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National Cooperative Bank

 

 

**MANAGEMENT'S ASSERTION ONASSESSMENT OF COMPLIANCE WITH SEC REGULATION AB SERVICING CRITERIA**

 

 

1.     Managementof the National Cooperative Bank, N.A., (the “Company”) is responsible forassessing compliance with the servicing criteria applicable to it underparagraph (d) of Item 1122 of Regulation AB of the Securities and ExchangeCommission (“SEC”) relating to the servicing of asset-backed securitiestransactions conducted by the Company (the “Platform”) as of and for the yearended December 31, 2022 (the “Reporting Period”). Appendix A identifies theindividual asset-backed transactions and securities defined by management asconstituting the Platform;

2.     Exceptas set forth in paragraph 3 below, the Company used the criteria set forth inparagraph (d) of Item 1122 of Regulation AB to provide an assertion on theCompany’s assessment of compliance with the applicable servicing criteria;

3.     Thecriteria listed in the column titled “Inapplicable Servicing Criteria” onAppendix B hereto are inapplicable to the Company based on the activities itperformed with respect to the Platform for the Reporting Period;

4.     Duringthe Reporting Period, there were no cash reserve accounts or accountsestablished as a form of over collateralization that were required to beseparately maintained according to transaction agreements, therefore theCompany did not perform any servicing activities related to these types ofaccounts as part of criteria 1122(d)(2)(iv) as of and for the year endedDecember 31, 2022.

5.     Duringthe Reporting Period, there were no loan modifications made, therefore theCompany did not perform any servicing activities related to criteria1122(d)(4)(vi) as of and for the year ended December 31, 2022.

6.     Duringthe Reporting Period, there were no adjustments to interest rates or rates ofreturn for pool assets with variable rates, therefore the Company did notperform any servicing activities related to criteria 1122(d)(4)(ix) as of andfor the year ended December 31, 2022.

7.     Duringthe Reporting Period, there were no late payment penalties fees assessed,therefore the Company did not perform any servicing activities related tocriteria 1122(d)(4)(xii) as of and for the year ended December 31, 2022.

8.     Duringthe Reporting Period, there were no charge-offs, therefore the Company did notperform any servicing activities related to these components of criteria1122(d)(4)(xiv) as of and for the year ended December 31, 2022.

9.     Withrespect to servicing criteria 1122(d)(4)(xi), the Company has engaged with avendor to perform the activities required by this servicing criteria.Management has determined that the vendor is not considered a “servicer” asdefined in Item 1101(j) of Regulation AB, and has elected to takeresponsibility for assessing compliance with the servicing criteria applicableto the vendor as permitted by the SEC’s Compliance & DisclosureInterpretation 200.06, Vendors Engaged by Servicers (“C&DI 200.06”),formerly Interpretation 17.06 of the SEC Division of Corporation Finance Manualof Publicly Available Telephone Interpretations. As permitted by C&DI200.06, management asserts that it has policies and procedures in place designedto provide reasonable assurance that the vendor’s activities comply in allmaterial respects with the servicing criteria applicable to the vendor.Management is not aware of any material deficiencies in such policies andprocedures or any material instances of non-compliance of the servicingcriteria as relates to the Company by such vendor. Management is solelyresponsible for determining that it meets the SEC requirements to applyC&DI 200.06 for the vendor and related criteria.

10.   TheCompany has complied, in all material respects, with the applicable servicingcriteria set forth in Item 1122(d) of Regulation AB, as of December 31, 2022and for the Reporting Period with respect to the Platform taken as a whole;

11.   GrantThornton LLP, an independent registered public accounting firm, has issued anattestation report on the Company’s assertion of compliance with the applicableservicing criteria for the Reporting Period.

 

 

National Cooperative Bank,N.A. 

January 31, 2023

 

 

 

/s/ Karyn Mann

Karyn Mann

SVP, Senior Vice President

 

 

**Appendix A to Management’sAssertion**

 

*Individual****Investors****for****which****National****Cooperative****Bank,****N.A.****Performed****Servicing****Activities*

* *

| Investor # | PoolDescription               |
|------------|-------------------------------|
| 363        | CSFB2000PS4                   |
| 378        | CSFB2004C4                    |
| 380        | CSFB2005C3                    |
| 383        | CSFB2006C1                    |
| 385        | CSMC2006C4                    |
| 386        | MSCI2007IQ13,throughApril2022 |
| 391        | WFBRBS2013C13                 |
| 392        | WFBRBS2013C15                 |
| 393        | WFBRBS2013C16                 |
| 394        | WFBRBS2013C18                 |
| 395        | WFBRBS2014C19                 |
| 396        | WFBRBS2014C20                 |
| 397        | WFBRBS2014C21                 |
| 398        | WFBRBS2014C22                 |
| 399        | WFBRBS2014C23                 |
| 400        | WFCM2014LC18                  |
| 401        | WFCM2015C26                   |
| 402        | WFCM2015C29                   |
| 403        | WFCM2015C30                   |
| 404        | WFCM2015LC22                  |
| 405        | WFCM2015NXS3                  |
| 406        | WFCM2016C32                   |
| 407        | WFCM2016C33                   |
| 408        | WFCM2016C35                   |
| 409        | WFCM2016LC24                  |
| 410        | WFCM2016C36                   |
| 411        | WFCM2016LC25                  |
| 412        | WFCM2017RC1                   |
| 413        | BANK2017BNK5                  |
| 414        | BANK2017BNK6                  |
| 415        | BANK2017BNK7                  |
| 416        | BANK2017BNK8                  |
| 417        | BANK2018 BNK10                |
| 418        | BANK2018 BNK11                |
| 419        | BANK2018 BNK12                |
| 422        | BANK2018 BNK13                |
| 423        | BANK2018 BNK14                |
| 424        | BANK2018 BNK15                |
| 426        | BANK2019 BNK16                |
| 427        | BANK2019 BNK18                |
| 428        | BANK2019 BNK19                |
| 429        | BANK2019 BNK20                |
| 461        | BANK2019 BNK22                |
| 462        | BANK2019 BNK24                |
| 463        | BANK2020 BNK25                |
| 464        | BANK2020 BNK26                |
| 465        | BANK2020 BNK28                |
| 466        | BANK2020 BNK30                |
| 467        | BANK2021 BNK31                |
| 468        | BANK2021 BNK32                |
| 469        | BANK2021 BNK33                |
| 472        | BANK2021 BNK34                |
| 473        | BANK2021 BNK35                |
| 474        | BANK2021 BNK36                |
| 476        | BANK2021 BNK37                |
| 477        | BANK2021 BNK38                |
| 478        | BANK2022 BNK39                |
| 479        | BANK2022 BNK40                |
| 481        | BANK2022 BNK41                |
| 482        | BANK2022BNK42                 |
| 483        | BANK2022 BNK43                |
| 484        | BANK2022 BNK44                |

 

**APPENDIX********B********to********Management’s********Assertion**

** **

| **SERVICING********CRITERIA**                                               | **APPLICABLE********SERVICING   CRITERIA**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | **INAPPLICABLE********SERVICING****CRITERIA**                           |
|-----------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------|
| ** **

** **

** **

**Reference**                           | ** **

** **

** **

**Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | ** **

** **

**Performed****Directly by the********Company** | ** **

**Performed********by   Vendor(s)********for which********the Company********is********the****Responsible Party** | **Performed********by subservicer(s)****or vendor(s) for which the Company   is Not the****Responsible Party** | **Not performed by the Company********or********by****subservicer(s)****or vendor(s) retained by   the****Company** |
| **General********Servicing********Considerations**                          |
| ** **

1122(d)(1)(i)                                                   | Policies and procedures are instituted to monitor any  performance or other triggers and events of default in accordance with the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |  

**X**                                                           |   |   |   |
| ** **

1122(d)(1)(ii)                                                  | If any material servicing activities are outsourced  to third parties, policies and procedures are instituted to monitor the third  party’s performance and compliance with such servicing activities.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |  

**X**                                                           |   |   |   |
| ** **

1122(d)(1)(iii)                                                 | Any requirements in the transaction agreements to maintain  a back-up servicer for the pool assets are maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                                                    |   |   | **X** |
| ** **

** **

1122(d)(1)(iv)                                      | A fidelity bond and errors and omissions policy is in  effect on the party participating in the servicing function throughout the  reporting period in the amount of coverage required by and otherwise in  accordance with the terms of the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                    |  

**X**                                                           |   |   |   |
| ** **

1122(d)(1)(v)                                                   | Aggregation of information, as applicable, is  mathematically accurate and the information conveyed accurately reflects the  information.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |  

**X**                                                           |   |   |   |
| **Cash********Collection********and********Administration**                 |
| ** **

** **

1122(d)(2)(i)                                       | Payments on pool assets are deposited into the  appropriate custodial bank accounts and related bank clearing accounts no more  than two business days of receipt, or such other number of days specified in  the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |  

**X**                                                           |   |   |   |
| ** **

1122(d)(2)(ii)                                                  | Disbursements made via wire transfer on behalf of an  obligor or to an investor are made only by authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |  

**X**                                                           |   |   |   |
| ** **

1122(d)(2)(iii)                                                 | Advances of funds or guarantees regarding  collections, cash flows or distributions, and any interest or other fees  charged for such advances, are made, reviewed and approved as specified in  the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |  

**X**                                                           |   |   |   |
| ** **

** **

1122(d)(2)(iv)                                      | The related accounts for the transaction, such as  cash reserve accounts or accounts established as a form of over  collateralization, are separately maintained (e.g., with respect to  commingling of cash) as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                               |  

**X**                                                           |   |   |   |
| ** **

** **

1122(d)(2)(v)                                       | Each custodial account is maintained at a federally  insured depository institution as set forth in the transaction agreements.  For purposes of this criterion, "federally insured depository  institution" with respect to a foreign financial institution means a  foreign financial institution that meets the requirements of

§240.13k-1(b)(1) of this chapter.                                                                                                                                                                                                                                                                                                                                    |  

 

**X**                                                   |   |   |   |
| ** **

1122(d)(2)(vi)                                                  | Unissued checks are safeguarded so as to prevent  unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | **X**                                                                   |   |   |   |
| ** **

** **

** **

** **

** **

1122(d)(2)(vii) | Reconciliations are prepared on a monthly basis for  all asset- backed securities related bank accounts, including custodial  accounts and related bank clearing accounts. These reconciliations: (A) Are  mathematically accurate; (B) Are prepared within 30 calendar days after the  bank statement cutoff date, or such other number of days specified in the  transaction agreements; (C) Are reviewed and approved by someone other than  the person who prepared the reconciliation; and (D) Contain explanations for  reconciling items. These reconciling items are resolved within 90 calendar  days of their original identification, or such other number of days specified  in the transaction agreements. |  

 

 

 

**X**                                   |   |   |   |
| **Investor********Remittances********and********Reporting**                 |
| ** **

** **

** **

** **

** **

1122(d)(3)(i)   | Reports to investors, including those to be filed  with the Commission, are maintained in accordance with the transaction  agreements and applicable Commission requirements.

Specifically, such reports: (A) Are prepared in  accordance with timeframes and other terms set forth in the transaction  agreements; (B) Provide information calculated in accordance with the terms  specified in the transaction agreements; (C) Are filed with the Commission as  required by its rules and regulations; and (D) Agree with investors’ or the  trustee’s records as to the total unpaid principal balance and number of pool  assets serviced by the servicer.                                           |                                                                    |   |   | ** **

** **

** **

** **

**X** |
| ** **

1122(d)(3)(ii)                                                  | Amounts due to investors are allocated and remitted  in accordance with timeframes, distribution priority and other terms set  forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |                                                                    |   |   |  

**X** |
| ** **

1122(d)(3)(iii)                                                 | Disbursements made to an investor are posted within  two business days to the servicer’s investor records, or such other number of  days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |                                                                    |   |   |  

**X** |
| ** **

1122(d)(3)(iv)                                                  | Amounts remitted to investors per the investor  reports agree with cancelled checks, or other form of payment, or custodial  bank statements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |                                                                    |   |   |  

**X** |
| **Pool********Asset********Administration**                                 |
| ** **

1122(d)(4)(i)                                                   | Collateral or security on pool assets is maintained  as required by the transaction agreements or related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | **X**                                                                   |   |   |   |
| ** **

1122(d)(4)(ii)                                                  | Pool assets and related documents are safeguarded as  required by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |                                                                    |   |   | **X** |
| ** **

1122(d)(4)(iii)                                                 | Any additions, removals or substitutions to the asset  pool are made, reviewed and approved in accordance with any conditions or  requirements in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |  

**X**                                                           |   |   |   |
| ** **

** **

** **

1122(d)(4)(iv)                          | Payments on pool assets, including any payoffs, made in  accordance with the related pool asset documents are posted to the applicable  servicer's obligor records maintained no more than two business days after  receipt, or such other number of days specified in the transaction  agreements, and allocated to principal, interest or other items (e.g.,  escrow) in accordance with the related pool asset documents.                                                                                                                                                                                                                                                                                            |  

 

**X**                                                   |   |   |   |
| ** **

1122(d)(4)(v)                                                   | The servicer's records regarding the pool assets  agree with the servicer's records with respect to an obligor's unpaid principal  balance.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             |  

**X**                                                           |   |   |   |
| ** **

** **

1122(d)(4)(vi)                                      | Changes with respect to the terms or status of an  obligor's mortgage loans (e.g., loan modifications or re-aging's) are made,  reviewed and approved by authorized personnel in accordance with the  transaction agreements and related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                          |  

**X**                                                           |   |   |   |
| ** **

** **

1122(d)(4)(vii)                                     | Loss mitigation or recovery actions (e.g. forbearance  plans, modifications and deeds in lieu of foreclosure, foreclosure and repossessions,  as applicable) are initiated, conducted and concluded in accordance with the  timeframes or other requirements established by the a transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                               |  

 

**X**                                                   |   |   |   |
| ** **

** **

** **

** **

1122(d)(4)(viii)            | Records documenting collection efforts are maintained  during the period a pool asset is delinquent in accordance with the  transaction agreements. Such records are maintained on at least a monthly  basis, or such other period specified in the transaction agreements, and  describe the entity's activities in monitoring delinquent pool assets  including, for example, phone calls, letters and payment rescheduling plans  in cases where delinquency is deemed temporary (e.g., illness or  unemployment).                                                                                                                                                                                                   |  

 

 

**X**                                           |   |   |   |
| ** **

1122(d)(4)(ix)                                                  | Adjustments to interest rates or rates of return for  pool assets with variable rates are computed based on the related pool asset  documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |  

**X**                                                           |   |   |   |
| ** **

** **

** **

** **

1122(d)(4)(x)               | Regarding any funds held in trust for an obligor (such  as escrow accounts) See following: (A) Such funds are analyzed, in accordance  with the obligor's pool asset documents, on at least an annual basis, or such  other period specified in the transaction agreements; (B) Interest on such  funds is paid, or credited, to obligors in accordance with applicable pool  asset documents and state laws; and (C) Such funds are returned to the  obligor within 30 calendar days of full repayment of the related pool asset,  or such other number of days specified in the transaction agreements.                                                                                                               |  

 

 

**X**                                           |   |   |   |
| ** **

** **

** **

1122(d)(4)(xi)                          | Payments made on behalf of an obligor (such as tax or  insurance payments) are made on or before the related penalty or expiration  dates, as indicated on the appropriate bills or notices for such payments,  provided that such support has been received by the servicer at least 30  calendar days prior to these dates, or such other number of days specified in  the transaction agreements.                                                                                                                                                                                                                                                                                                                    |  

 

**X**                                                   | ** **

** **

**X** |   |   |
| ** **

1122(d)(4)(xii)                                                 | Any late payment penalties in connection with any  payment to be made on behalf of an obligor are paid from the servicer’s funds  and not charged to the obligor, unless the late payment was due to the  obligor’s error or omission.                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |  

**X**                                                           |   |   |   |
| ** **

1122(d)(4)(xiii)                                                | Disbursements made on behalf of an obligor are posted  within two business days to the obligor’s records maintained by the servicer,  or such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |  

**X**                                                           |   |   |   |
| ** **

1122(d)(4)(xiv)                                                 | Delinquencies, charge-offs and uncollectible accounts  are recognized and recorded in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |  

**X**                                                           |   |   |   |
| ** **

1122(d)(4)(xv)                                                  | Any external enhancement or other support, identified  in Item 1114(a) (1) through (3) or Item 1115 of this Regulation AB, is  maintained as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |                                                                    |   |   | ** **

**X** |