**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, 2022or**

**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 Computershare Trust Company, National Association, as agent for**

**Wells Fargo Bank, National Association**

**as Certificate Administrator**

**9062 Old Annapolis Road**

**Columbia, MD**

**(Address of principalexecutive offices of the issuing entity)**

**21045**

**(Zip Code)**

**Registrant’s telephone number,including area code:**

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

Not applicable.

Indicate by check mark whether the registrant is a largeaccelerated filer, an accelerated filer, a non-accelerated filer, a smallerreporting company, or an emerging growth company. See the definitions of “largeaccelerated filer,” “accelerated filer,” “smaller reporting company,” and“emerging growth company” in Rule 12b-2 of the Exchange Act.

Large acceleratedfiler        o                                                                                                       Accelerated filer                                     o

Non-acceleratedfiler          ⌧  (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

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

Indicate by check mark whether any of those error correctionsare restatements that required a recovery analysis of incentive-basedcompensation received by any of the registrant’s executive officers during therelevant recovery period pursuant to §240.10D-1(b). o

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

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

Not applicable.

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

Not applicable.

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

Not applicable.

**DOCUMENTS INCORPORATED BY REFERENCE**

** **

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

Not applicable.

 

** **

**EXPLANATORY NOTES**

The Renaissance Center VI Mortgage Loan, the MountKemble Mortgage Loan and the Del Mar Terrace Apartments Mortgage Loan, whichconstituted approximately 2.5%, 1.9% and 1.1%, respectively, of the asset poolof the issuing entity as of its cut-off date, are each an asset of the issuingentity and are each part of a loan combination that includes the RenaissanceCenter VI Mortgage Loan, the Mount Kemble Mortgage Loan or the Del Mar TerraceApartments Mortgage Loan and one other *pari passu* loan, each of which isnot an asset of the issuing entity. These loan combinations, including theRenaissance Center VI Mortgage Loan, the Mount Kemble Mortgage Loan and the DelMar Terrace Apartments Mortgage Loan, are being serviced and administeredpursuant to the Pooling and Servicing Agreement, which is incorporated byreference 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 Trust transaction(the “MFTII 2019-B3B4 Transaction”). This loan combination, includingthe Moffett Towers II - Buildings 3 & 4 Mortgage Loan, is being servicedand administered pursuant to the trust and servicing agreement for the MFTII2019-B3B4 Transaction, which is incorporated by reference as Exhibit 4.2 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 El Con Center Mortgage Loan, whichconstituted approximately 2.0% of the asset pool of the issuing entity as ofits cut-off date.  The El Con Center Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the El ConCenter Mortgage Loan and one other *pari passu* loan, which is not anasset of the issuing entity. The other *pari passu* portion of the loancombination was securitized in the Wells Fargo Commercial Mortgage Trust2019-C51 transaction, Commission File Number 333-226486-06 (the “WFCM2019-C51 Transaction”). This loan combination, including the El Con CenterMortgage Loan, is 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 Shetland ParkMortgage Loan, previously an asset of the issuing entity being serviced underthe pooling and servicing agreement for the WFCM 2019-C51 Transaction, was notan asset of the issuing entity during the reporting period and is omitted fromthis Annual Report on Form 10-K and will be omitted from subsequent AnnualReports 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 188 SpearStreet Mortgage Loan, was serviced under the Pooling and Servicing Agreementfor the issuing entity prior to the closing of the securitization of a *paripassu* portion of the 188 Spear Street loan combination in the BBCMSMortgage Trust 2019-C4 transaction, Commission File Number 333-226850-03 (the “BBCMS2019-C4 Transaction”).  After the closing of the BBCMS 2019-C4Transaction on August 28, 2019, this loan combination, including the 188 SpearStreet Mortgage Loan was, and will continue to be, serviced and administeredpursuant to the pooling and servicing agreement with respect to the BBCMS2019-C4 Transaction, which is incorporated by reference as Exhibit 4.5 to thisAnnual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Smoke Tree Village and Smoke Tree CommonsMortgage Loan, which constituted approximately 1.1% of the asset pool of theissuing entity as of its cut-off date.  The Smoke Tree Village and SmokeTree Commons Mortgage Loan is an asset of the issuing entity and is part of aloan combination 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 Tree Village andSmoke Tree Commons 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 Smoke Tree Village and Smoke Tree Commonsloan combination in the UBS Commercial Mortgage Trust 2019-C17 transaction,Commission File Number 333-227784-04 (the “UBS 2019-C17 Transaction”). After the closing of the UBS 2019-C17 Transaction on October 15, 2019, thisloan combination, including the Smoke Tree Village and Smoke Tree CommonsMortgage Loan was, and will continue to be, serviced and administered pursuantto the pooling and servicing agreement with respect to the UBS 2019-C17Transaction, which is incorporated by reference as Exhibit 4.6 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 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 and the Smoke Tree Village and Smoke Tree Commons Mortgage Loan.As a result, Wells Fargo Bank, National Association is a “servicer” as definedin Item 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 Wells Fargo Bank, NationalAssociation in the capacities described above are listed in the Exhibit Index.

Wells Fargo Bank, NationalAssociation is the custodian of the mortgage loans serviced under the Poolingand Servicing Agreement, the Moffett Towers II - Buildings 3 & 4 MortgageLoan, the SoCal Retail Portfolio Mortgage Loan, the Embassy Suites atCentennial Olympic Park Mortgage Loan, the El Con Center Mortgage Loan, the 188Spear Street 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.

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 theoperating advisor of the mortgage loans serviced under the Pooling andServicing Agreement, the SoCal Retail Portfolio Mortgage Loan, the EmbassySuites at Centennial Olympic Park Mortgage Loan, the El Con Center MortgageLoan and the Smoke Tree Village and Smoke Tree Commons Mortgage Loan.  Asa result, 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 isthe primary servicer of the Moffett Towers II - Buildings 3 & 4 MortgageLoan and the Inland Life Storage Portfolio Mortgage Loan.  These mortgageloans constitute more than 5%, but less than 10%, of the pool assets of theissuing entity.  Therefore, the Depositor included in this Annual Reporton Form 10-K an assessment of compliance with applicable servicing criteria forKeyBank National Association and an accountants’ attestation report pursuant toItem 1122 of Regulation AB because KeyBank National Association is servicingmore than 5% of the pool assets.  However, the Depositor is not requiredto include 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.

Midland Loan Services, a Divisionof PNC Bank, National Association is the primary servicer of the Embassy Suitesat Centennial Olympic Park Mortgage Loan and the SoCal Retail PortfolioMortgage 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’ attestation reportpursuant 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.

Park Bridge Lender Services LLC isthe operating advisor of the Inland Life Storage Portfolio Mortgage Loan andthe 188 Spear Street 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’ attestation reportsdelivered by Park Bridge Lender Services LLC in the capacities described aboveare listed in the Exhibit Index.

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 Item 1122(d)(2)(iii)of Regulation AB in the assessment of compliance with applicable servicingcriteria and accountant’s attestation report for the subject transaction. As a result, this Annual Report on Form 10-K does not include an assessment ofcompliance with applicable servicing criteria of the trustee. One or more otherservicers of the Moffett Towers II - Buildings 3 & 4 Mortgage Loan, theSoCal Retail Portfolio Mortgage Loan and the Embassy Suites at CentennialOlympic Park Mortgage Loan have delivered one or more assessments of compliancewith respect to Item 1122(d)(2)(iii) of Regulation AB.

Wilmington Trust, NationalAssociation acts as trustee of  the mortgage loans serviced under thePooling and Servicing Agreement, the El Con Center Mortgage Loan, the 188 SpearStreet Mortgage Loan and the Smoke Tree Village and Smoke Tree Commons MortgageLoan.  Pursuant to the Pooling and Servicing Agreement, the pooling andservicing agreement for the WFCM 2019-C51 Transaction, the pooling andservicing agreement for the BBCMS 2019-C4 Transaction and the pooling andservicing agreement for the UBS 2019-C17 Transaction, the trustee is requiredto provide an assessment of compliance with applicable servicing criteriasolely with respect to Item 1122(d)(2)(iii) of Regulation AB (regardingadvances 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 mortgage loans servicedunder the Pooling and Servicing Agreement, the El Con Center Mortgage Loan, the188 Spear Street Mortgage Loan and the Smoke Tree Village and Smoke TreeCommons Mortgage Loan have delivered one or more assessments of compliance withrespect to Item 1122(d)(2)(iii) of Regulation AB.

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, the 188Spear Street Mortgage Loan and the Smoke Tree Village and Smoke Tree CommonsMortgage Loan to remit tax payments received from the escrow accounts ofborrowers to local taxing authorities, to report tax amounts due, to verify taxparcel information, and to verify non-escrow tax payments. These servicing functionsare included within the servicing criteria set forth in Items 1122(d)(4)(xi)and 1122(d)(4)(xii) of Regulation AB.  Therefore, under theprinciples-based definition of “servicer” set forth in Item 1101(j) ofRegulation AB that looks to the functions that an entity performs, this vendoris a “servicer” for the purposes of Item 1122 of Regulation AB.  *See*Compliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

This AnnualReport on Form 10-K includes an assessment of compliance with applicableservicing criteria, accountants’ attestation report and servicer compliancestatement from Computershare Trust Company, National Association (“CTCNA”). CTCNA was 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)).

The assessments of compliance withapplicable servicing criteria, accountants’ attestation reports and servicercompliance statements of the certificate administrator of the El Con CenterMortgage Loan, the Moffett Towers II - Buildings 3 & 4 Mortgage Loan, theSoCal Retail Portfolio Mortgage Loan, the Embassy Suites at Centennial OlympicPark Mortgage Loan, the 188 Spear Street Mortgage Loan, the Smoke Tree Villageand Smoke Tree Commons Mortgage Loan and the Inland Life Storage PortfolioMortgage Loan are omitted from this Annual Report on Form 10-K as thecertificate administrator pursuant to the related pooling and servicingagreement or trust and servicing agreement does not perform any activities thataddress servicing criteria with respect to the issuing entity and because theyare each not a “servicer” that meets the criteria in Item 1108(a)(2)(i) through(iii) of Regulation AB.

With respect to the *pari passu*loan combinations that include the Moffett Towers II - Buildings 3 & 4Mortgage Loan, the Inland Life Storage Portfolio Mortgage Loan, the El ConCenter Mortgage Loan, the SoCal Retail Portfolio Mortgage Loan, the EmbassySuites at Centennial Olympic Park Mortgage Loan, the 188 Spear Street MortgageLoan and the Smoke Tree Village and Smoke Tree Commons Mortgage Loan, (i) thereports on assessment of compliance with servicing criteria and attestation reportson assessment of compliance with servicing criteria of Greystone ServicingCompany LLC (as successor to C-III Asset Management LLC) as special servicer ofthe El Con Center 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 ofRegulation AB because they are parties performing activities that addressservicing criteria relating to 5% or less of the assets of the issuing entity;and (ii) the servicer compliance statements of KeyBank National Association asprimary servicer of the Moffett Towers II - Buildings 3 & 4 Mortgage Loanand the Inland Life Storage Portfolio Mortgage Loan, Situs Holdings, LLC asspecial servicer 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, Midland Loan Services, aDivision of PNC Bank, National Association as primary servicer of the SoCalRetail Portfolio Mortgage Loan and the Embassy Suites at Centennial OlympicPark Mortgage Loan, Rialto Capital Advisors, LLC as special servicer of the 188Spear Street Mortgage Loan and the Smoke Tree Village and Smoke Tree CommonsMortgage Loan and LNR Partners, LLC as special servicer of the Inland LifeStorage Portfolio Mortgage Loan, listed on the Exhibit Index are omitted fromthis Annual Report on Form 10-K as they are not required by Item 1123 ofRegulation AB to be included on this Annual Report on Form 10-K because theyare each an unaffiliated party that is not a “servicer” that meets the criteriain Item 1108(a)(2)(i) through (iii) of Regulation AB.

**PART I**

**Item 1.  Business.**

Omitted.

**Item 1A.  Risk Factors.**

Omitted.

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

None.

**Item 2.  Properties.**

Omitted.

**Item 3.  Legal Proceedings.**

Omitted.

**Item 4.  Mine Safety Disclosures.**

Not applicable.

**PART II**

**Item 5.  Market for Registrant’s Common Equity,Related Stockholder Matters and Issuer Purchases of Equity Securities.**

Omitted.

**Item 6. **

[Reserved]

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**Item 9B.  Other Information.**

None.

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

None.

**PART III**

**Item 10.  Directors, Executive Officers and CorporateGovernance.**

Omitted.

**Item 11.  Executive Compensation.**

Omitted.

**Item 12.  Security Ownership of Certain BeneficialOwners and Management and Related Stockholder Matters.**

Omitted.

**Item 13.  Certain Relationships and RelatedTransactions, and Director Independence.**

Omitted.

**Item 14.  Principal Accountant Fees and Services.**

Omitted.

**ADDITIONAL DISCLOSURE ITEMS FOR REGULATION AB**

**Item 1112(b) of Regulation AB, Significant ObligorFinancial Information.**

No single obligor represents 10% or more of the pool 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 December2014, Phoenix Light SF Limited (Phoenix Light) and certain related entities fileda complaint in the United States District Court for the Southern District ofNew York alleging claims against Wells Fargo Bank, N.A., in its capacity astrustee for a number of residential mortgage-backed securities (RMBS) trusts.Complaints raising similar allegations have been filed by Commerzbank AG in theSouthern District of New York and by IKB International and IKB DeutscheIndustriebank in New York state court. In each case, the plaintiffs allege thatWells Fargo Bank, N.A., as trustee, caused losses to investors, and plaintiffsassert causes of action based upon, among other things, the trustee’s allegedfailure to notify and enforce repurchase obligations of mortgage loan sellersfor purported breaches of representations and warranties, notify investors ofalleged events of default, and abide by appropriate standards of care followingalleged events of default. In July 2022, the district court dismissed PhoenixLight’s claims and certain of the claims asserted by Commerzbank AG, andsubsequently entered judgment in each case in favor of Wells Fargo Bank, N.A.In August 2022, Phoenix Light and Commerzbank AG appealed the district court’sdecision to the United States Court of Appeals for the Second Circuit. TheCompany previously settled two class actions filed by institutional investorsand an action filed by the National Credit Union Administration with similarallegations. In addition, Park Royal I LLC and Park Royal II LLC have filedsubstantially similar lawsuits in New York state court alleging Wells FargoBank, N.A., as trustee, failed to take appropriate actions upon learning ofdefective mortgage loan documentation.

**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 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 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,which is being serviced and administered pursuant to the pooling and servicingagreement for the WFCM 2019-C51 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 WFCM 2019-C51 Transaction incorporated by referenceas Exhibit 4.3 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the WFCM 2019-C51Transaction 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 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 thisAnnual Report 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 heretounder Item 15 to this Annual Report on Form 10-K. Attached as Schedule II tothe pooling and servicing agreement for the CF 2019-CF2 Transactionincorporated by reference as Exhibit 4.7 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theCF 2019-CF2 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The report on assessment of compliance for the twelvemonths ended December 31, 2022, furnished pursuant to Item 1122 of RegulationAB by KeyBank National Association (“KeyBank”), as servicer, discloses that thefollowing material instance of noncompliance occurred with respect to itsplatform:

The examinationperformed by Ernst & Young LLP identified an instance of materialnoncompliance with the servicing criteria set forth in Item 1122(d)(4)(ix) ofRegulation AB applicable to KeyBank during the year ended December 31, 2022.During compliance testing, it was discovered,that not all FlexARM loan mortgagors were offered loan rates within 45-60 daysbefore the rate change date, as required per the related pool asset documents.Per the related note, if the holder fails to offer a loan rate within 45-60days of any change date a margin of 2.25% is to be used. Given the notificationwas not made to the borrowers, a 3% margin was incorrectly applied. Thenoncompliance in Item 1122 (d)(4)(ix) is related to a servicing portfolio whichis wholly owned by the investor and is not held in a publicly traded security.

The followingremediation procedures have been initiated by KeyBank: (i) the impactedmortgage loans are currently in the process of being identified, (ii) investorcontact has been initiated, (iii) corrective actions are being considered andwill be tracked and monitored by senior management, (iv) procedures will bereviewed and revised, if necessary, to include new tracking and action steps toprevent this situation from recurring in the future, and (v) training will beprovided to the relevant staff members to prevent a recurrence.

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

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

**PART IV**

**Item 15. Exhibit and Financial Statement Schedules**

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

(1) Not applicable

(2) Not applicable

(3) See below

4.1          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 Trustee (filed asExhibit 99.7 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).

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 Administrator,Wilmington Trust, National Association, as Trustee, and Pentalpha SurveillanceLLC, as Operating Advisor and Asset Representations Reviewer (filed as Exhibit99.9 to the registrant’s Current Report on Form 8-K filed on August 20, 2019under Commission File No. 333-226486-08 and incorporated 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 andincorporated by 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, as CertificateAdministrator

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

33.9         Computershare Trust Company, National Association, asServicing Function Participant for the Custodian

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, asServicing Function Participant for the Custodian (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 FunctionParticipant of the Mount Kemble Mortgage Loan (see Exhibit 33.7)

33.23      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (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 (see Exhibit 33.9)

33.31      KeyBank National Association, as Primary Servicer ofthe 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 (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. See ExplanatoryNotes.)

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 (see Exhibit 33.9)

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

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

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

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

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

33.48      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.9)

33.49      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Embassy Suites at CentennialOlympic Park Mortgage Loan (see Exhibit 33.43)

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

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

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

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

33.54      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.9)

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

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

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

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

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

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

33.61      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.9)

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

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

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

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

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

33.67      CoreLogic Solutions, LLC, as Servicing Function Participantof the Smoke Tree Village and Smoke Tree Commons Mortgage Loan (see Exhibit33.7)

33.68      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.9)

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

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

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

33.72      Park Bridge Lender Services LLC, as OperatingAdvisor of the Inland Life Storage Portfolio Mortgage Loan (see Exhibit 33.59)

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

34.9        Computershare Trust Company, National Association, asServicing Function Participant for the Custodian

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 (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 Function Participantof the Mount Kemble Mortgage Loan (see Exhibit 34.7)

34.23      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (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 Servicer ofthe 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 (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 (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 (see Exhibit 34.9)

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

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

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

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

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

34.48      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.9)

34.49      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Embassy Suites at CentennialOlympic Park Mortgage Loan (see Exhibit 34.43)

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

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

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

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

34.54      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.9)

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

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

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

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

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

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

34.61      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.9)

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

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

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

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

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

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

34.68      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.9)

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

34.70      LNR Partners, LLC, as Special Servicer of the Inland Life Storage Portfolio MortgageLoan (Omitted. See Explanatory Notes.)

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

34.72      Park Bridge Lender Services LLC, as OperatingAdvisor of the Inland Life Storage Portfolio Mortgage Loan (see Exhibit 34.59)

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

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

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

35.17      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.) 

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

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

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

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

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

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

35.24      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 Fargo CommercialMortgage Securities, Inc. and Wells Fargo Bank, National Association (filed asExhibit 99.6 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)

99.2        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 HoldingsLLLP, Series TRS of Ladder Capital Finance Holdings LLLP (filed as Exhibit 99.4to the 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 RealEstate Finance LLC, as Initial Note A-1 Holder, Argentic Real Estate FinanceLLC, as Initial Note A-2 Holder, Argentic Real Estate Finance LLC, as InitialNote A-3 Holder, Argentic Real Estate Finance LLC, as Initial Note A-4 Holder,Argentic Real 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, by and between BSPRT Finance Sub-LenderII, LLC, as Note A-1 Holder, and BSPRT Finance Sub-Lender II, LLC, as Note A-2Holder (filed as Exhibit 99.17 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)

99.15      Amendedand Restated Co-Lender Agreement, dated as of September 6, 2019, between RialtoMortgage Finance, LLC, as Note A-1-1 Holder, Rialto Mortgage Finance, LLC, asNote A-1-2 Holder and Wilmington Trust, National Association, as Trustee forthe Benefit of the Registered Holders of Wells Fargo Commercial Mortgage Trust2019-C52, Commercial Mortgage Pass Through Certificates, Series 2019-C52, asNote A-2 Holder (filed as Exhibit 99.19 to the registrant’s Current Report onForm 8-K/A filed on October 1, 2019 under Commission File No. 333-226486-08 andincorporated by reference herein)

99.16      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 17, 2023