**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, 2019or**

**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: 333-226486-06**

**Central Index Key Number of the issuing entity:0001776721**

**Wells Fargo Commercial MortgageTrust 2019-C51**

**(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: 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: 0001685185**

**UBS AG, by and through its branchoffice at 1285 Avenue of the Americas, New York, New York**

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

** **

**Central Index Key Number of the sponsor: 0001541214**

**C-III Commercial Mortgage 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)** | **38-4117348**

**38-4117349**

**(I.R.S. Employer**

**Identification Numbers)** |
|------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------|

**c/o Wells Fargo Bank, National Association**

**as Certificate Administrator**

**9062 Old Annapolis Road**

**Columbia, MD**

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

**21045**

**(Zip Code)**

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

**(704) 374-6161**

Securities registered pursuant to Section 12(b) of the Act:

| Title of each class | Trading Symbol(s) | Name of each exchange on which registered |
|---------------------|-------------------|-------------------------------------------|
| None                |              |                                      |

Securities registered pursuant to Section 12(g) of theAct:  None.

Indicate by check mark if the registrant is a well-knownseasoned issuer, as defined in Rule 405 of the Securities Act.  o Yes ⌧No

Indicate by check mark if the registrant is not required tofile reports pursuant to Section 13 or Section 15(d) of the Act.  o Yes ⌧No

Indicate by check mark whether the registrant (1) has filedall reports required to be filed by Section 13 or 15(d) of the SecuritiesExchange Act of 1934 during the preceding 12 months (or for such shorter periodthat the registrant was required to file such reports), and (2) has beensubject to such filing requirements for the past 90 days.  ⌧ Yes oNo

Indicate by check mark whether the registrant has submittedelectronically and posted on its corporate Web site, if any, every InteractiveData File required to be submitted and posted pursuant to Rule 405 ofRegulation S-T (Section 232.405 of this chapter) during the preceding 12 months(or for such shorter period that the registrant was required to submit and postsuch files).

Not applicable.

Indicate by check mark if disclosure of delinquent filerspursuant to Item 405 of Regulation S-K (Section 229.405 of this chapter) is notcontained herein, and will not be contained, to the best of registrant’sknowledge, in definitive proxy or information statements incorporated byreference in Part III of this Form 10-K or any amendment to this Form10-K.   

Not applicable.

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

Large acceleratedfiler        o                                                                                                       Acceleratedfiler                                     o

Non-acceleratedfiler          ⌧  (Do not check ifa smaller reporting company)                          Smaller reportingcompany                    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 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 all documentsand reports required to be filed by Section 12, 13 or 15(d) of the SecuritiesExchange Act of 1934 subsequent to the distribution of securities under a planconfirmed by a court.  o Yes 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 documents shouldbe clearly described for identification purposes (e.g., annual report tosecurity holders for fiscal year ended December 24, 1980).

Not applicable.

 

** **

**EXPLANATORY NOTES**

The Nova Place Mortgage Loan, the 450-460 ParkAvenue South Mortgage Loan, the El Con Center Mortgage Loan, the Shetland ParkMortgage Loan and the ExchangeRight Net Leased Portfolio #27 Mortgage Loan,which constituted approximately 9.7%, 6.2%, 6.2%, 6.2% and 5.6%, respectively,of the asset pool of the issuing entity as of its cut-off date, are each anasset of the issuing entity and are each part of a loan combination thatincludes (a) with respect to the Nova Place Mortgage Loan which is an asset ofthe issuing entity and two other *pari passu* loans, which are not assetsof the issuing entity, (b) with respect to the 450-460 Park Avenue SouthMortgage Loan which is an asset of the issuing entity and one other *paripassu* loan, which is not an asset of the issuing entity, (c) with respectto the El Con Center Mortgage Loan which is an asset of the issuing entity andone other *pari passu* loan, which is not an asset of the issuing entity,(d) with respect to the Shetland Park Mortgage Loan which is an asset of theissuing entity and one other *pari passu* loan, which is not an asset of theissuing entity and (e) with respect to the ExchangeRight Net Leased Portfolio#27 Mortgage Loan which is an asset of the issuing entity and one other *paripassu* loan, which is not an asset of the issuing entity. These loancombinations, including the Nova Place Mortgage Loan, the 450-460 Park AvenueSouth Mortgage Loan, the El Con Center Mortgage Loan, the Shetland ParkMortgage Loan and the ExchangeRight Net Leased Portfolio #27 Mortgage Loan, arebeing serviced and administered pursuant to the Pooling and ServicingAgreement, which is incorporated by reference as Exhibit 4.1 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 Hilton at University Place Mortgage Loan,which constituted approximately 1.5% of the asset pool of the issuing entity asof its cut-off date.  The Hilton at University Place Mortgage Loan is anasset of the issuing entity and is part of a loan combination that includes theHilton at University Place Mortgage Loan and one other *pari passu* loan,which is not an asset of the issuing entity. The other *pari passu*portion of the loan combination was securitized in the Wells Fargo CommercialMortgage Trust 2019-C50 transaction, Commission File Number 333-226486-05 (the“WFCM 2019-C50 Transaction”). This loan combination, including theHilton at University Place Mortgage Loan, is being serviced and administeredpursuant to the pooling and servicing agreement for the WFCM 2019-C50Transaction, which is incorporated by reference as Exhibit 4.2 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 Patuxent Crossing Mortgage Loan and theWolverine Portfolio Mortgage Loan, which constituted approximately 2.3% and0.5%, respectively, of the asset pool of the issuing entity as of its cut-offdate.  The Patuxent Crossing Mortgage Loan and the Wolverine PortfolioMortgage Loan are each an asset of the issuing entity and are each part of aloan combination that includes (a) with respect to the Patuxent CrossingMortgage Loan and one other *pari passu* loan, which is not an asset ofthe issuing entity or (b) with respect to the Wolverine Portfolio Mortgage Loanand eight other *pari passu* loans, which are not assets of the issuingentity. The other *pari passu* portion of each loan combination wassecuritized in the BBCMS Mortgage Trust 2019-C3 transaction, Commission FileNumber 333-226850-02 (the “BBCMS 2019-C3 Transaction”). These loancombinations, including the Patuxent Crossing Mortgage Loan and the WolverinePortfolio Mortgage Loan, are being serviced and administered pursuant to thepooling and servicing agreement for the BBCMS 2019-C3 Transaction, which isincorporated by reference as Exhibit 4.3 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the CIRE Equity Retail & IndustrialPortfolio Mortgage Loan, which constituted approximately 3.0% of the asset poolof the issuing entity as of its cut-off date.  The CIRE Equity Retail& Industrial Portfolio Mortgage Loan is an asset of the issuing entity andis part of a loan combination that includes the CIRE Equity Retail &Industrial Portfolio Mortgage Loan and five other *pari passu* loans,which are not assets of the issuing entity.This loan combination, including theCIRE Equity Retail & Industrial 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 CIRE Equity Retail& Industrial Portfolio  loan combination in the Benchmark 2019-B12Mortgage Trust transaction, Commission File Number 333-228597-01 (the “BMARK2019-B12 Transaction”).  After the closing of the BMARK 2019-B12Transaction on August 8, 2019, this loan combination, including the CIRE EquityRetail & Industrial Portfolio Mortgage Loan was, and will continue to be,serviced and administered pursuant to the pooling and servicing agreement withrespect to the BMARK 2019-B12 Transaction, which is incorporated by referenceas Exhibit 4.4 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 188 Spear Street Mortgage Loan, whichconstituted approximately 6.4% 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 BBCMS MortgageTrust 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 describes exhibitsprovided by certain parties (in their capacities indicated on the ExhibitIndex) with respect to The Chantilly Office Portfolio Mortgage Loan, whichconstituted approximately 3.1% of the asset pool of the issuing entity as ofits cut-off date.  The Chantilly Office Portfolio Mortgage Loan is anasset of the issuing entity and is part of a loan combination that includes TheChantilly Office Portfolio Mortgage Loan and two other *pari passu* loans,which are not assets of the issuing entity. This loan combination, includingThe Chantilly Office Portfolio Mortgage Loan, was serviced under the Poolingand Servicing Agreement for the issuing entity prior to the closing of thesecuritization of a *pari passu* portion of The Chantilly Office Portfolioloan 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 Chantilly Office Portfolio Mortgage Loan was,and will continue to be, serviced and administered pursuant to the pooling andservicing agreement with respect to the UBS 2019-C17 Transaction, which isincorporated by reference as Exhibit 4.6 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 administered pursuantto 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 188 Spear Street Mortgage Loan, The Chantilly OfficePortfolio Mortgage Loan and the Hilton at University Place Mortgage Loan. As aresult, Wells Fargo Bank, National Association is a “servicer” as defined inItem 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, National Association is the custodian ofthe mortgage loans serviced under the Pooling and Servicing Agreement, the 188Spear Street Mortgage Loan, The Chantilly Office Portfolio Mortgage Loan, theHilton at University Place Mortgage Loan, the Patuxent Crossing Mortgage Loanand the Wolverine Portfolio Mortgage Loan.  As a result, Wells Fargo Bank,National Association is a servicing function participant in the capacitiesdescribed above, because it is servicing mortgage loans that constituted 5% ormore of the assets of the issuing entity as of its cut-off date. Theassessments of compliance with applicable servicing criteria and accountants’attestation reports delivered by Wells Fargo Bank, National Association in thecapacities described above are listed in the Exhibit Index.

Pentalpha Surveillance LLC is the operating advisor of themortgage loans serviced under the Pooling and Servicing Agreement, TheChantilly Office Portfolio Mortgage Loan, the CIRE Equity Retail &Industrial Portfolio Mortgage Loan, the Patuxent Crossing Mortgage Loan and theWolverine Portfolio Mortgage Loan.  As a result, Pentalpha SurveillanceLLC is a servicing function participant in the capacities described above,because it is servicing mortgage loans that constituted 5% or more of theassets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria and accountants’ attestationreports delivered by Pentalpha Surveillance LLC in the capacities describedabove are listed in the Exhibit Index.

Rialto Capital Advisors, LLC isthe special servicer of the 188 Spear Street Mortgage Loan, The ChantillyOffice Portfolio Mortgage Loan and the Hilton at University Place MortgageLoan. As a result, Rialto Capital Advisors, LLC is a “servicer” as defined inItem 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 Rialto Capital Advisors, LLC inthe capacities described above are listed in the Exhibit Index.

Park Bridge Lender Services LLC is the operating advisor ofthe 188 Spear Street Mortgage Loan and the Hilton at University Place MortgageLoan.  As a result, Park Bridge Lender Services LLC is a servicingfunction participant in the capacities described above, because it is servicingmortgage loans that constituted 5% or more of the assets of the issuing entityas of its cut-off date. The assessments of compliance with applicable servicingcriteria and accountants’ attestation reports delivered by Park Bridge LenderServices LLC in the capacities described above are listed in the Exhibit Index.

Midland Loan Services, a Divisionof PNC Bank, National Association is the primary servicer and special servicerof the Patuxent Crossing Mortgage Loan and the CIRE Equity Retail &Industrial Portfolio Mortgage Loan and the special servicer of the WolverinePortfolio Mortgage Loan.  These mortgage loans constitute more than 5%,but less than 10%, of the pool assets of the issuing entity.  Therefore,the Depositor included in this Annual Report on Form 10-K an assessment ofcompliance with applicable servicing criteria for Midland Loan Services, aDivision of PNC Bank, National Association and an accountants’ attestationreport pursuant to Item 1122 of Regulation AB because Midland Loan Services, aDivision of PNC Bank, National Association is servicing more than 5% of the poolassets.  However, the Depositor is not required to include in this AnnualReport on Form 10-K a servicer compliance statement pursuant to Item 1123 ofRegulation AB of Midland Loan Services, a Division of PNC Bank, NationalAssociation because Midland Loan Services, a Division of PNC Bank, NationalAssociation is an unaffiliated servicer servicing less than 10% of pool assets.

Wilmington Trust, NationalAssociation acts as trustee of the mortgage loans serviced under the Poolingand Servicing Agreement, the Hilton at University Place Mortgage Loan, the CIREEquity Retail & Industrial Portfolio Mortgage Loan, the 188 Spear StreetMortgage Loan and The Chantilly Office Portfolio Mortgage Loan.  Pursuantto the Pooling and Servicing Agreement, the pooling and servicing agreement forthe WFCM 2019-C50 Transaction, the pooling and servicing agreement for theBMARK 2019-B12 Transaction, the pooling and servicing agreement for the BBCMS2019-C4 Transaction and the pooling and servicing agreement for the UBS 2019-C17Transaction, the trustee is required to provide an assessment of compliancewith applicable servicing criteria solely with respect to Item 1122(d)(2)(iii)of Regulation AB (regarding advances of funds or guarantees regardingcollections, cash flows or distributions, and any interest or other feescharged for such advances, are made, reviewed and approved as specified in thetransaction agreements). However, during the reporting period, the trustee didnot perform any servicing function with respect to the servicing criteriaspecified in Item 1122(d)(2)(iii) of Regulation AB.  The master serviceror the special servicer, to the extent required, performed the servicingfunction identified with respect to Item 1122(d)(2)(iii) of Regulation AB, and eachsuch party included Item 1122(d)(2)(iii) of Regulation AB in the assessment ofcompliance with applicable servicing criteria and accountant’s attestationreport for the subject transaction.  As a result, this Annual Report onForm 10-K does not include an assessment of compliance with applicableservicing criteria of the trustee. One or more other servicers of the mortgageloans serviced under the Pooling and Servicing Agreement, the Hilton atUniversity Place Mortgage Loan, the CIRE Equity Retail & IndustrialPortfolio Mortgage Loan, the 188 Spear Street Mortgage Loan and The ChantillyOffice Portfolio Mortgage Loan have delivered one or more assessments ofcompliance with respect to Item 1122(d)(2)(iii) of Regulation AB.

Wells Fargo Bank, NationalAssociation acts as trustee of the Patuxent Crossing Mortgage Loan and theWolverine Portfolio Mortgage Loan.  Pursuant to the pooling and servicingagreement for the BBCMS 2019-C3 Transaction, the trustee is required to providean assessment of compliance with applicable servicing criteria solely withrespect to Item 1122(d)(2)(iii) of Regulation AB (regarding advances of fundsor guarantees regarding collections, cash flows or distributions, and anyinterest or other fees charged for such advances, are made, reviewed andapproved as specified in the transaction agreements). However, during thereporting period, the trustee did not perform any servicing function withrespect to the servicing criteria specified in Item 1122(d)(2)(iii) ofRegulation AB.  The master servicer or the special servicer, to the extentrequired, performed the servicing function identified with respect to Item1122(d)(2)(iii) of Regulation AB, and each such party included Item1122(d)(2)(iii) of Regulation AB in the assessment of compliance withapplicable servicing criteria and accountant’s attestation report for theSubject Transaction.  As a result, this Annual Report on Form 10-K doesnot include an assessment of compliance with applicable servicing criteria ofthe trustee. One or more other servicers of the Patuxent Crossing Mortgage Loanand the Wolverine Portfolio Mortgage Loan have delivered one or moreassessments of compliance with respect to Item 1122(d)(2)(iii) of RegulationAB.

This Annual Report on Form 10-Kincludes assessments of compliance with applicable servicing criteria andaccountants’ attestation reports from CoreLogic Commercial Real EstateServices, Inc. and National Tax Search, LLC.  These entities were engagedby the master servicer under the Pooling and Servicing Agreement and theprimary servicer of the Hilton at University Place Mortgage Loan, the 188 SpearStreet Mortgage Loan and The Chantilly Office Portfolio Mortgage Loan to remittax payments received from the escrow accounts of borrowers to local taxingauthorities, to report tax amounts due, to verify tax parcel information, andto verify non-escrow tax payments. These servicing functions are includedwithin the servicing criteria set forth in Items 1122(d)(4)(xi) and1122(d)(4)(xii) of Regulation AB.  Therefore, under the principles-baseddefinition of “servicer” set forth in Item 1101(j) of Regulation AB that looksto the functions that an entity performs, these vendors are “servicers” for thepurposes of Item 1122 of Regulation AB.  *See* Compliance andDisclosure Interpretations, Section 301.01 (Item 1101(j)).

Theassessments of compliance with applicable servicing criteria, accountants’attestation reports and servicer compliance statements of the certificateadministrator of the Hilton at University Place Mortgage Loan, the PatuxentCrossing Mortgage Loan, the Wolverine Portfolio Mortgage Loan, the 188 SpearStreet Mortgage Loan, The Chantilly Office Portfolio Mortgage Loan and the CIREEquity Retail & Industrial Portfolio Mortgage Loan listed on the ExhibitIndex are omitted from this Annual Report on Form 10-K as the certificateadministrator pursuant to the related pooling and servicing agreement or trustand servicing agreement does not perform any activities that address servicingcriteria with respect to the issuing entity and because they are each not a“servicer” that meets the criteria in Item 1108(a)(2)(i) through (iii) ofRegulation AB.

With respect to the *pari passu*loan combinations that include the Patuxent Crossing Mortgage Loan, theWolverine Portfolio Mortgage Loan and the CIRE Equity Retail & IndustrialPortfolio Mortgage Loan, (i) the reports on assessment of compliance withservicing criteria and attestation reports on assessment of compliance withservicing criteria of KeyBank National Association as primary servicer of theWolverine Portfolio Mortgage Loan and Citibank, N.A. as custodian of the CIREEquity Retail & Industrial Portfolio Mortgage Loan, listed on the ExhibitIndex are omitted from this Annual Report on Form 10-K as they are not requiredto be included on this Annual Report on Form 10-K per Instruction 3 to Item1122 of Regulation AB because it is a party 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 Wolverine Portfolio Mortgage Loan, Midland LoanServices, a Division of PNC Bank, National Association as primary servicer ofthe Patuxent Crossing Mortgage Loan and the CIRE Equity Retail & IndustrialPortfolio Mortgage Loan, listed on the Exhibit Index are omitted from thisAnnual Report on Form 10-K as they are not required by Item 1123 of RegulationAB to be included on this Annual Report on Form 10-K because they are each anunaffiliated party that is not a “servicer” that meets the criteria in Item1108(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.  Selected Financial Data.**

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**Item 9B.  Other Information.**

None.

**PART III**

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

Omitted.

**Item 11.  Executive Compensation.**

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**ADDITIONAL DISCLOSURE ITEMS FOR REGULATION AB**

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

No single obligor represents 10% or more of the pool 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 credit enhancementor other support for the certificates within this transaction as describedunder 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 nomaterial pending legal proceeding involving the trust or any party related tothe trust, other than routine litigation incidental to the duties of thoserespective parties, and the following, with respect to Citibank N.A., ascustodian, and Wells Fargo Bank, National Association, as certificateadministrator, as custodian and as trustee. 

In the ordinary course of business, Citibank, N.A. (“Citibank”)is involved in a number of legal proceedings, including in connection with itsrole as trustee of certain RMBS transactions.  Certain of these Citibankas trustee-related matters are disclosed herein. 

On June 18, 2014, a civil action was filed against Citibankin the Supreme Court of the State of New York by a group of investors in 48private-label RMBS trusts for which Citibank allegedly serves or did serve astrustee, asserting claims for purported violations of the Trust Indenture Actof 1939 (the “Trust Indenture Act”), breach of contract, breach offiduciary duty and negligence based on Citibank’s alleged failure to performits duties as trustee for the 48 RMBS trusts.  On November 24, 2014,plaintiffs sought leave to withdraw this action.  On the same day, asmaller subset of similar plaintiff investors in 27 private-label RMBS trustsfor which Citibank allegedly serves or did serve as trustee, filed a new civilaction against Citibank in the United States District Court for the SouthernDistrict of New York asserting similar claims as the prior action filed instate court.  In January 2015, the court closed plaintiffs’ original statecourt action.  On September 8, 2015, the federal court dismissed allclaims as to 24 of the 27 trusts and allowed certain of the claims to proceedas to the other three trusts. Subsequently, plaintiffs voluntarily dismissedall claims with respect to two of the three trusts. On April 7, 2017, Citibankfiled a motion for summary judgment. Plaintiffs filed its consolidatedopposition brief and cross motion for partial summary judgment on May 22,2017.  Briefing on those motions was completed on August 4, 2017. On March22, 2018, the court granted Citibank’s motion for summary judgment in itsentirety, denied Plaintiffs’ motion for summary judgment and ordered the clerkto close the case. On April 20, 2018, plaintiffs filed a notice of appeal.Plaintiffs’ opening brief was filed on August 3, 2018. Citibank filed itsopposition on November 2, 2018.  Plaintiffs’ filed their reply on November16, 2018.  On June 7, 2019, the Second Circuit dismissed plaintiffs’appeal following the parties’ filing of a stipulation withdrawing the case withprejudice pursuant to Federal Rule of Appellate Procedure 42.

On November 24, 2015, the same investors that brought thefederal case brought a new civil action in the Supreme Court of the State ofNew York related to 25 private-label RMBS trusts for which Citibank allegedlyserves or did serve as trustee.  This case includes the 24 trustspreviously dismissed in the federal action, and one additional trust.  Theinvestors assert claims for breach of contract, breach of fiduciary duty, breachof duty to avoid conflicts of interest, and violation of New York’s Streit Act(the “Streit Act”).  Following oral argument on Citibank’s motionto dismiss, Plaintiffs filed an amended complaint on August 5, 2016.  OnJune 27, 2017, the state court issued a decision, dismissing the Event ofDefault claims, mortgage-file-related claims, the fiduciary duty claims, andthe conflict of interest claims.  The decision sustained certain breach ofcontract claims including the claim alleging discovery of breaches ofrepresentations and warranties, a claim related to robo-signing, and theimplied covenant of good faith claim.  Citibank appealed the lower court’sdecision, and on January 16, 2018, the Appellate Division, First Department,dismissed the claims related to robo-signing and the implied covenant of goodfaith, but allowed plaintiffs’ claim alleging discovery of breaches ofrepresentations and warranties to proceed.  On June 7, 2019, plaintiffsfiled a motion for discontinuance of the action and dismissal of plaintiffs’claims with prejudice.

On August 19, 2015, the Federal Deposit Insurance Corporation(“FDIC”) as Receiver for a failed financial institution filed a civilaction against Citibank in the Southern District of New York.  This actionrelates to one private-label RMBS trust for which Citibank formerly served astrustee.  FDIC asserts claims for breach of contract, violation of theStreit Act, and violation of the Trust Indenture Act. Citibank jointly briefeda motion to dismiss with The Bank of New York Mellon and U.S. Bank, N.A.,entities that have also been sued by FDIC in their capacity as trustee, andthese cases have all been consolidated in front of Judge Carter.  OnSeptember 30, 2016, the Court granted the motion to dismiss without prejudicefor lack of subject matter jurisdiction.  On October 14, 2016, FDIC fileda motion for reargument or relief from judgment from the Court’s dismissalorder.  On July 11, 2017, Judge Carter ruled on the motion forreconsideration regarding his dismissal of the action.  He deniedreconsideration of his decision on standing, but granted leave to amend thecomplaint by October 9, 2017.  The FDIC subsequently requested anextension of time to file its amended complaint, which was granted. The FDIC filedits amended complaint on December 8, 2017. Defendants’ jointly filed a motionto dismiss the amended complaint and that joint motion was fully briefed as ofMay 3, 2018.  On March 20, 2019, the Court granted Defendants’ jointmotion to dismiss the amended complaint. The FDIC's deadline to file a noticeof appeal was April 22, 2019. The FDIC has not appealed. 

There can be no assurances as to the outcome of litigation orthe possible impact of litigation on the trustee or the RMBS trusts. However, Citibank denies liability and continues to vigorously defend againstthese litigations.  Furthermore, neither the above-disclosed litigationsnor any other pending legal proceeding involving Citibank will materiallyaffect Citibank’s ability to perform its duties under the related servicingagreement for this CMBS transaction.

 

Beginning on June 18, 2014, agroup of institutional investors filed civil complaints in the Supreme Court ofthe State of New York, New York County, and later the U.S. District Court forthe Southern District of New York, against Wells Fargo Bank, N.A., (“WellsFargo Bank”) in its capacity as trustee for certain residential mortgagebacked securities (“RMBS”) trusts.  The complaints against WellsFargo Bank alleged that the trustee caused losses to investors and assertedcauses of action based upon, among other things, the trustee's alleged failureto: (i) notify and enforce repurchase obligations of mortgage loan sellers forpurported breaches of representations and warranties, (ii) notify investors ofalleged events of default, and (iii) abide by appropriate standards of carefollowing alleged events of default. Relief sought included money damages in anunspecified amount, reimbursement of expenses, and equitable relief. InNovember 2018, Wells Fargo Bank reached an agreement, in which it denied anywrongdoing, to resolve such claims on a classwide basis for the 271 RMBS trustsat issue.  On May 6, 2019, the court entered an order approving thesettlement agreement.  Separate lawsuits against Wells Fargo Bank makingsimilar allegations filed by certain other institutional investors concerningseveral RMBS trusts in New York federal and state court are not covered by theagreement.  With respect to such litigations, Wells Fargo Bank believes plaintiffs'claims are without merit and intends to contest the claims vigorously, butthere can be no assurances as to the outcome of the litigations or the possibleimpact of the litigations on Wells Fargo Bank or the RMBS trusts.

**Item 1119 of Regulation AB, Affiliations and CertainRelationships and Related Transactions.**

The information regarding this Item has been previouslyprovided in the prospectus of the Registrant relating to the issuing entityfiled on July 11, 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 entities participatingin a servicing function for the transaction responsible for each applicableservicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Hilton at University PlaceMortgage Loan, which is being serviced and administered pursuant to the poolingand servicing agreement for the WFCM 2019-C50 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit AA to thepooling and servicing agreement for the WFCM 2019-C50 Transaction incorporatedby reference as Exhibit 4.2 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the WFCM2019-C50 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 Patuxent Crossing Mortgage Loanand the Wolverine Portfolio Mortgage Loan, which are being serviced andadministered pursuant to the pooling and servicing agreement for the BBCMS2019-C3 Transaction, are attached hereto under Item 15 to this Annual Report onForm 10-K. Attached as Exhibit AA to the pooling and servicing agreement forthe BBCMS 2019-C3 Transaction incorporated by reference as Exhibit 4.3 to thisAnnual Report on Form 10-K is a chart identifying the entities participating ina servicing function for the BBCMS 2019-C3 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 CIRE Equity Retail &Industrial Portfolio Mortgage Loan, which is being serviced and administeredpursuant to the pooling and servicing agreement for the BMARK 2019-B12Transaction, are attached hereto under Item 15 to this Annual Report on Form10-K. Attached as Exhibit O to the pooling and servicing agreement for theBMARK 2019-B12 Transaction incorporated by reference as Exhibit 4.4 to thisAnnual Report on Form 10-K is a chart identifying the entities participating ina servicing function for the BMARK 2019-B12 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 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 Chantilly Office PortfolioMortgage Loan, which is being serviced and administered pursuant to the poolingand servicing agreement for the UBS 2019-C17 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit Z to thepooling and servicing agreement for the UBS 2019-C17 Transaction incorporatedby reference as Exhibit 4.6 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the UBS2019-C17 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The report on assessment of compliance with applicableservicing criteria furnished pursuant to Item 1122 of Regulation AB by MidlandLoan Services, a Division of PNC Bank National Association (“Midland”)discloses that a material instance of noncompliance occurred, as describedbelow:

Material Instance of Noncompliance

In certain instances, the ScheduleAL Files (Item 1125 of Regulation AB) were not reported in accordance with theterms specified in the transaction agreements, in conflict with Item1122(d)(3)(i): “Reports to investors, including those to be filed with theCommission, are maintained in accordance with the transaction agreements andapplicable Commission requirements. Specifically, such reports: (A) Areprepared in accordance with timeframes and other terms set forth in thetransaction agreements”.  The noncompliance consisted of omitted orinaccurately reported fields as described in (1) and (2) below.  (1) Inconnection with other enhancements Midland made to its manual Schedule ALprocess, starting in April 2019, Midland developed and implemented new ScheduleAL reporting templates for each applicable CMBS transaction that closed priorto April 2019 and for each applicable CMBS transaction going forward. Related to this, Midland made certain template setup errors, along with relatedand other manual inputting of information errors, and the errors were notidentified prior to submission of the applicable Schedule AL Files in certaincases due to breakdowns in quality control.  (2) In one applicabletransaction, the related Schedule AL File for a given month was not savedproperly resulting in the prior month's Schedule AL File being submitted forthe given month instead of the correct Schedule AL File. 

The identified instances did notinvolve the servicing of assets included in this securitization.

Steps Taken to Remedy the Material Instance of Noncompliance

Midland’s Schedule AL reportingprocess was enhanced in April of 2019, however, the process remained manualthroughout the 2019 calendar year.  Errors relating to certain Schedule ALFiles during 2019 were identified during the related audit.  Followingidentification, Midland made staffing changes and additional enhancements andimprovements to its processes and procedures to support its Schedule ALreporting obligations and expects to move to an automated solution for thisprocess.  

Midland is currently remediating theSchedule AL reporting for certain of the CMBS transactions found to beincorrect. 

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

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

**PART IV**

**Item 15. Exhibits, Financial Statement Schedules**

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

(1) Not applicable

(2) Not applicable

(3) See below

 

4.1          Poolingand Servicing Agreement, dated as of July 1, 2019, by and among Wells Fargo CommercialMortgage 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 as Asset Representations Reviewer (filed asExhibit 4.1 to the registrant’s Current Report on Form 8-K/A filed on August15, 2019 under Commission File No. 333-226486-06 and incorporated by referenceherein).

4.2          Poolingand Servicing Agreement, dated as of May 1, 2019, between Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, Rialto Capital Advisors, LLC, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Park Bridge LenderServices LLC, as Operating Advisor and as Asset Representations Reviewer (filedas Exhibit 99.7 to the registrant’s Current Report on Form 8-K filed on July11, 2019 under Commission File No. 333-226486-06 and incorporated by referenceherein).

4.3          Poolingand Servicing Agreement, dated as of June 1, 2019, by and among BarclaysCommercial Mortgage Securities LLC, as Depositor, Midland Loan Services, aDivision of PNC Bank, National Association, as Master Servicer, Midland LoanServices, a Division of PNC Bank, National Association, as Special Servicer,Wells Fargo Bank, National Association, as Certificate Administrator, WellsFargo Bank, National Association, as Trustee, and Pentalpha Surveillance LLC,as Operating Advisor and as Asset Representations Reviewer (filed as Exhibit99.6 to the registrant’s Current Report on Form 8-K filed on July 11, 2019under Commission File No. 333-226486-06 and incorporated by reference herein).

4.4          Poolingand Servicing Agreement, dated as of August 1, 2019, between CitigroupCommercial Mortgage Securities Inc., as Depositor, Midland Loan Services, aDivision of PNC Bank, National Association, as Master Servicer, Midland LoanServices, a Division of PNC Bank, National Association, Pacific Life InsuranceCompany and Trimont Real Estate Advisors, LLC, each as a Special Servicer,Pentalpha Surveillance LLC, as Operating Advisor and Asset RepresentationsReviewer, Citibank, N.A., as Certificate Administrator, and Wilmington Trust,National Association, as Trustee (filed as Exhibit 99.1 to the registrant’sCurrent Report on Form 8-K filed on August 13, 2019 under Commission File No.333-226486-06 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 Special Servicer,Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Park Bridge LenderServices LLC, as Operating Advisor and as Asset Representations Reviewer (filedas Exhibit 99.1 to the registrant’s Current Report on Form 8-K filed onSeptember 3, 2019 under Commission File No. 333-226486-06 and incorporated byreference 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 as 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. 333-226486-06 andincorporated 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, NationalAssociation, as Master Servicer

33.2        C-III Asset ManagementLLC, as Special Servicer

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

33.4        Wells Fargo Bank, NationalAssociation, as Certificate Administrator

33.5        Wells Fargo Bank, NationalAssociation, as Custodian

33.6        Pentalpha SurveillanceLLC, as Operating Advisor

33.7        CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant

33.8        National Tax Search, LLC,as Servicing Function Participant

33.9        Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Nova Place Mortgage Loan (see Exhibit33.1)

33.10      C-III Asset ManagementLLC, as Special Servicer of the Nova Place Mortgage Loan (see Exhibit 33.2)

33.11      Wilmington Trust, National Association, as Trustee of the Nova Place MortgageLoan (Omitted. See Explanatory Notes.)

33.12      Wells Fargo Bank, NationalAssociation, as Custodian of the Nova Place Mortgage Loan (see Exhibit 33.5)

33.13      Pentalpha SurveillanceLLC, as Operating Advisor of the Nova Place Mortgage Loan (see Exhibit 33.6)

33.14      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Nova PlaceMortgage Loan (see Exhibit 33.7)

33.15      National Tax Search, LLC,as Servicing Function Participant of the Nova Place Mortgage Loan (see Exhibit33.8)

33.16      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 450-460 Park Avenue South Mortgage Loan(see Exhibit 33.1)

33.17      C-III Asset ManagementLLC, as Special Servicer of the 450-460 Park Avenue South Mortgage Loan (seeExhibit 33.2)

33.18      Wilmington Trust, National Association, as Trustee of the 450-460 Park AvenueSouth Mortgage Loan (Omitted. See Explanatory Notes.)

33.19      Wells Fargo Bank, NationalAssociation, as Custodian of the 450-460 Park Avenue South Mortgage Loan (seeExhibit 33.5)

33.20      Pentalpha SurveillanceLLC, as Operating Advisor of the 450-460 Park Avenue South Mortgage Loan (seeExhibit 33.6)

33.21      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the 450-460 ParkAvenue South Mortgage Loan (see Exhibit 33.7)

33.22      National Tax Search, LLC,as Servicing Function Participant of the 450-460 Park Avenue South MortgageLoan (see Exhibit 33.8)

33.23      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the El Con Center Mortgage Loan (seeExhibit 33.1)

33.24      C-III Asset ManagementLLC, as Special Servicer of the El Con Center Mortgage Loan (see Exhibit 33.2)

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

33.26      Wells Fargo Bank, NationalAssociation, as Custodian of the El Con Center Mortgage Loan (see Exhibit 33.5)

33.27      Pentalpha SurveillanceLLC, as Operating Advisor of the El Con Center Mortgage Loan (see Exhibit 33.6)

33.28      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the El Con CenterMortgage Loan (see Exhibit 33.7)

33.29      National Tax Search, LLC,as Servicing Function Participant of the El Con Center Mortgage Loan (seeExhibit 33.8)

33.30      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Shetland Park Mortgage Loan (seeExhibit 33.1)

33.31      C-III Asset ManagementLLC, as Special Servicer of the Shetland Park Mortgage Loan (see Exhibit 33.2)

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

33.33      Wells Fargo Bank, NationalAssociation, as Custodian of the Shetland Park Mortgage Loan (see Exhibit 33.5)

33.34      Pentalpha SurveillanceLLC, as Operating Advisor of the Shetland Park Mortgage Loan (see Exhibit 33.6)

33.35      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Shetland ParkMortgage Loan (see Exhibit 33.7)

33.36      National Tax Search, LLC,as Servicing Function Participant of the Shetland Park Mortgage Loan (seeExhibit 33.8)

33.37      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the ExchangeRight Net Leased Portfolio #27Mortgage Loan (see Exhibit 33.1)

33.38      C-III Asset ManagementLLC, as Special Servicer of the ExchangeRight Net Leased Portfolio #27 MortgageLoan (see Exhibit 33.2)

33.39      Wilmington Trust, National Association, as Trustee of the ExchangeRight NetLeased Portfolio #27 Mortgage Loan (Omitted. See Explanatory Notes.)

33.40      Wells Fargo Bank, NationalAssociation, as Custodian of the ExchangeRight Net Leased Portfolio #27Mortgage Loan (see Exhibit 33.5)

33.41      Pentalpha SurveillanceLLC, as Operating Advisor of the ExchangeRight Net Leased Portfolio #27Mortgage Loan (see Exhibit 33.6)

33.42      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the ExchangeRightNet Leased Portfolio #27 Mortgage Loan (see Exhibit 33.7)

33.43      National Tax Search, LLC,as Servicing Function Participant of the ExchangeRight Net Leased Portfolio #27Mortgage Loan (see Exhibit 33.8)

33.44      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Hilton at University Place MortgageLoan (see Exhibit 33.1)

33.45      Rialto Capital Advisors,LLC, as Special Servicer of the Hilton at University Place Mortgage Loan

33.46      Wilmington Trust, National Association, as Trustee of the Hilton at UniversityPlace Mortgage Loan (Omitted. See Explanatory Notes.)

33.47      Wells Fargo Bank, NationalAssociation, as Custodian of the Hilton at University Place Mortgage Loan (seeExhibit 33.5)

33.48      Park Bridge LenderServices LLC, as Operating Advisor of the Hilton at University Place MortgageLoan

33.49      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Hilton atUniversity Place Mortgage Loan (see Exhibit 33.7)

33.50      National Tax Search, LLC,as Servicing Function Participant of the Hilton at University Place MortgageLoan (see Exhibit 33.8)

33.51      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the PatuxentCrossing Mortgage Loan

33.52      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the PatuxentCrossing Mortgage Loan (see Exhibit 33.51)

33.53      Wells Fargo Bank, National Association, as Trustee of the Patuxent CrossingMortgage Loan (Omitted. See Explanatory Notes.)

33.54      Wells Fargo Bank, NationalAssociation, as Custodian of the Patuxent Crossing Mortgage Loan (see Exhibit 33.5)

33.55      Pentalpha SurveillanceLLC, as Operating Advisor of the Patuxent Crossing Mortgage Loan (see Exhibit33.6)

33.56      KeyBank National Association, as Primary Servicer of the Wolverine PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.57      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of theWolverine Portfolio Mortgage Loan (see Exhibit 33.51)

33.58      Wells Fargo Bank, National Association, as Trustee of the Wolverine PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.59      Wells Fargo Bank, NationalAssociation, as Custodian of the Wolverine Portfolio Mortgage Loan (see Exhibit33.5)

33.60      Pentalpha SurveillanceLLC, as Operating Advisor of the Wolverine Portfolio Mortgage Loan (see Exhibit33.6)

33.61      Midland Loan Services, a Divisionof PNC Bank, National Association, as Primary Servicer of the CIRE EquityRetail & Industrial Portfolio Mortgage Loan (see Exhibit 33.51)

33.62      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the CIREEquity Retail & Industrial Portfolio Mortgage Loan (see Exhibit 33.51)

33.63      Wilmington Trust, National Association, as Trustee of the CIRE Equity Retail& Industrial Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.64      Citibank, N.A., as Custodian of the CIRE Equity Retail & IndustrialPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.65      Pentalpha SurveillanceLLC, as Operating Advisor of the CIRE Equity Retail & Industrial PortfolioMortgage Loan (see Exhibit 33.6)

33.66      U.S. Bank NationalAssociation, as Servicing Function Participant of the CIRE Equity Retail &Industrial Portfolio Mortgage Loan

33.67      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 188 Spear Street Mortgage Loan (seeExhibit 33.1)

33.68      Rialto Capital Advisors,LLC, as Special Servicer of the 188 Spear Street Mortgage Loan (see Exhibit33.45)

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

33.70      Wells Fargo Bank, NationalAssociation, as Custodian of the 188 Spear Street Mortgage Loan (see Exhibit33.5)

33.71      Park Bridge LenderServices LLC, as Operating Advisor of the 188 Spear Street Mortgage Loan (seeExhibit 33.48)

33.72      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the 188 SpearStreet Mortgage Loan (see Exhibit 33.7)

33.73      National Tax Search, LLC,as Servicing Function Participant of the 188 Spear Street Mortgage Loan (seeExhibit 33.8)

33.74      Wells Fargo Bank, NationalAssociation, as Primary Servicer of The Chantilly Office Portfolio MortgageLoan (see Exhibit 33.1)

33.75      Rialto Capital Advisors,LLC, as Special Servicer of The Chantilly Office Portfolio Mortgage Loan (seeExhibit 33.45)

33.76      Wilmington Trust, National Association, as Trustee of The Chantilly Office PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.77      Wells Fargo Bank, NationalAssociation, as Custodian of The Chantilly Office Portfolio Mortgage Loan (seeExhibit 33.5)

33.78      Pentalpha SurveillanceLLC, as Operating Advisor of The Chantilly Office Portfolio Mortgage Loan (seeExhibit 33.6)

33.79      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of The ChantillyOffice Portfolio Mortgage Loan (see Exhibit 33.7)

33.80      National Tax Search, LLC,as Servicing Function Participant of The Chantilly Office Portfolio MortgageLoan (see Exhibit 33.8)

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

34.1        Wells Fargo Bank, NationalAssociation, as Master Servicer

34.2        C-III Asset ManagementLLC, as Special Servicer

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

34.4        Wells Fargo Bank, NationalAssociation, as Certificate Administrator

34.5        Wells Fargo Bank, NationalAssociation, as Custodian

34.6        Pentalpha SurveillanceLLC, as Operating Advisor

34.7        CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant

34.8        National Tax Search, LLC,as Servicing Function Participant

34.9        Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Nova Place Mortgage Loan (see Exhibit34.1)

34.10      C-III Asset ManagementLLC, as Special Servicer of the Nova Place Mortgage Loan (see Exhibit 34.2)

34.11      Wilmington Trust, National Association, as Trustee of the Nova Place MortgageLoan (Omitted. See Explanatory Notes.)

34.12      Wells Fargo Bank, NationalAssociation, as Custodian of the Nova Place Mortgage Loan (see Exhibit 34.5)

34.13      Pentalpha SurveillanceLLC, as Operating Advisor of the Nova Place Mortgage Loan (see Exhibit 34.6)

34.14      CoreLogic Commercial Real EstateServices, Inc., as Servicing Function Participant of the Nova Place MortgageLoan (see Exhibit 34.7)

34.15      National Tax Search, LLC,as Servicing Function Participant of the Nova Place Mortgage Loan (see Exhibit34.8)

34.16      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 450-460 Park Avenue South Mortgage Loan(see Exhibit 34.1)

34.17      C-III Asset ManagementLLC, as Special Servicer of the 450-460 Park Avenue South Mortgage Loan (seeExhibit 34.2)

34.18      Wilmington Trust, National Association, as Trustee of the 450-460 Park AvenueSouth Mortgage Loan (Omitted. See Explanatory Notes.)

34.19      Wells Fargo Bank, NationalAssociation, as Custodian of the 450-460 Park Avenue South Mortgage Loan (seeExhibit 34.5)

34.20      Pentalpha SurveillanceLLC, as Operating Advisor of the 450-460 Park Avenue South Mortgage Loan (seeExhibit 34.6)

34.21      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the 450-460 ParkAvenue South Mortgage Loan (see Exhibit 34.7)

34.22      National Tax Search, LLC,as Servicing Function Participant of the 450-460 Park Avenue South MortgageLoan (see Exhibit 34.8)

34.23      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the El Con Center Mortgage Loan (seeExhibit 34.1)

34.24      C-III Asset ManagementLLC, as Special Servicer of the El Con Center Mortgage Loan (see Exhibit 34.2)

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

34.26      Wells Fargo Bank, NationalAssociation, as Custodian of the El Con Center Mortgage Loan (see Exhibit 34.5)

34.27      Pentalpha SurveillanceLLC, as Operating Advisor of the El Con Center Mortgage Loan (see Exhibit 34.6)

34.28      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the El Con CenterMortgage Loan (see Exhibit 34.7)

34.29      National Tax Search, LLC,as Servicing Function Participant of the El Con Center Mortgage Loan (seeExhibit 34.8)

34.30      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Shetland Park Mortgage Loan (seeExhibit 34.1)

34.31      C-III Asset ManagementLLC, as Special Servicer of the Shetland Park Mortgage Loan (see Exhibit 34.2)

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

34.33      Wells Fargo Bank, NationalAssociation, as Custodian of the Shetland Park Mortgage Loan (see Exhibit 34.5)

34.34      Pentalpha SurveillanceLLC, as Operating Advisor of the Shetland Park Mortgage Loan (see Exhibit 34.6)

34.35      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Shetland ParkMortgage Loan (see Exhibit 34.7)

34.36      National Tax Search, LLC,as Servicing Function Participant of the Shetland Park Mortgage Loan (seeExhibit 34.8)

34.37      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the ExchangeRight Net Leased Portfolio #27Mortgage Loan (see Exhibit 34.1)

34.38      C-III Asset ManagementLLC, as Special Servicer of the ExchangeRight Net Leased Portfolio #27 MortgageLoan (see Exhibit 34.2)

34.39      Wilmington Trust, National Association, as Trustee of the ExchangeRight NetLeased Portfolio #27 Mortgage Loan (Omitted. See Explanatory Notes.)

34.40      Wells Fargo Bank, NationalAssociation, as Custodian of the ExchangeRight Net Leased Portfolio #27Mortgage Loan (see Exhibit 34.5)

34.41      Pentalpha SurveillanceLLC, as Operating Advisor of the ExchangeRight Net Leased Portfolio #27Mortgage Loan (see Exhibit 34.6)

34.42      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the ExchangeRightNet Leased Portfolio #27 Mortgage Loan (see Exhibit 34.7)

34.43      National Tax Search, LLC,as Servicing Function Participant of the ExchangeRight Net Leased Portfolio #27Mortgage Loan (see Exhibit 34.8)

34.44      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Hilton at University Place MortgageLoan (see Exhibit 34.1)

34.45      Rialto Capital Advisors,LLC, as Special Servicer of the Hilton at University Place Mortgage Loan

34.46      Wilmington Trust, National Association, as Trustee of the Hilton at UniversityPlace Mortgage Loan (Omitted. See Explanatory Notes.)

34.47      Wells Fargo Bank, NationalAssociation, as Custodian of the Hilton at University Place Mortgage Loan (seeExhibit 34.5)

34.48      Park Bridge LenderServices LLC, as Operating Advisor of the Hilton at University Place MortgageLoan

34.49      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Hilton atUniversity Place Mortgage Loan (see Exhibit 34.7)

34.50      National Tax Search, LLC,as Servicing Function Participant of the Hilton at University Place MortgageLoan (see Exhibit 34.8)

34.51      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the PatuxentCrossing Mortgage Loan

34.52      Midland Loan Services, a Divisionof PNC Bank, National Association, as Special Servicer of the Patuxent CrossingMortgage Loan (see Exhibit 34.51)

34.53      Wells Fargo Bank, National Association, as Trustee of the Patuxent CrossingMortgage Loan (Omitted. See Explanatory Notes.)

34.54      Wells Fargo Bank, NationalAssociation, as Custodian of the Patuxent Crossing Mortgage Loan (see Exhibit34.5)

34.55      Pentalpha SurveillanceLLC, as Operating Advisor of the Patuxent Crossing Mortgage Loan (see Exhibit34.6)

34.56      KeyBank National Association, as Primary Servicer of the Wolverine PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.57      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of theWolverine Portfolio Mortgage Loan (see Exhibit 34.51)

34.58      Wells Fargo Bank, National Association, as Trustee of the Wolverine PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.59      Wells Fargo Bank, NationalAssociation, as Custodian of the Wolverine Portfolio Mortgage Loan (see Exhibit34.5)

34.60      Pentalpha SurveillanceLLC, as Operating Advisor of the Wolverine Portfolio Mortgage Loan (see Exhibit34.6)

34.61      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the CIREEquity Retail & Industrial Portfolio Mortgage Loan (see Exhibit 34.51)

34.62      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the CIREEquity Retail & Industrial Portfolio Mortgage Loan (see Exhibit 34.51)

34.63      Wilmington Trust, National Association, as Trustee of the CIRE Equity Retail& Industrial Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.64      Citibank, N.A., as Custodian of the CIRE Equity Retail & IndustrialPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.65      Pentalpha SurveillanceLLC, as Operating Advisor of the CIRE Equity Retail & Industrial PortfolioMortgage Loan (see Exhibit 34.6)

34.66      U.S. Bank NationalAssociation, as Servicing Function Participant of the CIRE Equity Retail &Industrial Portfolio Mortgage Loan

34.67      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 188 Spear Street Mortgage Loan (seeExhibit 34.1)

34.68      Rialto Capital Advisors,LLC, as Special Servicer of the 188 Spear Street Mortgage Loan (see Exhibit34.45)

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

34.70      Wells Fargo Bank, NationalAssociation, as Custodian of the 188 Spear Street Mortgage Loan (see Exhibit34.5)

34.71      Park Bridge LenderServices LLC, as Operating Advisor of the 188 Spear Street Mortgage Loan (seeExhibit 34.48)

34.72      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the 188 SpearStreet Mortgage Loan (see Exhibit 34.7)

34.73      National Tax Search, LLC,as Servicing Function Participant of the 188 Spear Street Mortgage Loan (seeExhibit 34.8)

34.74      Wells Fargo Bank, NationalAssociation, as Primary Servicer of The Chantilly Office Portfolio MortgageLoan (see Exhibit 34.1)

34.75      Rialto Capital Advisors,LLC, as Special Servicer of The Chantilly Office Portfolio Mortgage Loan (seeExhibit 34.45)

34.76      Wilmington Trust, National Association, as Trustee of The Chantilly OfficePortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.77      Wells Fargo Bank, NationalAssociation, as Custodian of The Chantilly Office Portfolio Mortgage Loan (seeExhibit 34.5)

34.78      Pentalpha SurveillanceLLC, as Operating Advisor of The Chantilly Office Portfolio Mortgage Loan (seeExhibit 34.6)

34.79      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of The ChantillyOffice Portfolio Mortgage Loan (see Exhibit 34.7)

34.80      National Tax Search, LLC,as Servicing Function Participant of The Chantilly Office Portfolio MortgageLoan (see Exhibit 34.8)

35           Servicer compliance statements.

35.1        Wells Fargo Bank, NationalAssociation, as Master Servicer

35.2        C-III Asset ManagementLLC, as Special Servicer

35.3        Wells Fargo Bank, NationalAssociation, as Certificate Administrator

35.4        Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Nova Place Mortgage Loan (see Exhibit35.1)

35.5        C-III Asset ManagementLLC, as Special Servicer of the Nova Place Mortgage Loan (see Exhibit 35.2)

35.6        Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 450-460 Park Avenue South Mortgage Loan(see Exhibit 35.1)

35.7        C-III Asset ManagementLLC, as Special Servicer of the 450-460 Park Avenue South Mortgage Loan (seeExhibit 35.2)

35.8        Wells Fargo Bank, NationalAssociation, as Primary Servicer of the El Con Center Mortgage Loan (seeExhibit 35.1)

35.9        C-III Asset ManagementLLC, as Special Servicer of the El Con Center Mortgage Loan (see Exhibit 35.2)

35.10      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Shetland Park Mortgage Loan (seeExhibit 35.1)

35.11      C-III Asset ManagementLLC, as Special Servicer of the Shetland Park Mortgage Loan (see Exhibit 35.2)

35.12      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the ExchangeRight Net Leased Portfolio #27Mortgage Loan (see Exhibit 35.1)

35.13      C-III Asset Management LLC,as Special Servicer of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan(see Exhibit 35.2)

35.14      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Hilton at University Place MortgageLoan (see Exhibit 35.1)

35.15      Rialto Capital Advisors,LLC, as Special Servicer of the Hilton at University Place Mortgage Loan

35.16      Midland Loan Services, a Division of PNC Bank, National Association, as PrimaryServicer of the Patuxent Crossing Mortgage Loan (Omitted. See ExplanatoryNotes.)

35.17      Midland Loan Services, a Division of PNC Bank, National Association, as SpecialServicer of the Patuxent Crossing Mortgage Loan (Omitted. See ExplanatoryNotes.)

35.18      KeyBank National Association, as Primary Servicer of the Wolverine PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

35.19      Midland Loan Services, a Division of PNC Bank, National Association, as SpecialServicer of the Wolverine Portfolio Mortgage Loan (Omitted. See ExplanatoryNotes.)

35.20      Midland Loan Services, a Division of PNC Bank, National Association, as PrimaryServicer of the CIRE Equity Retail & Industrial Portfolio Mortgage Loan(Omitted. See Explanatory Notes.)

35.21      Midland Loan Services, a Division of PNC Bank, National Association, as SpecialServicer of the CIRE Equity Retail & Industrial Portfolio Mortgage Loan(Omitted. See Explanatory Notes.)

35.22      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 188 Spear Street Mortgage Loan (seeExhibit 35.1)

35.23      Rialto Capital Advisors,LLC, as Special Servicer of the 188 Spear Street Mortgage Loan (see Exhibit35.15)

35.24      Wells Fargo Bank, NationalAssociation, as Primary Servicer of The Chantilly Office Portfolio MortgageLoan (see Exhibit 35.1)

35.25      Rialto Capital Advisors,LLC, as Special Servicer of The Chantilly Office Portfolio Mortgage Loan (seeExhibit 35.15)

99.1        MortgageLoan Purchase Agreement, dated as of June 21, 2019, between Wells FargoCommercial Mortgage Securities, Inc. and Rialto Mortgage Finance, LLC (filed asExhibit 99.1 to the registrant’s Current Report on Form 8-K filed on July 11,2019 under Commission File No. 333-226486-06 and incorporated by referenceherein).

99.2        MortgageLoan Purchase Agreement, dated as of June 21, 2019, between Wells FargoCommercial Mortgage Securities, Inc. and Wells Fargo Bank, National Association(filed as Exhibit 99.2 to the registrant’s Current Report on Form 8-K filed onJuly 11, 2019 under Commission File No. 333-226486-06 and incorporated byreference herein).

99.3        MortgageLoan Purchase Agreement, dated and effective as of June 21, 2019, between WellsFargo Commercial Mortgage Securities, Inc. Barclays Capital Holdings Inc. andBarclays Capital Real Estate Inc. (filed as Exhibit 99.3 to the registrant’sCurrent Report on Form 8-K filed on July 11, 2019 under Commission File No.333-226486-06 and incorporated by reference herein).

99.4        MortgageLoan Purchase Agreement, dated as of June 21, 2019, between Wells FargoCommercial Mortgage Securities, Inc. and UBS AG, by and through its branchoffice at 1285 Avenue of the Americas, New York, New York (filed as Exhibit99.4 to the registrant’s Current Report on Form 8-K filed on July 11, 2019under Commission File No. 333-226486-06 and incorporated by reference herein).

99.5        MortgageLoan Purchase Agreement, dated as of June 21, 2019, between Wells FargoCommercial Mortgage Securities, Inc., C-III Capital Partners LLC and C-IIICommercial Mortgage LLC (filed as Exhibit 99.5 to the registrant’s CurrentReport on Form 8-K filed on July 11, 2019 under Commission File No.333-226486-06 and incorporated by reference herein).

99.6        AgreementBetween Note Holders, dated as of July 11, 2019, by and between Wells FargoBank, National Association, as Initial Note A-1 Holder, Wells Fargo Bank,National Association, as Initial Note A-2 Holder, and Wells Fargo Bank,National Association, as Initial Note A-3 Holder (filed as Exhibit 99.8 to theregistrant’s Current Report on Form 8-K filed on July 11, 2019 under CommissionFile No. 333-226486-06 and incorporated by reference herein).

99.7        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 99.9 to the registrant’s CurrentReport on Form 8-K/A filed on August 21, 2019 under Commission File No.333-226486-06 and incorporated by reference herein).

99.8        AgreementBetween Note Holders, dated as of July 11, 2019, by and between Wells FargoBank, National Association, as Initial Note A-1 Holder, and Wells Fargo Bank,National Association, as Initial Note A-2 Holder (filed as Exhibit 99.10 to theregistrant’s Current Report on Form 8-K filed on July 11, 2019 under CommissionFile No. 333-226486-06 and incorporated by reference herein).

99.9        Co-LenderAgreement, dated as of May 1, 2019, between Rialto Mortgage Finance, LLC, asNote A-1 Holder, and Rialto Mortgage Finance, LLC, as Note A-2 Holder (filed asExhibit 99.11 to the registrant’s Current Report on Form 8-K filed on July 11,2019 under Commission File No. 333-226486-06 and incorporated by referenceherein).

99.10      Co-LenderAgreement, dated as of May 1, 2019, between Rialto Mortgage Finance, LLC, asNote A-1 Holder, and Rialto Mortgage Finance, LLC, as Note A-2 Holder (filed asExhibit 99.12 to the registrant’s Current Report on Form 8-K filed on July 11,2019 under Commission File No. 333-226486-06 and incorporated by referenceherein).

99.11      AgreementBetween Note Holders, dated as of June 14, 2019, by and between BarclaysCapital Real Estate Inc., as Initial Note A-1 Holder, and Barclays Capital RealEstate Inc., as Initial Note A-2 Holder (filed as Exhibit 99.13 to theregistrant’s Current Report on Form 8-K filed on July 11, 2019 under CommissionFile No. 333-226486-06 and incorporated by reference herein).

99.12      AgreementBetween Note Holders, dated as of July 11, 2019, by and between UBS AG, by andthrough its branch office at 1285 Avenue of the Americas, New York, New York,as Initial Note A-1 Holder, Initial Note A-2 Holder and Initial Note A-3 Holder(filed as Exhibit 99.14 to the registrant’s Current Report on Form 8-K filed onJuly 11, 2019 under Commission File No. 333-226486-06 and incorporated byreference herein).

99.13      AgreementBetween Note Holders, dated as of July 11, 2019, by and between Deutsche BankAG, New York Branch, as Initial Note A-1 Holder, Deutsche Bank AG, New YorkBranch, as Initial Note A-2 Holder, Deutsche Bank AG, New York Branch, asInitial Note A-3 Holder, UBS AG, by and through its branch office at 1285Avenue of the Americas, New York, New York, as Initial Note A-4 Holder, UBS AG,by and through its branch office at 1285 Avenue of the Americas, New York, NewYork, as Initial Note A-5 Holder, and UBS AG, by and through its branch officeat 1285 Avenue of the Americas, New York, New York, as Initial Note A-6 Holder(filed as Exhibit 99.15 to the registrant’s Current Report on Form 8-K filed onJuly 11, 2019 under Commission File No. 333-226486-06 and incorporated byreference herein).

99.14      AgreementBetween Note Holders, dated as of April 4, 2019, by and between BarclaysCapital Real Estate Inc., as Initial Note A-1 Holder, and Barclays Capital RealEstate Inc., as Initial Note A-2 Holder (filed as Exhibit 99.16 to theregistrant’s Current Report on Form 8-K filed on July 11, 2019 under CommissionFile No. 333-226486-06 and incorporated by reference herein).

99.15      AgreementBetween Note Holders, dated as of April 24, 2019, by and between BarclaysCapital Real Estate Inc., as Initial Note A-1 Holder, and Barclays Capital RealEstate Inc., as Initial Note A-2 Holder (filed as Exhibit 99.17 to theregistrant’s Current Report on Form 8-K filed on July 11, 2019 under CommissionFile No. 333-226486-06 and incorporated by reference herein).

99.16      AgreementBetween Note Holders, dated as of May 14, 2019, by and between UBS AG, by andthrough its branch office at 1285 Avenue of the Americas, New York, New York,as Initial Note A-1 Holder, Initial Note A-2 Holder, Initial Note A-3 Holder,Initial Note A-4 Holder, Initial Note A-5 Holder, Initial Note A-6 Holder,Initial Note A-7 Holder, Initial Note A-8 Holder, Initial Note A-9 Holder andInitial Note A-10 Holder (filed as Exhibit 99.18 to the registrant’s CurrentReport on Form 8-K filed on July 11, 2019 under Commission File No.333-226486-06 and incorporated by reference herein).

(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 23, 2020