exhibit 4.2to 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 El Con Center Mortgage Loan and the ShetlandPark Mortgage Loan, which constituted approximately 2.0% and 1.4%, respectively,of the asset pool of the issuing entity as of its cut-off date.  The ElCon Center Mortgage Loan and the Shetland Park Mortgage Loan are each an assetof the issuing entity and are each part of a loan combination that includes theEl Con Center Mortgage Loan or the Shetland Park Mortgage Loan and one other *paripassu* loan, each of which is not an asset of the issuing entity. The other *paripassu* portion of each loan combination was securitized in the Wells FargoCommercial Mortgage Trust 2019-C51 transaction, Commission File Number333-226486-06 (the “WFCM 2019-C51 Transaction”). These loancombinations, including the El Con Center Mortgage Loan and the Shetland ParkMortgage Loan, are being serviced and administered pursuant to the pooling andservicing agreement for the WFCM 2019-C51 Transaction, which is incorporated byreference as Exhibit 4.3 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 SoCal Retail Portfolio Mortgage Loan and theEmbassy Suites at Centennial Olympic Park Mortgage Loan, which constitutedapproximately 4.4% and 4.3%, respectively, of the asset pool of the issuingentity as of its cut-off date.  The SoCal Retail Portfolio Mortgage Loanand the Embassy Suites at Centennial Olympic Park Mortgage Loan are each anasset of the issuing entity and are each part of a loan combination thatincludes (a) with respect to the SoCal Retail Portfolio Mortgage Loan, sevenother *pari passu* loans, which are not assets of the issuing entity or(b) with respect to the Embassy Suites at Centennial Olympic Park MortgageLoan, two other *pari passu* loans, which are not assets of the issuingentity. A *pari passu* portion of each loan combination was securitized inthe Morgan Stanley Capital I Trust 2019-H7 transaction, Commission File Number333-227446-05 (the “MSC 2019-H7 Transaction”). These loan combinations,including the SoCal Retail Portfolio Mortgage Loan and the Embassy Suites atCentennial Olympic Park Mortgage Loan, are being serviced and administeredpursuant to the pooling and servicing agreement for the MSC 2019-H7Transaction, which is incorporated by reference as Exhibit 4.4 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 188 Spear Street Mortgage Loan, whichconstituted approximately 2.0% of the asset pool of the issuing entity as ofits cut-off date.  The 188 Spear Street Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the 188 SpearStreet Mortgage Loan and two other *pari passu* loans, which are notassets of the issuing entity.  This loan combination, including the 188Spear Street Mortgage Loan, was serviced under the Pooling and ServicingAgreement for the issuing entity prior to the closing of the securitization ofa *pari passu* portion of the 188 Spear Street loan combination in theBBCMS Mortgage Trust 2019-C4 transaction, Commission File Number 333-226850-03(the “BBCMS 2019-C4 Transaction”).  After the closing of the BBCMS2019-C4 Transaction on August 28, 2019, this loan combination, including the188 Spear Street Mortgage Loan was, and will continue to be, serviced andadministered pursuant to the pooling and servicing agreement with respect tothe BBCMS 2019-C4 Transaction, which is incorporated by reference as Exhibit4.5 to this Annual Report on Form 10-K.

The Exhibit Index describes exhibitsprovided by certain parties (in their capacities indicated on the ExhibitIndex) with respect to the Smoke Tree Village and Smoke Tree Commons MortgageLoan, which constituted approximately 1.1% of the asset pool of the issuingentity as of its cut-off date.  The Smoke Tree Village and Smoke TreeCommons Mortgage Loan is an asset of the issuing entity and is part of a loancombination that includes the Smoke Tree Village and Smoke Tree CommonsMortgage Loan and two other *pari passu* loans, which are not assets ofthe issuing entity.  This loan combination, including the Smoke TreeVillage and Smoke Tree Commons Mortgage Loan, was serviced under the Poolingand Servicing Agreement for the issuing entity prior to the closing of thesecuritization of a *pari passu* portion of the Smoke Tree Village andSmoke Tree Commons loan combination in the UBS Commercial Mortgage Trust2019-C17 transaction, Commission File Number 333-227784-04 (the “UBS2019-C17 Transaction”).  After the closing of the UBS 2019-C17 Transactionon October 15, 2019, this loan combination, including the Smoke Tree Villageand Smoke Tree Commons Mortgage Loan was, and will continue to be, serviced andadministered pursuant to the pooling and servicing agreement with respect tothe UBS 2019-C17 Transaction, which is incorporated by reference as Exhibit 4.6to 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 Inland Life Storage Portfolio Mortgage Loan,which constituted approximately 3.5% of the asset pool of the issuing entity asof its cut-off date.  The Inland Life Storage Portfolio Mortgage Loan isan asset of the issuing entity and is part of a loan combination that includesthe Inland Life Storage Portfolio Mortgage Loan and four other *pari passu*loans, which are not assets of the issuing entity.  This loan combination,including the Inland Life Storage Portfolio Mortgage Loan, was serviced underthe Pooling and Servicing Agreement for the issuing entity prior to the closingof the securitization of a *pari passu* portion of the Inland Life StoragePortfolio loan combination in the CF 2019-CF2 Mortgage Trust transaction,Commission File Number 333-228697-02 (the “CF 2019-CF2 Transaction”). After the closing of the CF 2019-CF2 Transaction on October 17, 2019, this loancombination, including the Inland Life Storage Portfolio Mortgage Loan was, andwill continue to be, serviced and administered pursuant to the pooling andservicing agreement with respect to the CF 2019-CF2 Transaction, which isincorporated by reference as Exhibit 4.7 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.

Wells Fargo Bank, NationalAssociation is the master servicer and certificate administrator of themortgage loans serviced under the Pooling and Servicing Agreement and theprimary servicer of the El Con Center Mortgage Loan, the 188 Spear StreetMortgage Loan, the Shetland Park Mortgage Loan and the Smoke Tree Village andSmoke Tree Commons Mortgage Loan. As a result, Wells Fargo Bank, 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 Wells Fargo Bank, National Association in the capacities described above arelisted in the Exhibit Index.

Wells Fargo Bank, National Association is the custodian ofthe mortgage loans serviced under the Pooling and Servicing Agreement, theMoffett Towers II - Buildings 3 & 4 Mortgage Loan, the SoCal RetailPortfolio Mortgage Loan, the Embassy Suites at Centennial Olympic Park MortgageLoan, the El Con Center Mortgage Loan, the 188 Spear Street Mortgage Loan, theShetland Park Mortgage Loan and the Smoke Tree Village and Smoke Tree CommonsMortgage Loan.  As a result, Wells Fargo Bank, National Association is aservicing function participant in the capacities described above, because it isservicing mortgage loans that constituted 5% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria and accountants’ attestation reports delivered byWells Fargo Bank, National Association in the capacities described above arelisted in the Exhibit Index.

Midland Loan Services, a Divisionof PNC Bank, National Association is the primary servicer of the SoCal RetailPortfolio Mortgage Loan and the Embassy Suites at Centennial Olympic ParkMortgage Loan.  These mortgage loans constitute more than 5%, but lessthan 10%, of the pool assets of the issuing entity.  Therefore, theDepositor included in this Annual Report on Form 10-K an assessment ofcompliance with applicable servicing criteria for Midland Loan Services, aDivision of PNC Bank, National Association and an accountants’ attestationreport pursuant to Item 1122 of Regulation AB because Midland Loan Services, aDivision of PNC Bank, National Association is servicing more than 5% of thepool assets.  However, the Depositor is not required to include in thisAnnual Report on Form 10-K a servicer compliance statement pursuant to Item1123 of Regulation AB of Midland Loan Services, a Division of PNC Bank,National Association because Midland Loan Services, a Division of PNC Bank,National Association is an unaffiliated servicer servicing less than 10% ofpool assets.

Argentic Services Company LP isthe special servicer of the mortgage loans serviced under the Pooling andServicing Agreement, the SoCal Retail Portfolio Mortgage Loan and the EmbassySuites at Centennial Olympic Park Mortgage Loan. As a result, Argentic ServicesCompany LP is a “servicer” as defined in Item 1108(a)(2)(iii) of Regulation AB,in the capacities described above, because it is servicing mortgage loans thatconstituted 10% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby Argentic Services Company LP in the capacities described above are listed inthe Exhibit Index.

Pentalpha Surveillance LLC is the operating advisor of themortgage loans serviced under the Pooling and Servicing Agreement, the SoCalRetail Portfolio Mortgage Loan, the Embassy Suites at Centennial Olympic ParkMortgage Loan, the El Con Center Mortgage Loan, the Shetland Park Mortgage Loanand the Smoke Tree Village and Smoke Tree Commons Mortgage Loan.  As aresult, Pentalpha Surveillance LLC is a servicing function participant in thecapacities described above, because it is servicing mortgage loans thatconstituted 5% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria andaccountants’ attestation reports delivered by Pentalpha Surveillance LLC in thecapacities described above are listed in the Exhibit Index.

KeyBank National Association is the primary servicer of theMoffett Towers II - Buildings 3 & 4 Mortgage Loan and the Inland LifeStorage Portfolio Mortgage Loan.  These mortgage loans constitute morethan 5%, but less than 10%, of the pool assets of the issuing entity. Therefore, the Depositor included in this Annual Report on Form 10-K anassessment of compliance with applicable servicing criteria for KeyBankNational Association and an accountants’ attestation report pursuant to Item1122 of Regulation AB because KeyBank National Association is servicing morethan 5% of the pool assets.  However, the Depositor is not required toinclude in this Annual Report on Form 10-K a servicer compliance statementpursuant to Item 1123 of Regulation AB of KeyBank National Association becauseKeyBank National Association is an unaffiliated servicer servicing less than10% of pool assets.

Park Bridge Lender Services LLC is the operating advisor ofthe Inland Life Storage Portfolio Mortgage Loan and the 188 Spear StreetMortgage Loan.  As a result, Park Bridge Lender Services LLC is aservicing function participant in the capacities described above, because it isservicing mortgage loans that constituted 5% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria and accountants’ attestation reports delivered byPark Bridge Lender Services LLC in the capacities described above are listed inthe Exhibit Index.

Wilmington Trust, NationalAssociation acts as trustee of the mortgage loans serviced under the Poolingand Servicing Agreement, the 188 Spear Street Mortgage Loan, the El Con CenterMortgage Loan, the Shetland Park Mortgage Loan and the Smoke Tree Village andSmoke Tree Commons Mortgage Loan.  Pursuant to the Pooling and ServicingAgreement, the pooling and servicing agreement for the WFCM 2019-C51Transaction, the pooling and servicing agreement for the BBCMS 2019-C4Transaction and the pooling and servicing agreement for the UBS 2019-C17Transaction, 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 regardingcollections, cash flows or distributions, and any interest or other feescharged for such advances, are made, reviewed and approved as specified in thetransaction agreements). However, during the reporting period, the trustee didnot 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 mortgage loans serviced under the Pooling and Servicing Agreement, the 188Spear Street Mortgage Loan, the El Con Center Mortgage Loan, the Shetland ParkMortgage Loan and the Smoke Tree Village and Smoke Tree Commons Mortgage Loanhave delivered one or more assessments of compliance with respect to Item1122(d)(2)(iii) of Regulation AB.

Wells Fargo Bank, NationalAssociation acts as trustee of the Moffett Towers II - Buildings 3 & 4Mortgage Loan, the SoCal Retail Portfolio Mortgage Loan and the Embassy Suitesat Centennial Olympic Park Mortgage Loan.  Pursuant to the trust andservicing agreement for the MFTII 2019-B3B4 Transaction and the pooling andservicing agreement for the MSC 2019-H7 Transaction, the trustee is required toprovide an assessment of compliance with applicable servicing criteria solelywith respect to Item 1122(d)(2)(iii) of Regulation AB (regarding advances offunds or guarantees regarding collections, cash flows or distributions, and anyinterest or other fees charged for such advances, are made, reviewed andapproved as specified in the transaction agreements). However, during thereporting period, the trustee did not perform any servicing function withrespect to the servicing criteria specified in Item 1122(d)(2)(iii) ofRegulation AB.  The master servicer or the special servicer, to the extentrequired, performed the servicing function identified with respect to Item1122(d)(2)(iii) of Regulation AB, and each such party included Item1122(d)(2)(iii) of Regulation AB in the assessment of compliance withapplicable servicing criteria and accountant’s attestation report for thesubject transaction.  As a result, this Annual Report on Form 10-K doesnot include an assessment of compliance with applicable servicing criteria ofthe trustee. One or more other servicers of the Moffett Towers II - Buildings 3& 4 Mortgage Loan, the SoCal Retail Portfolio Mortgage Loan and the EmbassySuites at Centennial Olympic Park Mortgage Loan have delivered one or moreassessments of compliance with respect to Item 1122(d)(2)(iii) of RegulationAB.

Citibank, N.A. acts as trustee ofthe Inland Life Storage Portfolio Mortgage Loan.  Pursuant to the poolingand servicing agreement for the CF 2019-CF2 Transaction, the trustee isrequired to provide an assessment of compliance with applicable servicingcriteria solely with respect to Item 1122(d)(2)(iii) of Regulation AB(regarding advances of funds or guarantees regarding collections, cash flows ordistributions, and any interest or other fees charged for such advances, aremade, reviewed and approved as specified in the transaction agreements).However, during the reporting period, the trustee did not perform any servicingfunction 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 Inland Life Storage PortfolioMortgage Loan have delivered one or more assessments of compliance with respectto Item 1122(d)(2)(iii) of Regulation AB.

This Annual Report on Form 10-Kincludes assessments of compliance with applicable servicing criteria andaccountants’ attestation reports from CoreLogic Solutions, LLC.  Thisentity was engaged by the master servicer under the Pooling and ServicingAgreement and the primary servicer of the El Con Center Mortgage Loan, theShetland Park Mortgage Loan, the 188 Spear Street Mortgage Loan and the SmokeTree Village and Smoke Tree Commons Mortgage Loan to remit tax paymentsreceived from the escrow accounts of borrowers to local taxing authorities, toreport tax amounts due, to verify tax parcel information, and to verifynon-escrow tax payments. These servicing functions are included within theservicing criteria set forth in Items 1122(d)(4)(xi) and 1122(d)(4)(xii) ofRegulation AB.  Therefore, under the principles-based definition of“servicer” set forth in Item 1101(j) of Regulation AB that looks to thefunctions that an entity performs, this vendor is a “servicer” for the purposesof Item 1122 of Regulation AB.  *See* Compliance and DisclosureInterpretations, 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 corporate trustservices 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 El Con Center Mortgage Loan, the Shetland Park MortgageLoan, the Moffett Towers II - Buildings 3 & 4 Mortgage Loan, the SoCalRetail Portfolio Mortgage Loan, the Embassy Suites at Centennial Olympic ParkMortgage Loan, the 188 Spear Street Mortgage Loan, the Smoke Tree Village andSmoke Tree Commons Mortgage Loan and the Inland Life Storage Portfolio MortgageLoan are omitted from this Annual Report on Form 10-K as the certificateadministrator pursuant to the related pooling and servicing agreement or trustand servicing agreement does not perform any activities that address servicingcriteria with respect to the issuing entity and because they are each not a“servicer” that meets the criteria in Item 1108(a)(2)(i) through (iii) of RegulationAB.

With respect to the *pari passu*loan combination that includes the Moffett Towers II - Buildings 3 & 4Mortgage Loan, the SoCal Retail Portfolio Mortgage Loan, the Embassy Suites atCentennial Olympic Park Mortgage Loan, the Shetland Park Mortgage Loan, theInland Life Storage Portfolio Mortgage Loan, the 188 Spear Street MortgageLoan, the El Con Center Mortgage Loan and the Smoke Tree Village and Smoke TreeCommons Mortgage Loan, (i) the reports on assessment of compliance withservicing criteria and attestation reports on assessment of compliance withservicing criteria of Greystone Servicing Company LLC (as successor to C-IIIAsset Management LLC) as special servicer of the El Con Center Mortgage Loanand the Shetland Park Mortgage Loan, Rialto Capital Advisors, LLC as specialservicer of the 188 Spear Street Mortgage Loan and the Smoke Tree Village andSmoke Tree Commons Mortgage Loan, LNR Partners, LLC as special servicer of theInland Life Storage Portfolio Mortgage Loan and Citibank, N.A. as custodian ofthe Inland Life Storage Portfolio Mortgage Loan, listed on the Exhibit Indexare omitted from this Annual Report on Form 10-K as they are not required to beincluded on this Annual Report on Form 10-K per Instruction 3 to Item 1122 of RegulationAB because they are parties performing activities that address servicingcriteria relating to 5% or less of the assets of the issuing entity; and (ii)the servicer compliance statements of KeyBank National Association as primaryservicer of the Moffett Towers II - Buildings 3 & 4 Mortgage Loan and theInland Life Storage Portfolio Mortgage Loan, Situs Holdings, LLC as specialservicer of the Moffett Towers II - Buildings 3 & 4 Mortgage Loan,Greystone Servicing Company LLC (as successor to C-III Asset Management LLC) asspecial servicer of the El Con Center Mortgage Loan and the Shetland ParkMortgage Loan, Midland Loan Services, a Division of PNC Bank, NationalAssociation as primary servicer of the SoCal Retail Portfolio Mortgage Loan andthe Embassy Suites at Centennial Olympic Park Mortgage Loan, Rialto CapitalAdvisors, LLC as special servicer of the 188 Spear Street Mortgage Loan and theSmoke Tree Village and Smoke Tree Commons Mortgage Loan and LNR Partners, LLCas special servicer of the Inland Life Storage Portfolio Mortgage Loan, listedon the Exhibit Index are omitted from this Annual Report on Form 10-K as theyare not required by Item 1123 of Regulation AB to be included on this AnnualReport on Form 10-K because they are each an unaffiliated party that is not a“servicer” that meets the criteria in Item 1108(a)(2)(i) through (iii) ofRegulation AB.

**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 assets heldby the issuing entity. 

 

**Item 1114(b)(2) of Regulation AB, Significant EnhancementProvider Financial Information.**

No entity or group of affiliated entities provides any external creditenhancement or other support for the certificates within this transaction asdescribed under Item 1114(a) of Regulation AB.

**Item 1115(b) of Regulation AB, Certain DerivativesInstruments (Financial Information).**

No entity or group of affiliated entities provides anyderivative instruments or other support for the certificates within thistransaction as described under Item 1115 of Regulation AB.

**Item 1117 of Regulation AB, Legal Proceedings.**

The registrant knows of no material pending legal proceedinginvolving the trust or any party related to the trust, other than routinelitigation incidental to the duties of those respective parties, and thefollowing, with respect to Wells Fargo Bank, National Association, as trustee,as certificate administrator and as 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 foregoingcases, 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 allegesthat Wells Fargo Bank failed to perform default oversight duties. Wells FargoBank has asserted counterclaims alleging that Nomura and Natixis failed toprovide Wells 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 August 20, 2019 pursuant to Rule 424(b)(2).

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

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 mortgage loans are attached hereto under Item15 to this Annual Report on Form 10-K. Attached as Exhibit AA to the Poolingand Servicing Agreement incorporated by reference as Exhibit 4.1 to this AnnualReport on Form 10-K is a chart identifying the entities participating in aservicing function for the 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 Moffett Towers II - Buildings 3& 4 Mortgage Loan, which is being serviced and administered pursuant to thetrust and servicing agreement for the MFTII 2019-B3B4 Transaction, are attachedhereto under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit Lto the trust and servicing agreement for the MFTII 2019-B3B4 Transactionincorporated by reference as Exhibit 4.2 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theMFTII 2019-B3B4 Transaction responsible for each applicable servicing criteriaset 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 El Con Center Mortgage Loan andthe Shetland Park Mortgage Loan, which are being serviced and administeredpursuant to the pooling and servicing agreement for the WFCM 2019-C51Transaction, are attached hereto under Item 15 to this Annual Report on Form10-K. Attached as Exhibit AA to the pooling and servicing agreement for theWFCM 2019-C51 Transaction incorporated by reference as Exhibit 4.3 to thisAnnual Report on Form 10-K is a chart identifying the entities participating ina servicing function for the WFCM 2019-C51 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 SoCal Retail Portfolio MortgageLoan and the Embassy Suites at Centennial Olympic Park Mortgage Loan, which arebeing serviced and administered pursuant to the pooling and servicing agreementfor the MSC 2019-H7 Transaction, are attached hereto under Item 15 to this AnnualReport on Form 10-K. Attached as Exhibit AA to the pooling and servicingagreement for the MSC 2019-H7 Transaction incorporated by reference as Exhibit4.4 to this Annual Report on Form 10-K is a chart identifying the entitiesparticipating in a servicing function for the MSC 2019-H7 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 188 Spear Street Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the BBCMS 2019-C4 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-C4 Transaction incorporated by referenceas Exhibit 4.5 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the BBCMS 2019-C4Transaction 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 Smoke Tree Village and Smoke TreeCommons Mortgage Loan, which is being serviced and administered pursuant to thepooling and servicing agreement for the UBS 2019-C17 Transaction, are attachedhereto under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit Zto the pooling and servicing agreement for the UBS 2019-C17 Transactionincorporated by reference as Exhibit 4.6 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theUBS 2019-C17 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 Inland Life Storage PortfolioMortgage Loan, which is being serviced and administered pursuant to the poolingand servicing agreement for the CF 2019-CF2 Transaction, are attached hereto underItem 15 to this Annual Report on Form 10-K. Attached as Schedule II to thepooling and servicing agreement for the CF 2019-CF2 Transaction incorporated byreference as Exhibit 4.7 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the CF2019-CF2 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

**Item 1123 of Regulation AB, Servicer Compliance Statement.**

The servicer compliance statements are attached as Exhibitsto this Annual Report on Form 10-K.

**PART IV**

**Item 15. 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          Poolingand Servicing Agreement, dated as of August 1, 2019, by and among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, LNR Partners, LLC, as Special Servicer, WellsFargo Bank, National Association, as Certificate Administrator, WilmingtonTrust, 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 August 20, 2019 underCommission File No. 333-226486-08 and incorporated by reference herein). 

4.2          Trustand Servicing Agreement, dated as of July 11, 2019, by and among BarclaysCommercial Mortgage Securities LLC, as Depositor, KeyBank National Association,as Servicer, Situs Holdings, LLC, as Special Servicer, Wells Fargo Bank,National Association, as Certificate Administrator and Custodian, Wells FargoBank, National Association, as Trustee (filed as Exhibit 99.7 to theregistrant’s Current Report on Form 8-K filed on August 20, 2019 underCommission File No. 333-226486-08 and incorporated by reference herein).

4.3          Poolingand Servicing Agreement, dated as of July 1, 2019, by and among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, C-III Asset Management LLC, as 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 99.9 to the registrant’s Current Report on Form 8-Kfiled on August 20, 2019 under Commission File No. 333-226486-08 andincorporated by reference herein).

4.4          Poolingand Servicing Agreement, dated as of July 1, 2019, by and among Morgan StanleyCapital I Inc., as Depositor, Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer, LNR Partners, LLC, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administratorand Trustee, and Pentalpha Surveillance LLC, as Operating Advisor and AssetRepresentations Reviewer (filed as Exhibit 99.8 to the registrant’s CurrentReport on Form 8-K filed on August 20, 2019 under Commission File No.333-226486-08 and incorporated by reference herein).

4.5          Poolingand Servicing Agreement, dated as of August 1, 2019, by and among BarclaysCommercial Mortgage Securities LLC, as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, Rialto Capital Advisors, LLC, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administratorand Custodian, Wilmington Trust, National Association, as Trustee, and ParkBridge Lender Services LLC, as Operating Advisor and Asset RepresentationsReviewer (filed as Exhibit 99.1 to the registrant’s Current Report on Form 8-Kfiled on September 3, 2019 under Commission File No. 333-226486-08 and incorporatedby reference herein).

4.6          Poolingand Servicing Agreement, dated as of October 1, 2019, by and among UBSCommercial Mortgage Securitization Corp., as Depositor, Wells Fargo Bank,National Association, as Master Servicer, Rialto Capital Advisors, LLC, asSpecial Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator, Wilmington Trust, National Association, as Trustee, andPentalpha Surveillance LLC, as Operating Advisor and Asset RepresentationsReviewer (filed as Exhibit 99.1 to the registrant’s Current Report on Form 8-Kfiled on October 21, 2019 under Commission File No. 333-226486-08 andincorporated by reference herein).

4.7          Poolingand Servicing Agreement, dated as of October 1, 2019, by and among CCRECommercial Mortgage Securities, L.P., as Depositor, KeyBank NationalAssociation, as Master Servicer and as a Special Servicer solely with respectto The Stanwix Whole Loan, LNR Partners, LLC, as a Special Servicer, Citibank,N.A., as Trustee, Citibank, N.A., as Certificate Administrator, Paying Agentand Custodian, Park Bridge Lender Services LLC, as Operating Advisor, and ParkBridge Lender LLC, as Asset Representations Reviewer (filed as Exhibit 99.1 tothe registrant’s Current Report on Form 8-K filed on October 23, 2019 underCommission File No. 333-226486-08 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        Wells Fargo Bank, National Association, as MasterServicer

33.2        Argentic Services Company LP, as Special Servicer

33.3        Wilmington Trust, National Association, as Trustee (Omitted. See ExplanatoryNotes.)

33.4        Wells Fargo Bank, National Association, asCertificate Administrator

33.5        Wells Fargo Bank, National Association, asCustodian

33.6        Pentalpha Surveillance LLC, as Operating Advisor

33.7        CoreLogic Solutions, LLC, as Servicing FunctionParticipant

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

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

33.10      Wells Fargo Bank, National Association, as PrimaryServicer of the Renaissance Center VI Mortgage Loan (see Exhibit 33.1)

33.11      Argentic Services Company LP, as Special Servicerof the Renaissance Center VI Mortgage Loan (see Exhibit 33.2)

33.12      Wilmington Trust, National Association, as Trustee of the Renaissance Center VIMortgage Loan (Omitted. See Explanatory Notes.)

33.13      Wells Fargo Bank, National Association, asCustodian of the Renaissance Center VI Mortgage Loan (see Exhibit 33.5)

33.14      Pentalpha Surveillance LLC, as Operating Advisor ofthe Renaissance Center VI Mortgage Loan (see Exhibit 33.6)

33.15      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Renaissance Center VI Mortgage Loan (see Exhibit 33.7)

33.16      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.17      Wells Fargo Bank, National Association, as PrimaryServicer of the Mount Kemble Mortgage Loan (see Exhibit 33.1)

33.18      Argentic Services Company LP, as Special Servicerof the Mount Kemble Mortgage Loan (see Exhibit 33.2)

33.19      Wilmington Trust, National Association, as Trustee of the Mount Kemble MortgageLoan (Omitted. See Explanatory Notes.)

33.20      Wells Fargo Bank, National Association, asCustodian of the Mount Kemble Mortgage Loan (see Exhibit 33.5)

33.21      Pentalpha Surveillance LLC, as Operating Advisor ofthe Mount Kemble Mortgage Loan (see Exhibit 33.6)

33.22      CoreLogic Solutions, LLC, as Servicing Function Participantof the Mount Kemble Mortgage Loan (see Exhibit 33.7)

33.23      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.24      Wells Fargo Bank, National Association, as PrimaryServicer of the Del Mar Terrace Apartments Mortgage Loan (see Exhibit 33.1)

33.25      Argentic Services Company LP, as Special Servicerof the Del Mar Terrace Apartments Mortgage Loan (see Exhibit 33.2)

33.26      Wilmington Trust, National Association, as Trustee of the Del Mar TerraceApartments Mortgage Loan (Omitted. See Explanatory Notes.)

33.27      Wells Fargo Bank, National Association, asCustodian of the Del Mar Terrace Apartments Mortgage Loan (see Exhibit 33.5)

33.28      Pentalpha Surveillance LLC, as Operating Advisor ofthe Del Mar Terrace Apartments Mortgage Loan (see Exhibit 33.6)

33.29      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Del Mar Terrace Apartments Mortgage Loan (see Exhibit 33.7)

33.30      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.31      KeyBank National Association, as Primary Servicerof the Moffett Towers II - Buildings 3 & 4 Mortgage Loan

33.32      Situs Holdings, LLC, as Special Servicer of theMoffett Towers II - Buildings 3 & 4 Mortgage Loan

33.33      Wells Fargo Bank, National Association, as Trustee of the Moffett Towers II -Buildings 3 & 4 Mortgage Loan (Omitted. See Explanatory Notes.)

33.34      Wells Fargo Bank, National Association, asCustodian of the Moffett Towers II - Buildings 3 & 4 Mortgage Loan (seeExhibit 33.5)

33.35      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.36      Wells Fargo Bank, National Association, as PrimaryServicer of the El Con Center Mortgage Loan (see Exhibit 33.1)

33.37      Greystone Servicing Company LLC (as successor to C-III Asset Management LLC),as Special Servicer of the El Con Center Mortgage Loan (Omitted. SeeExplanatory Notes.)

33.38      Wilmington Trust, National Association, as Trustee of the El Con CenterMortgage Loan (Omitted. See Explanatory Notes.)

33.39      Wells Fargo Bank, National Association, asCustodian of the El Con Center Mortgage Loan (see Exhibit 33.5)

33.40      Pentalpha Surveillance LLC, as Operating Advisor ofthe El Con Center Mortgage Loan (see Exhibit 33.6)

33.41      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the El Con Center Mortgage Loan (see Exhibit 33.7)

33.42      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.43      Wells Fargo Bank, National Association, as PrimaryServicer of the Shetland Park Mortgage Loan (see Exhibit 33.1)

33.44      Greystone Servicing Company LLC (as successor to C-III Asset Management LLC),as Special Servicer of the Shetland Park Mortgage Loan (Omitted. SeeExplanatory Notes.)

33.45      Wilmington Trust, National Association, as Trustee of the Shetland ParkMortgage Loan (Omitted. See Explanatory Notes.)

33.46      Wells Fargo Bank, National Association, asCustodian of the Shetland Park Mortgage Loan (see Exhibit 33.5)

33.47      Pentalpha Surveillance LLC, as Operating Advisor ofthe Shetland Park Mortgage Loan (see Exhibit 33.6)

33.48      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Shetland Park Mortgage Loan (see Exhibit 33.7)

33.49      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.50      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the SoCal Retail PortfolioMortgage Loan

33.51      Argentic Services Company LP, as Special Servicerof the SoCal Retail Portfolio Mortgage Loan (see Exhibit 33.2)

33.52      Wells Fargo Bank, National Association, as Trustee of the SoCal RetailPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.53      Wells Fargo Bank, National Association, asCustodian of the SoCal Retail Portfolio Mortgage Loan (see Exhibit 33.5)

33.54      Pentalpha Surveillance LLC, as Operating Advisor ofthe SoCal Retail Portfolio Mortgage Loan (see Exhibit 33.6)

33.55      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.56      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Embassy Suites at CentennialOlympic Park Mortgage Loan (see Exhibit 33.50)

33.57      Argentic Services Company LP, as Special Servicerof the Embassy Suites at Centennial Olympic Park Mortgage Loan (see Exhibit33.2)

33.58      Wells Fargo Bank, National Association, as Trustee of the Embassy Suites atCentennial Olympic Park Mortgage Loan (Omitted. See Explanatory Notes.)

33.59      Wells Fargo Bank, National Association, asCustodian of the Embassy Suites at Centennial Olympic Park Mortgage Loan (seeExhibit 33.5)

33.60      Pentalpha Surveillance LLC, as Operating Advisor ofthe Embassy Suites at Centennial Olympic Park Mortgage Loan (see Exhibit 33.6)

33.61      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.62      Wells Fargo Bank, National Association, as PrimaryServicer of the 188 Spear Street Mortgage Loan (see Exhibit 33.1)

33.63      Rialto Capital Advisors, LLC, as Special Servicer of the 188 Spear StreetMortgage Loan (Omitted. See Explanatory Notes.)

33.64      Wilmington Trust, National Association, as Trustee of the 188 Spear StreetMortgage Loan (Omitted. See Explanatory Notes.)

33.65      Wells Fargo Bank, National Association, asCustodian of the 188 Spear Street Mortgage Loan (see Exhibit 33.5)

33.66      Park Bridge Lender Services LLC, as OperatingAdvisor of the 188 Spear Street Mortgage Loan

33.67      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 188 Spear Street Mortgage Loan (see Exhibit 33.7)

33.68      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.69      Wells Fargo Bank, National Association, as PrimaryServicer of the Smoke Tree Village and Smoke Tree Commons Mortgage Loan (seeExhibit 33.1)

33.70      Rialto Capital Advisors, LLC, as Special Servicer of the Smoke Tree Village andSmoke Tree Commons Mortgage Loan (Omitted. See Explanatory Notes.)

33.71      Wilmington Trust, National Association, as Trustee of the Smoke Tree Villageand Smoke Tree Commons Mortgage Loan (Omitted. See Explanatory Notes.)

33.72      Wells Fargo Bank, National Association, asCustodian of the Smoke Tree Village and Smoke Tree Commons Mortgage Loan (seeExhibit 33.5)

33.73      Pentalpha Surveillance LLC, as Operating Advisor ofthe Smoke Tree Village and Smoke Tree Commons Mortgage Loan (see Exhibit 33.6)

33.74      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Smoke Tree Village and Smoke Tree Commons Mortgage Loan (seeExhibit 33.7)

33.75      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.76      KeyBank National Association, as Primary Servicerof the Inland Life Storage Portfolio Mortgage Loan (see Exhibit 33.31)

33.77      LNR Partners, LLC, as Special Servicer of the Inland Life Storage PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.78      Citibank, N.A., as Trustee and Custodian of the Inland Life Storage Portfolio MortgageLoan (Omitted. See Explanatory Notes.)

33.79      Park Bridge Lender Services LLC, as OperatingAdvisor of the Inland Life Storage Portfolio Mortgage Loan (see Exhibit 33.66)

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

34.1        Wells Fargo Bank, National Association, as MasterServicer

34.2        Argentic Services Company LP, as Special Servicer

34.3        Wilmington Trust, National Association, as Trustee (Omitted. See ExplanatoryNotes.)

34.4        Wells Fargo Bank, National Association, asCertificate Administrator

34.5        Wells Fargo Bank, National Association, asCustodian

34.6        Pentalpha Surveillance LLC, as Operating Advisor

34.7        CoreLogic Solutions, LLC, as Servicing FunctionParticipant

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

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

34.10      Wells Fargo Bank, National Association, as PrimaryServicer of the Renaissance Center VI Mortgage Loan (see Exhibit 34.1)

34.11      Argentic Services Company LP, as Special Servicerof the Renaissance Center VI Mortgage Loan (see Exhibit 34.2)

34.12      Wilmington Trust, National Association, as Trustee of the Renaissance Center VIMortgage Loan (Omitted. See Explanatory Notes.)

34.13      Wells Fargo Bank, National Association, asCustodian of the Renaissance Center VI Mortgage Loan (see Exhibit 34.5)

34.14      Pentalpha Surveillance LLC, as Operating Advisor ofthe Renaissance Center VI Mortgage Loan (see Exhibit 34.6)

34.15      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Renaissance Center VI Mortgage Loan (see Exhibit 34.7)

34.16      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1, 2021(see Exhibit 34.9)

34.17      Wells Fargo Bank, National Association, as PrimaryServicer of the Mount Kemble Mortgage Loan (see Exhibit 34.1)

34.18      Argentic Services Company LP, as Special Servicerof the Mount Kemble Mortgage Loan (see Exhibit 34.2)

34.19      Wilmington Trust, National Association, as Trustee of the Mount Kemble MortgageLoan (Omitted. See Explanatory Notes.)

34.20      Wells Fargo Bank, National Association, asCustodian of the Mount Kemble Mortgage Loan (see Exhibit 34.5)

34.21      Pentalpha Surveillance LLC, as Operating Advisor ofthe Mount Kemble Mortgage Loan (see Exhibit 34.6)

34.22      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Mount Kemble Mortgage Loan (see Exhibit 34.7)

34.23      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

34.24      Wells Fargo Bank, National Association, as PrimaryServicer of the Del Mar Terrace Apartments Mortgage Loan (see Exhibit 34.1)

34.25      Argentic Services Company LP, as Special Servicerof the Del Mar Terrace Apartments Mortgage Loan (see Exhibit 34.2)

34.26      Wilmington Trust, National Association, as Trustee of the Del Mar TerraceApartments Mortgage Loan (Omitted. See Explanatory Notes.)

34.27      Wells Fargo Bank, National Association, asCustodian of the Del Mar Terrace Apartments Mortgage Loan (see Exhibit 34.5)

34.28      Pentalpha Surveillance LLC, as Operating Advisor ofthe Del Mar Terrace Apartments Mortgage Loan (see Exhibit 34.6)

34.29      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Del Mar Terrace Apartments Mortgage Loan (see Exhibit 34.7)

34.30      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1, 2021(see Exhibit 34.9)

34.31      KeyBank National Association, as Primary Servicerof the Moffett Towers II - Buildings 3 & 4 Mortgage Loan

34.32      Situs Holdings, LLC, as Special Servicer of theMoffett Towers II - Buildings 3 & 4 Mortgage Loan

34.33      Wells Fargo Bank, National Association, as Trustee of the Moffett Towers II -Buildings 3 & 4 Mortgage Loan (Omitted. See Explanatory Notes.)

34.34      Wells Fargo Bank, National Association, asCustodian of the Moffett Towers II - Buildings 3 & 4 Mortgage Loan (seeExhibit 34.5)

34.35      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

34.36      Wells Fargo Bank, National Association, as PrimaryServicer of the El Con Center Mortgage Loan (see Exhibit 34.1)

34.37      Greystone Servicing Company LLC (as successor to C-III Asset Management LLC),as Special Servicer of the El Con Center Mortgage Loan (Omitted. SeeExplanatory Notes.)

34.38      Wilmington Trust, National Association, as Trustee of the El Con CenterMortgage Loan (Omitted. See Explanatory Notes.)

34.39      Wells Fargo Bank, National Association, asCustodian of the El Con Center Mortgage Loan (see Exhibit 34.5)

34.40      Pentalpha Surveillance LLC, as Operating Advisor ofthe El Con Center Mortgage Loan (see Exhibit 34.6)

34.41      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the El Con Center Mortgage Loan (see Exhibit 34.7)

34.42      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

34.43      Wells Fargo Bank, National Association, as PrimaryServicer of the Shetland Park Mortgage Loan (see Exhibit 34.1)

34.44      Greystone Servicing Company LLC (as successor to C-III Asset Management LLC),as Special Servicer of the Shetland Park Mortgage Loan (Omitted. SeeExplanatory Notes.)

34.45      Wilmington Trust, National Association, as Trustee of the Shetland ParkMortgage Loan (Omitted. See Explanatory Notes.)

34.46      Wells Fargo Bank, National Association, asCustodian of the Shetland Park Mortgage Loan (see Exhibit 34.5)

34.47      Pentalpha Surveillance LLC, as Operating Advisor ofthe Shetland Park Mortgage Loan (see Exhibit 34.6)

34.48      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Shetland Park Mortgage Loan (see Exhibit 34.7)

34.49      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

34.50      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the SoCal Retail PortfolioMortgage Loan

34.51      Argentic Services Company LP, as Special Servicerof the SoCal Retail Portfolio Mortgage Loan (see Exhibit 34.2)

34.52      Wells Fargo Bank, National Association, as Trustee of the SoCal RetailPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.53      Wells Fargo Bank, National Association, asCustodian of the SoCal Retail Portfolio Mortgage Loan (see Exhibit 34.5)

34.54      Pentalpha Surveillance LLC, as Operating Advisor ofthe SoCal Retail Portfolio Mortgage Loan (see Exhibit 34.6)

34.55      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

34.56      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Embassy Suites at CentennialOlympic Park Mortgage Loan (see Exhibit 34.50)

34.57      Argentic Services Company LP, as Special Servicerof the Embassy Suites at Centennial Olympic Park Mortgage Loan (see Exhibit34.2)

34.58      Wells Fargo Bank, National Association, as Trustee of the Embassy Suites atCentennial Olympic Park Mortgage Loan (Omitted. See Explanatory Notes.)

34.59      Wells Fargo Bank, National Association, asCustodian of the Embassy Suites at Centennial Olympic Park Mortgage Loan (seeExhibit 34.5)

34.60      Pentalpha Surveillance LLC, as Operating Advisor ofthe Embassy Suites at Centennial Olympic Park Mortgage Loan (see Exhibit 34.6)

34.61      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

34.62      Wells Fargo Bank, National Association, as PrimaryServicer of the 188 Spear Street Mortgage Loan (see Exhibit 34.1)

34.63      Rialto Capital Advisors, LLC, as Special Servicer of the 188 Spear StreetMortgage Loan (Omitted. See Explanatory Notes.)

34.64      Wilmington Trust, National Association, as Trustee of the 188 Spear StreetMortgage Loan (Omitted. See Explanatory Notes.)

34.65      Wells Fargo Bank, National Association, asCustodian of the 188 Spear Street Mortgage Loan (see Exhibit 34.5)

34.66      Park Bridge Lender Services LLC, as OperatingAdvisor of the 188 Spear Street Mortgage Loan

34.67      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 188 Spear Street Mortgage Loan (see Exhibit 34.7)

34.68      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

34.69      Wells Fargo Bank, National Association, as PrimaryServicer of the Smoke Tree Village and Smoke Tree Commons Mortgage Loan (seeExhibit 34.1)

34.70      Rialto Capital Advisors, LLC, as Special Servicer of the Smoke Tree Village andSmoke Tree Commons Mortgage Loan (Omitted. See Explanatory Notes.)

34.71      Wilmington Trust, National Association, as Trustee of the Smoke Tree Villageand Smoke Tree Commons Mortgage Loan (Omitted. See Explanatory Notes.)

34.72      Wells Fargo Bank, National Association, asCustodian of the Smoke Tree Village and Smoke Tree Commons Mortgage Loan (seeExhibit 34.5)

34.73      Pentalpha Surveillance LLC, as Operating Advisor ofthe Smoke Tree Village and Smoke Tree Commons Mortgage Loan (see Exhibit 34.6)

34.74      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Smoke Tree Village and Smoke Tree Commons Mortgage Loan (seeExhibit 34.7)

34.75      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

34.76      KeyBank National Association, as Primary Servicerof the Inland Life Storage Portfolio Mortgage Loan (see Exhibit 34.31)

34.77      LNR Partners, LLC, as Special Servicer of the Inland Life Storage PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.78      Citibank, N.A., as Trustee and Custodian of the Inland Life Storage PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.79      Park Bridge Lender Services LLC, as OperatingAdvisor of the Inland Life Storage Portfolio Mortgage Loan (see Exhibit 34.66)

35           Servicer compliance statements.

35.1        Wells Fargo Bank, National Association, as MasterServicer

35.2        Argentic Services Company LP, as Special Servicer

35.3        Wells Fargo Bank, National Association, asCertificate Administrator

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

35.5        Wells Fargo Bank, National Association, as PrimaryServicer of the Renaissance Center VI Mortgage Loan (see Exhibit 35.1)

35.6        Argentic Services Company LP, as Special Servicerof the Renaissance Center VI Mortgage Loan (see Exhibit 35.2)

35.7        Wells Fargo Bank, National Association, as PrimaryServicer of the Mount Kemble Mortgage Loan (see Exhibit 35.1)

35.8        Argentic Services Company LP, as Special Servicerof the Mount Kemble Mortgage Loan (see Exhibit 35.2)

35.9        Wells Fargo Bank, National Association, as PrimaryServicer of the Del Mar Terrace Apartments Mortgage Loan (see Exhibit 35.1)

35.10      Argentic Services Company LP, as Special Servicerof the Del Mar Terrace Apartments Mortgage Loan (see Exhibit 35.2)

35.11      KeyBank National Association, as Primary Servicer of the Moffett Towers II -Buildings 3 & 4 Mortgage Loan (Omitted. See Explanatory Notes.)

35.12      Situs Holdings, LLC, as Special Servicer of the Moffett Towers II - Buildings 3& 4 Mortgage Loan (Omitted. See Explanatory Notes.)

35.13      Wells Fargo Bank, National Association, as PrimaryServicer of the El Con Center Mortgage Loan (see Exhibit 35.1)

35.14      Greystone Servicing Company LLC (as successor to C-III Asset Management LLC),as Special Servicer of the El Con Center Mortgage Loan (Omitted. SeeExplanatory Notes.)

35.15      Wells Fargo Bank, National Association, as PrimaryServicer of the Shetland Park Mortgage Loan (see Exhibit 35.1)

35.16      Greystone Servicing Company LLC (as successor to C-III Asset Management LLC),as Special Servicer of the Shetland Park Mortgage Loan (Omitted. See ExplanatoryNotes.)

35.17      Midland Loan Services, a Division of PNC Bank, National Association, as PrimaryServicer of the SoCal Retail Portfolio Mortgage Loan (Omitted. See ExplanatoryNotes.)

35.18      Argentic Services Company LP, as Special Servicerof the SoCal Retail Portfolio Mortgage Loan (see Exhibit 35.2)

35.19      Midland Loan Services, a Division of PNC Bank, National Association, as PrimaryServicer of the Embassy Suites at Centennial Olympic Park Mortgage Loan(Omitted. See Explanatory Notes.)

35.20      Argentic Services Company LP, as Special Servicerof the Embassy Suites at Centennial Olympic Park Mortgage Loan (see Exhibit35.2)

35.21      Wells Fargo Bank, National Association, as PrimaryServicer of the 188 Spear Street Mortgage Loan (see Exhibit 35.1)

35.22      Rialto Capital Advisors, LLC, as Special Servicer of the 188 Spear StreetMortgage Loan (Omitted. See Explanatory Notes.)

35.23      Wells Fargo Bank, National Association, as PrimaryServicer of the Smoke Tree Village and Smoke Tree Commons Mortgage Loan (seeExhibit 35.1)

35.24      Rialto Capital Advisors, LLC, as Special Servicer of the Smoke Tree Village andSmoke Tree Commons Mortgage Loan (Omitted. See Explanatory Notes.)

35.25      KeyBank National Association, as Primary Servicer of the Inland Life StoragePortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

35.26      LNR Partners, LLC, as Special Servicer of the Inland Life Storage PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

99.1        MortgageLoan Purchase Agreement, dated as of August 5, 2019, between Wells FargoCommercial Mortgage Securities, Inc. and Wells Fargo Bank, National Association(filed as Exhibit 99.6 to the registrant’s Current Report on Form 8-K filed onAugust 20, 2019 under Commission File No. 333-226486-08 and incorporated byreference herein)

99.2        MortgageLoan Purchase Agreement, dated as of August 5, 2019, between Wells FargoCommercial Mortgage Securities, Inc. and Argentic Real Estate Finance LLC(filed as Exhibit 99.1 to the registrant’s Current Report on Form 8-K filed onAugust 20, 2019 under Commission File No. 333-226486-08 and incorporated byreference herein)

99.3        MortgageLoan Purchase Agreement, dated as of August 5, 2019, between Wells FargoCommercial Mortgage Securities, Inc. and Rialto Mortgage Finance, LLC (filed asExhibit 99.2 to the registrant’s Current Report on Form 8-K filed on August 20,2019 under Commission File No. 333-226486-08 and incorporated by referenceherein)

99.4        MortgageLoan Purchase Agreement, dated as of August 5, 2019, between Wells FargoCommercial Mortgage Securities, Inc., Barclays Capital Real Estate Inc. andBarclays Capital Holdings Inc. (filed as Exhibit 99.3 to the registrant’sCurrent Report on Form 8-K filed on August 20, 2019 under Commission File No.333-226486-08 and incorporated by reference herein)

99.5        MortgageLoan Purchase Agreement, dated as of August 5, 2019, among Wells FargoCommercial Mortgage Securities, Inc., Ladder Capital Finance LLC, LadderCapital Finance Holdings LLLP, Series REIT of Ladder Capital Finance Holdings LLLP,Series TRS of Ladder Capital Finance Holdings LLLP (filed as Exhibit 99.4 tothe registrant’s Current Report on Form 8-K filed on August 20, 2019 underCommission File No. 333-226486-08 and incorporated by reference herein)

99.6        MortgageLoan Purchase Agreement, dated as of August 5, 2019, between Wells FargoCommercial Mortgage Securities, Inc., BSPRT CMBS Finance, LLC and BenefitStreet Partners Realty Trust, Inc. (filed as Exhibit 99.5 to the registrant’sCurrent Report on Form 8-K filed on August 20, 2019 under Commission File No.333-226486-08 and incorporated by reference herein)

99.7        Co-LenderAgreement, dated as of July 11, 2019, by and among Barclays Bank PLC, as NoteA-1-A Holder and Note B-1 Holder, Barclays Capital Real Estate Inc., as InitialNote A-1-B Holder, Initial Note A-1-D Holder and Initial Note A-1-E Holder,Bank of America, N.A., as Note A-1-C Holder, Deutsche Bank AG, New York Branch,as Initial Note A-2-A Holder, Initial Note A-2-B Holder, Initial Note A-2-CHolder and Initial Note B-2 Holder, and Goldman Sachs Bank USA, as Initial NoteA-3-A Holder, Initial Note A-3-B Holder, Initial Note A-3-C Holder, and InitialNote B-3 Holder (filed as Exhibit 99.10 to the registrant’s Current Report onForm 8-K filed on August 20, 2019 under Commission File No. 333-226486-08 andincorporated by reference herein)

99.8        AgreementBetween Note Holders, dated as of June 19, 2019, by and between Argentic Real EstateFinance LLC, as Initial Note A-1 Holder, Argentic Real Estate Finance LLC, asInitial Note A-2 Holder, Argentic Real Estate Finance LLC, as Initial Note A-3Holder, Argentic Real Estate Finance LLC, as Initial Note A-4 Holder, ArgenticReal Estate Finance LLC, as Initial Note A-5 Holder, Argentic Real EstateFinance LLC, as Initial Note A-6 Holder, Argentic Real Estate Finance LLC, asInitial Note A-7 Holder, and Argentic Real Estate Finance LLC, as Initial NoteA-8 Holder (filed as Exhibit 99.11 to the registrant’s Current Report on Form8-K filed on August 20, 2019 under Commission File No. 333-226486-08 andincorporated by reference herein)

99.9        Co-LenderAgreement, dated as of July 6, 2019, by and between SPREF WH II LLC, as InitialNote A-1 Holder, SPREF WH II LLC, as Initial Note A-2 Holder, SPREF WH II LLC,as Initial Note A-3 Holder, SPREF WH II LLC, as Initial Note A-4 Holder, SPREFWH II LLC, as Initial Note A-5 Holder, and SPREF WH II LLC, as Initial Note A-6Holder (filed as Exhibit 99.12 to the registrant’s Current Report on Form 8-Kfiled on August 20, 2019 under Commission File No. 333-226486-08 andincorporated by reference herein) 

99.10      AgreementBetween Note Holders, dated as of July 2, 2019, by and between KeyBank NationalAssociation, as Initial Note A-1-A Holder, Initial Note A-1-B Holder andInitial Note A-1-C Holder, and Barclays Capital Real Estate Inc., as InitialNote A-2-A Holder and Initial Note A-2-B Holder (filed as Exhibit 99.13 to theregistrant’s Current Report on Form 8-K filed on August 20, 2019 underCommission File No. 333-226486-08 and incorporated by reference herein) 

99.11      Co-LenderAgreement, dated as of July 25, 2019, by and between BSPRT Finance Sub-LenderI, LLC, as Note A-1 Holder, and BSPRT Finance Sub-Lender I, LLC, as Note A-2Holder (filed as Exhibit 99.14 to the registrant’s Current Report on Form 8-Kfiled on August 20, 2019 under Commission File No. 333-226486-08 andincorporated by reference herein) 

99.12      AgreementBetween Note Holders, dated as of June 14, 2019, by and between BarclaysCapital Real Estate Inc., as Initial Note A-1 Holder, Barclays Capital RealEstate Inc., as Initial Note A-2 Holder, and Barclays Capital Real Estate Inc.,as Initial Note A-3 Holder (filed as Exhibit 99.15 to the registrant’s CurrentReport on Form 8-K filed on August 20, 2019 under Commission File No.333-226486-08 and incorporated by reference herein)

99.13      Co-LenderAgreement, dated as of May 1, 2019, between Rialto Mortgage Finance, LLC, asInitial Note A-1 Holder, and Rialto Mortgage Finance, LLC, as Initial Note A-2Holder (filed as Exhibit 99.16 to the registrant’s Current Report on Form 8-Kfiled on August 20, 2019 under Commission File No. 333-226486-08 andincorporated by reference herein)

99.14      Co-LenderAgreement, dated as of July 25, 2019, between BSPRT Finance Sub-Lender II, LLC,as Note A-1 Holder, and BSPRT Finance Sub-Lender II, LLC, as Note A-2 Holder(filed as Exhibit 99.17 to the registrant’s Current Report on Form 8-K filed onAugust 20, 2019 under Commission File No. 333-226486-08 and incorporated byreference herein)

99.15      Co-LenderAgreement, dated as of May 1, 2019, between Rialto Mortgage Finance, LLC, asInitial Note A-1 Holder, and Rialto Mortgage Finance, LLC, as Initial Note A-2Holder (filed as Exhibit 99.18 to the registrant’s Current Report on Form 8-Kfiled on August 20, 2019 under Commission File No. 333-226486-08 andincorporated by reference herein)

99.16      Amendedand Restated Co-Lender Agreement, dated as of September 6, 2019, between RialtoMortgage Finance, LLC, as Initial Note A-1 Holder, Rialto Mortgage Finance,LLC, as Initial Note A-2 Holder and Wilmington Trust, National Association, asTrustee for the Benefit of the Registered Holders of Wells Fargo CommercialMortgage Trust 2019-C52, Commercial Mortgage Pass Through Certificates, Series 2019-C52(filed as Exhibit 99.19 to the registrant’s Current Report on Form 8-K/A filedon October 1, 2019 under Commission File No. 333-226486-08 and incorporated byreference herein)

99.17      Co-LenderAgreement, dated as of August 20, 2019, by and between BSPRT CMBS Finance, LLC,as Note A-1 Holder, and BSPRT CMBS Finance, LLC, as Note A-2 Holder (filed asExhibit 99.20 to the registrant’s Current Report on Form 8-K filed on August20, 2019 under Commission File No. 333-226486-08 and incorporated by referenceherein)

(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.

Wells Fargo Commercial MortgageSecurities, Inc.(Depositor)

/s/ AnthonySfarra

AnthonySfarra, President

(senior officer in charge ofsecuritization of the depositor)

Date: March 14, 2022