**Management’s Reporton Assessment of Compliance with SEC Regulation AB**

**Servicing Criteriaas Master Servicer**

 

 

BerkadiaCommercial Mortgage LLC (“Berkadia”) is responsible for assessing compliance,as of and for the year ended December 31, 2023 (the “Reporting Period”), withthe Servicing Criteria set forth in Item 1122(d) of Regulation AB of the U.S.Securities and Exchange Commission for asset-backed securities transactions.This assertion includes all commercial mortgage loans sold in publicsecuritizations from the period January 1, 2006 through December 31, 2023 forwhich Berkadia served as master servicer (the “Platform”).

 

Berkadiahas concluded that the criteria are applicable as shown below (indicated by X)to the master servicing of the loans in the Platform:

 

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**Regulation********AB********Criteria********1122(d)**                                                                                                                                                                                                                      | **Applicability****of Criteria as the Master****Servicer**                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |
|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| (1)                                                                                                                                                                                                                                                                                                  | Generalservicingconsiderations.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |   |
| (i)                                                                                                                                                                                                                                                                                                  | Policiesandproceduresareinstitutedtomonitoranyperformanceorothertriggersandevents of  default in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                               | X |
| (ii)                                                                                                                                                                                                                                                                                                 | Ifanymaterialservicingactivitiesareoutsourcedtothirdparties,policiesandproceduresare instituted to monitor the third party’s performance and  compliance with such servicing activities.                                                                                                                                                                                                                                                                                                                             |  

X |
| (iii)                                                                                                                                                                                                                                                                                                | Anyrequirementsinthe  transactionagreementstomaintaina back-upservicerfor thepool assets are maintained.                                                                                                                                                                                                                                                                                                                                                                                                                   | (1) |
| (iv)                                                                                                                                                                                                                                                                                                 | Afidelitybondanderrorsandomissionspolicyisineffectonthepartyparticipatingintheservicing function throughout the reporting  period in the amount of coverage required by and otherwise in accordance with  the terms of the transaction agreements.                                                                                                                                                                                                                                                                         |  

X |
| (2)                                                                                                                                                                                                                                                                                                  | Cashcollectionand administration.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |   |
| (i)                                                                                                                                                                                                                                                                                                  | Paymentsonpoolassetsaredepositedintothecustodialbankaccountsandrelatedbankclearing  accountsnomorethantwobusinessdaysofreceipt,orsuchothernumberofdays specifiedinthe transaction  agreements.                                                                                                                                                                                                                                                                                                                             |  

X1 |
| (ii)                                                                                                                                                                                                                                                                                                 | Disbursements made via wire transfer  on behalf of an obligor or to an investor are made only by authorized  personnel.                                                                                                                                                                                                                                                                                                                                                                                                    | X |
| (iii)                                                                                                                                                                                                                                                                                                | Advancesoffundsorguaranteesregardingcollections,cashflowsordistributions,andanyinterest or other fees charged for such  advances, are made, reviewed and approved as specified in the transection  agreements.                                                                                                                                                                                                                                                                                                             |  

X1 |
| (iv)                                                                                                                                                                                                                                                                                                 | The related  accounts for the transaction, such as cash reserve accounts or accounts  established as a form of overcollateralization, are separately maintained  (e.g., with respect to commingling of cash) as set forth in the transaction  agreements.                                                                                                                                                                                                                                                                  |  

X |
| (v)                                                                                                                                                                                                                                                                                                  | Eachcustodialaccountismaintainedatafederallyinsureddepositoryinstitution assetforthinthe  transactionagreements.Forpurposesofthiscriterion,“federallyinsureddepositoryinstitution”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 |
| (vi)                                                                                                                                                                                                                                                                                                 | Unissuedchecksaresafeguardedtopreventunauthorizedaccess.                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | X |
| (vii)      Reconciliationsarepreparedonamonthlybasisforallasset-backedsecuritiesrelatedbank  accounts,includingcustodialaccountsandrelatedbank clearingaccounts.Thesereconciliations:                                                                                            |  

X                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |
| (A)Aremathematicallyaccurate;                                                                                                                                                                                                                                                                        | X                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
| (B)Arepreparedwithin30calendardaysafterthebankstatementcutoffdate,orsuchothernumberof days specified in  the transaction agreements.                                                                                                                                                                 | X                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
| (C)Arereviewedandapprovedbysomeoneotherthanthepersonwhopreparedthe reconciliation; and                                                                                                                                                                                                               | X                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
| (D)Containexplanationsforreconcilingitems.Thesereconcilingitemsareresolvedwithin90calendar days of their original  identification, or such other number of days specified in the transaction agreements.                                                                                             |  

X                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |
| (3)     Investorremittancesandreporting.                                                                                                                                                                                                                                              |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |
| (i)Reportstoinvestors,includingthosetobefiledwiththeCommission,aremaintainedinaccordance  with the transaction agreements and applicable Commission requirements.  Specifically, such reports:                                                                                                       | X                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
| (A)        Arepreparedinaccordancewithtimeframesandothertermssetforthinthetransaction agreements;                                                                                                                                                                      | X                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
| (B)      Provideinformationcalculatedinaccordancewith thetermsspecifiedinthetransaction agreements;                                                                                                                                                                              | X                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
| (C)      ArefiledwiththeCommissionasrequiredbyitsrulesandregulations;and                                                                                                                                                                                                         | (1)                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |
| (D)Agreewithinvestors’orthetrustee’srecordsastothetotalunpaidprincipalbalanceandnumberof pool assets serviced by the servicer.                                                                                                                                                           | X                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
| (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 |
| (iii)                                                                                                                                                                                                                                                                                                | Disbursementsmadetoan investorareposted within  two businessdaysto theservicer’sinvestor records,  or such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                             |  

X |
| (iv)                                                                                                                                                                                                                                                                                                 | Amounts remitted to investors per  the investor reports agree with cancelled checks, or otherform of payment, or custodial bank  statements.                                                                                                                                                                                                                                                                                                                                                                               | X |
| (4)                                                                                                                                                                                                                                                                                                  | Poolasset  administration.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |   |
| (i)                                                                                                                                                                                                                                                                                                  | Collateral or security on pool  assets is maintained as required by the transaction agreements or related  pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                           |  

X1 |
| (ii)                                                                                                                                                                                                                                                                                                 | Poolassetsandrelateddocumentsaresafeguardedasrequiredbythetransactionagreements.                                                                                                                                                                                                                                                                                                                                                                                                                                           | (1) |
| (iii)                                                                                                                                                                                                                                                                                                | Any additions, removals or  substitutions to the asset pool are made, reviewed and approved inaccordance with any conditions or  requirements in the transaction agreements.                                                                                                                                                                                                                                                                                                                                               |  

X |
| (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  businessdaysafterreceipt,orsuchothernumberofdaysspecifiedinthetransactionagreements, andallocatedtoprincipal,interestorotheritems(e.g.,escrow)inaccordancewiththerelatedpool asset documents.                                                                                                                        |  

 

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

X |
| (vii)Loss mitigation or recovery actions (e.g.,  forbearance plans, modifications and deeds in lieu of foreclosure,foreclosuresandrepossessions,asapplicable)areinitiated,conductedandconcluded in  accordance with the timeframes or other requirements established by the  transaction agreements. |  

(1)                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |
| (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 |
| (ix)                                                                                                                                                                                                                                                                                                 | Adjustmentstointerestratesorratesofreturnforpoolassetswithvariableratesarecomputed based on the  related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                             | X |
| (x)                                                                                                                                                                                                                                                                                                  | Regardinganyfundsheldintrustforanobligor(suchasescrowaccounts):                                                                                                                                                                                                                                                                                                                                                                                                                                                            |   |
| (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;                                                                                                                                                                                                                                                                                                                                         | X |
| (B)                                                                                                                                                                                                                                                                                                  | Interestonsuchfundsispaid,orcredited,toobligorsinaccordancewithapplicablepoolasset documents and state laws; and                                                                                                                                                                                                                                                                                                                                                                                                           | X |
| (C)                                                                                                                                                                                                                                                                                                  | Suchfundsarereturnedtotheobligorwithin30calendardaysoffullrepaymentoftherelated pool asset, or such other number of days specified in the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                         |  

X2 |
| (xi)                                                                                                                                                                                                                                                                                                 | Paymentsmadeonbehalfofanobligor(suchastaxorinsurancepayments)aremadeonor  beforetherelated penaltyorexpirationdates,asindicatedontheappropriatebillsornotices for suchpayments,provided  that such support has been received bythe  serviceratleast 30 calendardayspriortothesedates,orsuchothernumberofdaysspecifiedinthetransaction  agreements.                                                                                                                                                                         |  

 

 

X1 |
| (xii)                                                                                                                                                                                                                                                                                                | Any late payment penalties in connection  with any payment to be made on behalf ofan  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.                                                                                                                                                                                                                                                                          |  

 

X1 |
| (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.                                                                                                                                                                                                                                                                                                         |  

 

X1 |
| (xiv)                                                                                                                                                                                                                                                                                                | Delinquencies,charge-offsanduncollectibleaccountsarerecognizedandrecordedin accordance with the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                   |  

X2 |
| (xv)                                                                                                                                                                                                                                                                                                 | Anyexternalenhancementorothersupport,identifiedinItem1114(a)(1)through(3)orItem 1115 of this  Regulation AB, is maintained as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                     |  

(1) |
|                                                                                                                                                                                                                                                                                                 |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |   |   |

 

XServicer was responsible for these criteria in its role as Master Servicer.

X1Servicing activities associated with this criterion are performed by BerkadiaCommercial Mortgage and a third-party vendor for which Berkadia is theresponsible party.

X2There was no transaction activity relevant to the servicing criteria as of andfor the year ended December 31, 2023

(1)Per servicing and pooling agreements, the criteria does not apply to the roleof Master Servicer.

 

 

TheServicing Criteria, after giving effect to the foregoing exclusions, arereferred to as the “Applicable Servicing Criteria.”

 

Forthe Reporting Period, Berkadia has assessed its compliance with the Applicable ServicingCriteria for the Platform and has concluded that its servicing operation hascomplied, in all material respects, with the Applicable Servicing Criteria.

 

GrantThornton LLP, an independent registered public accounting firm, has issued anattestation report on management’s assertion of compliance with the ApplicableServicing Criteria.

 

BerkadiaCommercial Mortgage LLC 

 

February15, 2024

 

/s/Mark E. McCool

MarkE. McCool

 

President-BerkadiaCommercial Real Estate Services, Servicing 

BerkadiaCommercial Mortgage LLC