**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: 333-228375-01**

**Central Index Key Number of the issuing entity:0001774962**

**BANK 2019-BNK18**

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

** **

**Central Index Key Number of the depositor: 0001005007**

**Banc of America Merrill LynchCommercial Mortgage Inc.**

**(exact name of the depositor as specified in itscharter)**

** **

**Central Index Key Number of the sponsor: 0001102113**

**Bank of America, NationalAssociation**

**(exact name of the sponsor 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: 0001541557**

**Morgan Stanley Mortgage CapitalHoldings LLC**

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

** **

** **

**Central Index Key Number of the sponsor: 0001577313**

**National Cooperative Bank, N.A.**

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

** **

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

**the issuing entity)** | **38-4117273**

**38-4117274**

**38-7221292**

**(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:**

**(646) 855-3953**

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 accelerated filer       o                                                                                                 Acceleratedfiler                                  o

Non-acceleratedfiler         ⌧  (Do not check if a smaller reportingcompany)                        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 alldocuments and reports required to be filed by Section 12, 13 or 15(d) of theSecurities Exchange Act of 1934 subsequent to the distribution of securitiesunder a plan confirmed by a court.  oYes oNo

Not applicable.

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

Not applicable.

**DOCUMENTS INCORPORATED BY REFERENCE**

** **

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

Not applicable.

 

** **

**EXPLANATORY NOTES**

The Alhambra Mortgage Loan, the 350 BushStreet Mortgage Loan, the Ford Factory Mortgage Loan, the Newport CorporateCenter Mortgage Loan, the 9201 West Sunset Boulevard Mortgage Loan, the CentralTower Mortgage Loan and the Westin Atlanta Airport Mortgage Loan, whichconstituted approximately 9.6%, 9.6%, 9.2%, 7.1%, 6.8%, 6.1% and 4.4%, 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 Alhambra 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 350 Bush Street Mortgage Loanwhich is an asset of the issuing entity and two other *pari passu* loans,which are not assets of the issuing entity, (c) with respect to the FordFactory Mortgage Loan which is an asset of the issuing entity and one other *paripassu* loan, which is not an asset of the issuing entity, (d) with respectto the Newport Corporate Center Mortgage Loan which is an asset of the issuingentity and three other *pari passu* loans and ten subordinate companionloans, each of which are not assets of the issuing entity, (e) with respect tothe 9201 West Sunset Boulevard Mortgage Loan which is an asset of the issuingentity and one other *pari passu* loan, which is not an asset of theissuing entity, (f) with respect to the Central Tower Mortgage Loan which is anasset of the issuing entity and one other *pari passu* loan, which is notan asset of the issuing entity and (g) with respect to the Westin AtlantaAirport 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 Alhambra Mortgage Loan, the 350 Bush StreetMortgage Loan, the Ford Factory Mortgage Loan, the Newport Corporate CenterMortgage Loan, the 9201 West Sunset Boulevard Mortgage Loan, the Central TowerMortgage Loan and the Westin Atlanta Airport Mortgage Loan, are being servicedand administered pursuant to the Pooling and Servicing Agreement, which isincorporated by reference as Exhibit 4.1 to this Annual Report on Form 10-K. 

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the ILPT Hawaii Portfolio Mortgage Loan, whichconstituted approximately 3.9% of the asset pool of the issuing entity as ofits cut-off date.  The ILPT Hawaii Portfolio Mortgage Loan is an asset ofthe issuing entity and is part of a loan combination that includes the ILPTHawaii Portfolio Mortgage Loan and seventeen other *pari passu* loans,which are not assets of the issuing entity. A *pari passu* portion of theloan combination was securitized in the ILPT Trust 2019-SURF transaction (the “ILPT2019-SURF Transaction”). This loan combination, including the ILPT HawaiiPortfolio Mortgage Loan, is being serviced and administered pursuant to thetrust and servicing agreement for the ILPT 2019-SURF Transaction, which isincorporated by reference as Exhibit 4.2 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 Great Wolf Lodge Southern CaliforniaMortgage Loan, which constituted approximately 3.9% of the asset pool of theissuing entity as of its cut-off date.  The Great Wolf Lodge SouthernCalifornia Mortgage Loan is an asset of the issuing entity and is part of aloan combination that includes the Great Wolf Lodge Southern CaliforniaMortgage Loan and three other *pari passu* loans and one subordinatecompanion loan, which are not assets of the issuing entity. A *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 the GreatWolf Lodge Southern California Mortgage Loan, is being serviced andadministered pursuant to the pooling and servicing agreement for the WFCM2019-C50 Transaction, which is incorporated by reference as Exhibit 4.3 to thisAnnual Report on Form 10-K.

The master servicer of a poolingand servicing agreement or trust and servicing agreement also functions as theprimary servicer of the related mortgage loans serviced and administeredpursuant to such agreement unless a separate primary servicer is identifiedherein.  If this report does not identify a separate primary servicer, theservicer compliance statement provided by the master servicer under any suchagreement also encompasses its responsibilities as primary servicer of therelated mortgage loan or mortgage loans.

Wells Fargo Bank, NationalAssociation is the master servicer and certificate administrator of themortgage loans serviced under the Pooling and Servicing Agreement and theprimary servicer of the Great Wolf Lodge Southern California Mortgage Loan. Asa result, 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, theGreat Wolf Lodge Southern California Mortgage Loan and the ILPT HawaiiPortfolio Mortgage Loan.  As a result, Wells Fargo Bank, NationalAssociation 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 Wells Fargo Bank, National Association in the capacitiesdescribed above are listed in the Exhibit Index.

Rialto Capital Advisors, LLC isthe special servicer of the mortgage loans serviced under the Pooling andServicing Agreement, the Great Wolf Lodge Southern California Mortgage Loan andthe ILPT Hawaii Portfolio Mortgage Loan. As a result, Rialto Capital Advisors,LLC is a “servicer” as defined in Item 1108(a)(2)(iii) of Regulation AB, in thecapacities described above, because it is servicing mortgage loans that constituted10% or more of the assets of the issuing entity as of its cut-off date. Theassessments of compliance with applicable servicing criteria, accountants’attestation reports and servicer compliance statements delivered by RialtoCapital Advisors, LLC in the capacities described above are listed in theExhibit Index.

Park Bridge Lender Services LLC is the operating advisor ofthe Great Wolf Lodge Southern California Mortgage Loan and the ILPT HawaiiPortfolio Mortgage Loan.  As a result, Park Bridge Lender Services LLC isa servicing function participant in the capacities described above, because itis servicing mortgage loans that constituted 5% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria and accountants’ attestation reports delivered byPark Bridge Lender Services LLC in the capacities described above are listed inthe Exhibit Index.

Wilmington Trust, NationalAssociation acts as trustee of the mortgage loans serviced under the Poolingand Servicing Agreement and the Great Wolf Lodge Southern California MortgageLoan.  Pursuant to the Pooling and Servicing Agreement and the pooling andservicing agreement for the WFCM 2019-C50 Transaction, the trustee is requiredto provide an assessment of compliance with applicable servicing criteriasolely with respect to Item 1122(d)(2)(iii) of Regulation AB (regardingadvances of funds or guarantees regarding collections, cash flows ordistributions, and any interest or other fees charged for such advances, aremade, reviewed and approved as specified in the transaction agreements).However, during the reporting period, the trustee did not perform any servicingfunction with respect to the servicing criteria specified in Item1122(d)(2)(iii) of Regulation AB.  The master servicer or the specialservicer, to the extent required, performed the servicing function identifiedwith respect to Item 1122(d)(2)(iii) of Regulation AB, and each such party includedItem 1122(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 mortgage loans serviced underthe Pooling and Servicing Agreement and the Great Wolf Lodge SouthernCalifornia Mortgage Loan have delivered one or more assessments of compliancewith respect to Item 1122(d)(2)(iii) of Regulation AB.

Wells Fargo Bank, NationalAssociation acts as trustee of the ILPT Hawaii Portfolio Mortgage Loan. Pursuant to the trust and servicing agreement for the ILPT 2019-SURFTransaction, 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 criteria specifiedin Item 1122(d)(2)(iii) of Regulation AB.  The master servicer or thespecial servicer, to the extent required, performed the servicing functionidentified with respect to Item 1122(d)(2)(iii) of Regulation AB, and each suchparty 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 ILPTHawaii Portfolio Mortgage Loan have delivered one or more assessments ofcompliance with respect to Item 1122(d)(2)(iii) of Regulation AB.

This Annual Report on Form 10-Kincludes assessments of compliance with applicable servicing criteria andaccountants’ attestation reports from CoreLogic 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 Great Wolf Lodge Southern California Mortgage Loan toremit tax payments received from the escrow accounts of borrowers to localtaxing authorities, to report tax amounts due, to verify tax parcelinformation, and to verify non-escrow tax payments. These servicing functionsare included within the servicing criteria set forth in Items 1122(d)(4)(xi)and 1122(d)(4)(xii) of Regulation AB.  Therefore, under theprinciples-based definition of “servicer” set forth in Item 1101(j) ofRegulation AB that looks to the functions that an entity performs, thesevendors are “servicers” for the purposes of Item 1122 of Regulation AB.  *See*Compliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

Theassessments of compliance with applicable servicing criteria, accountants’attestation reports and servicer compliance statements of the certificateadministrator of the ILPT Hawaii Portfolio Mortgage Loan and the Great WolfLodge Southern California Mortgage Loan listed on the Exhibit Index are omittedfrom this Annual Report on Form 10-K as the certificate administrator pursuantto the related pooling and servicing agreement or trust and servicing agreementdoes not perform any activities that address servicing criteria with respect tothe issuing entity and because they are each not a “servicer” that meets thecriteria in Item 1108(a)(2)(i) through (iii) of Regulation AB.

With respect to the *pari passu*loan combinations that include the ILPT Hawaii Portfolio Mortgage Loan and theNewport Corporate Center Mortgage Loan, (i) the report on assessment ofcompliance with servicing criteria and attestation report on assessment ofcompliance with servicing criteria of Midland Loan Services, a Division of PNCBank, National Association as primary servicer of the ILPT Hawaii PortfolioMortgage Loan, listed on the Exhibit Index are omitted from this Annual Reporton Form 10-K as they are not required to be included on this Annual Report onForm 10-K per Instruction 3 to Item 1122 of Regulation AB because they areparties performing activities that address servicing criteria relating to 5% orless of the assets of the issuing entity; and (ii) the servicer compliancestatements of Midland Loan Services, a Division of PNC Bank, NationalAssociation as primary servicer of the ILPT Hawaii Portfolio Mortgage Loan andSitus Holdings, LLC as special servicer of the Newport Corporate CenterMortgage Loan, listed on the Exhibit Index are omitted from this Annual Report onForm 10-K as they are not required by Item 1123 of Regulation AB to be includedon this Annual Report on Form 10-K because they are each an unaffiliated partythat is not a “servicer” that meets the criteria in Item 1108(a)(2)(i) through(iii) of Regulation AB.

 

**PART I**

**Item 1.  Business.**

Omitted.

**Item 1A.  Risk Factors.**

Omitted.

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

None.

**Item 2.  Properties.**

Omitted.

**Item 3.  Legal Proceedings.**

Omitted.

**Item 4.  Mine Safety Disclosures.**

Not applicable.

**PART II**

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

Omitted.

**Item 6.  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 creditenhancement or other support for the certificates within this transaction asdescribed under Item 1114(a) of Regulation AB.

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

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

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

The registrant knows of no material pending legal proceedinginvolving the trust or any party related to the trust, other than routinelitigation incidental to the duties of those respective parties, and thefollowing, with respect to Wells Fargo Bank, National Association, as trustee,as certificate administrator and as custodian.

Beginning on June 18, 2014, a group of institutionalinvestors filed civil complaints in the Supreme Court of the State of New York,New York County, and later the U.S. District Court for the Southern District ofNew York, against Wells Fargo Bank, N.A., (“Wells Fargo Bank”) in itscapacity as trustee for certain residential mortgage backed securities (“RMBS”)trusts.  The complaints against Wells Fargo Bank alleged that the trusteecaused losses to investors and asserted causes of action based upon, amongother things, the trustee's alleged failure to: (i) notify and enforcerepurchase obligations of mortgage loan sellers for purported breaches ofrepresentations and warranties, (ii) notify investors of alleged events ofdefault, and (iii) abide by appropriate standards of care following allegedevents of default. Relief sought included money damages in an unspecifiedamount, reimbursement of expenses, and equitable relief. In November 2018,Wells Fargo Bank reached an agreement, in which it denied any wrongdoing, toresolve such claims on a classwide basis for the 271 RMBS trusts atissue.  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 believesplaintiffs' claims are without merit and intends to contest the claimsvigorously, but there can be no assurances as to the outcome of the litigationsor the possible impact of the litigations on Wells Fargo Bank or the RMBStrusts.

**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 May 31, 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 such assessmentsof compliance with respect to the mortgage loans are attached hereto under Item15 to this Annual Report on Form 10-K. Attached as Exhibit Z to the Pooling andServicing Agreement incorporated by reference as Exhibit 4.1 to this AnnualReport on Form 10-K is a chart identifying the entities participating in aservicing function for the transaction responsible for each applicableservicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the ILPT Hawaii Portfolio MortgageLoan, which is being serviced and administered pursuant to the trust andservicing agreement for the ILPT 2019-SURF Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit L to thetrust and servicing agreement for the ILPT 2019-SURF 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 ILPT2019-SURF 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 Great Wolf Lodge SouthernCalifornia Mortgage Loan, which is being serviced and administered pursuant tothe pooling and servicing agreement for the WFCM 2019-C50 Transaction, areattached hereto under Item 15 to this Annual Report on Form 10-K. Attached asExhibit AA to the pooling and servicing agreement for the WFCM 2019-C50Transaction incorporated by reference as Exhibit 4.3 to this Annual Report onForm 10-K is a chart identifying the entities participating in a servicingfunction for the WFCM 2019-C50 Transaction responsible for each applicableservicing criteria set forth 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. 

Report on Assessment of Compliance with Applicable ServicingCriteria Not Included

For the reasons discussed in theExplanatory Notes above, Midland is not a party performing activities thataddress servicing criteria relating to 5% or more of the assets of the issuingentity.  Therefore, the report of assessment of compliance with applicableservicing criteria for Midland has not been included as an exhibit to thisAnnual Report on Form 10-K.

**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 May 1, 2019, by and among Banc of AmericaMerrill Lynch Commercial Mortgage Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as General Master Servicer, Rialto Capital Advisors, LLC, asGeneral Special Servicer, National Cooperative Bank, N.A., as NCB MasterServicer and as NCB Special Servicer, Situs Holdings, LLC, as Newport CorporateSpecial Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator, Wilmington Trust, National Association, as Trustee , andPentalpha Surveillance LLC, as Operating Advisor and Asset RepresentationsReviewer (filed as Exhibit 4.1 to the registrant’s Current Report on Form 8-Kfiled on May 31, 2019 under Commission File No. 333-228375-01 and incorporatedby reference herein). 

4.2         Trustand Servicing Agreement, dated as of March 7, 2019, by and among Morgan StanleyCapital I Inc., as Depositor, Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer, Rialto Capital Advisors, LLC, asSpecial Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator, Certificate Registrar, Authenticating Agent and Custodian, WellsFargo Bank, National Association, as Trustee, and Park Bridge Lender ServicesLLC, as Operating Advisor (filed as Exhibit 4.2 to the registrant’s CurrentReport on Form 8-K filed on May 31, 2019 under Commission File No.333-228375-01 and incorporated by reference herein).

4.3         Poolingand Servicing Agreement, dated as of May 1, 2019, by and among 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 Administratorand Custodian, Wilmington Trust, National Association, as Trustee , and ParkBridge Lender Services LLC, as Operating Advisor and Asset RepresentationsReviewer (filed as Exhibit 4.3 to the registrant’s Current Report on Form 8-Kfiled on May 31, 2019 under Commission File No. 333-228375-01 and incorporatedby reference herein).

4.4         AgreementBetween Note Holders, dated as of May 31, 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 4.4 to theregistrant’s Current Report on Form 8-K filed on May 31, 2019 under CommissionFile No. 333-228375-01 and incorporated by reference herein).

4.5         AgreementBetween Note Holders, dated as of May 31, 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 4.5 to theregistrant’s Current Report on Form 8-K filed on May 31, 2019 under CommissionFile No. 333-228375-01 and incorporated by reference herein).

4.6         AgreementBetween Note Holders, dated as of March 29, 2019, by and between Bank ofAmerica, N.A., as Initial Note A-1 Holder, and Bank of America, N.A., asInitial Note A-2 Holder (filed as Exhibit 4.6 to the registrant’s CurrentReport on Form 8-K filed on May 31, 2019 under Commission File No.333-228375-01 and incorporated by reference herein).

4.7         AgreementBetween Note Holders, dated as of May 16, 2019, by and between Deutsche BankAG, New York Branch, as Initial Note A-1-A Holder, Initial Note A-1-B Holder,Initial Note A-1-C Holder, Initial Note B-1-A Holder, Initial Note B-1-BHolder, Initial Note C-1-A Holder, Initial Note C-1-B Holder and Initial NoteD-1 Holder, and Wells Fargo Bank, National Association, Initial Note A-2-AHolder, Initial Note A-2-B Holder, Initial Note A-2-C Holder, Initial NoteB-2-A Holder, Initial Note B-2-B Holder, Initial Note C-2-A Holder, InitialNote C-2-B Holder and Initial Note D-2 Holder (filed as Exhibit 4.7 to theregistrant’s Current Report on Form 8-K filed on May 31, 2019 under CommissionFile No. 333-228375-01 and incorporated by reference herein).

4.8         AgreementBetween Note Holders, dated as of May 31, 2019, by and between Morgan StanleyBank, N.A., as Initial Note A-1 Holder, and Morgan Stanley Bank, N.A., asInitial Note A-2 Holder (filed as Exhibit 4.8 to the registrant’s CurrentReport on Form 8-K filed on May 31, 2019 under Commission File No.333-228375-01 and incorporated by reference herein).

4.9         AgreementBetween Note Holders, dated as of April 26, 2019, by and between Morgan StanleyBank, N.A., as Initial Note A-1 Holder, and Deutsche Bank AG, New York Branch,as Initial Note A-2 Holder (filed as Exhibit 4.9 to the registrant’s CurrentReport on Form 8-K filed on May 31, 2019 under Commission File No.333-228375-01 and incorporated by reference herein).

4.10       AgreementBetween Note Holders, dated as of May 31, 2019, by and between Morgan StanleyBank, N.A., as Initial Note A-1-A Holder, Morgan Stanley Bank, N.A., as InitialNote A-1-B Holder, and Morgan Stanley Bank, N.A., as Initial Note A-2 Holder(filed as Exhibit 4.10 to the registrant’s Current Report on Form 8-K/A filedon February 25, 2020 under Commission File No. 333-228375-01 and incorporatedby reference herein).

4.11       AgreementBetween Note Holders, dated as of March 7, 2019, by and between Morgan StanleyBank, N.A., as Initial Note A-1 Holder, Initial Note A-5-1 Holder, Initial NoteA-5-2 Holder, Initial Note A-5-3 Holder and Initial Note A-5-4 Holder, CitiReal Estate Funding Inc., as Initial Note A-2 Holder, Initial Note A-6-1Holder, Initial Note A-6-2 Holder and Initial Note A-6-3 Holder, UBS AG, NewYork Branch, as Initial Note A-3 Holder, Initial Note A-7-1 Holder, InitialNote A-7-2 Holder, Initial Note A-9 Holder, Initial Note A-10 Holder andInitial Note A-11 Holder, and JPMorgan Chase Bank, National Association,Initial Note A-4 Holder, Initial Note A-8-1 Holder and Initial Note A-8-2Holder (filed as Exhibit 4.11 to the registrant’s Current Report on Form 8-Kfiled on May 31, 2019 under Commission File No. 333-228375-01 and incorporatedby reference herein).

4.12       Amendedand Restated Co-Lender Agreement, dated as of March 15, 2019, by and betweenWells Fargo Bank, National Association, as Initial Note A-1 Holder, Wells FargoBank, National Association, as Initial Note A-2 Holder, Wells Fargo Bank,National Association, as Initial Note A-3 Holder, Column Financial, Inc., asInitial Note A-4 Holder, Wells Fargo Bank, National Association, as InitialNote A-5 Holder, and KSL Capital Partners Co Trust II, as Initial Note B-1Holder (filed as Exhibit 4.12 to the registrant’s Current Report on Form 8-Kfiled on May 31, 2019 under Commission File No. 333-228375-01 and incorporatedby 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 General Master Servicer

33.2       National Cooperative Bank,N.A., as NCB Master Servicer

33.3       Rialto Capital Advisors,LLC, as General Special Servicer

33.4       National Cooperative Bank,N.A., as NCB Special Servicer (see Exhibit 33.2)

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

33.6       Wells Fargo Bank, NationalAssociation, as Certificate Administrator

33.7       Wells Fargo Bank, NationalAssociation, as Custodian

33.8       Pentalpha SurveillanceLLC, as Operating Advisor

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

33.10     National Tax Search, LLC,as Servicing Function Participant

33.11     Wells Fargo Bank, NationalAssociation, as Primary Servicer of The Alhambra Mortgage Loan (see Exhibit33.1)

33.12     Rialto Capital Advisors,LLC, as Special Servicer of The Alhambra Mortgage Loan (see Exhibit 33.3)

33.13     Wilmington Trust, National Association, as Trustee of The Alhambra MortgageLoan (Omitted. See Explanatory Notes.)

33.14     Wells Fargo Bank, NationalAssociation, as Custodian of The Alhambra Mortgage Loan (see Exhibit 33.7)

33.15     Pentalpha SurveillanceLLC, as Operating Advisor of The Alhambra Mortgage Loan (see Exhibit 33.8)

33.16     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of The AlhambraMortgage Loan (see Exhibit 33.9)

33.17     National Tax Search, LLC,as Servicing Function Participant of The Alhambra Mortgage Loan (see Exhibit33.10)

33.18     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 350 Bush Street Mortgage Loan (seeExhibit 33.1)

33.19     Rialto Capital Advisors,LLC, as Special Servicer of the 350 Bush Street Mortgage Loan (see Exhibit33.3)

33.20     Wilmington Trust, National Association, as Trustee of the 350 Bush StreetMortgage Loan (Omitted. See Explanatory Notes.)

33.21     Wells Fargo Bank, NationalAssociation, as Custodian of the 350 Bush Street Mortgage Loan (see Exhibit33.7)

33.22     Pentalpha SurveillanceLLC, as Operating Advisor of the 350 Bush Street Mortgage Loan (see Exhibit33.8)

33.23     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the 350 Bush StreetMortgage Loan (see Exhibit 33.9)

33.24     National Tax Search, LLC,as Servicing Function Participant of the 350 Bush Street Mortgage Loan (seeExhibit 33.10)

33.25     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Ford Factory Mortgage Loan (see Exhibit33.1)

33.26     Rialto Capital Advisors,LLC, as Special Servicer of the Ford Factory Mortgage Loan (see Exhibit 33.3)

33.27     Wilmington Trust, National Association, as Trustee of the Ford Factory MortgageLoan (Omitted. See Explanatory Notes.)

33.28     Wells Fargo Bank, NationalAssociation, as Custodian of the Ford Factory Mortgage Loan (see Exhibit 33.7)

33.29     Pentalpha SurveillanceLLC, as Operating Advisor of the Ford Factory Mortgage Loan (see Exhibit 33.8)

33.30     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Ford FactoryMortgage Loan (see Exhibit 33.9)

33.31     National Tax Search, LLC,as Servicing Function Participant of the Ford Factory Mortgage Loan (seeExhibit 33.10)

33.32     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Newport Corporate Center Mortgage Loan(see Exhibit 33.1)

33.33     Situs Holdings, LLC, asSpecial Servicer of the Newport Corporate Center Mortgage Loan

33.34     Wilmington Trust, National Association, as Trustee of the Newport CorporateCenter Mortgage Loan (Omitted. See Explanatory Notes.)

33.35     Wells Fargo Bank, NationalAssociation, as Custodian of the Newport Corporate Center Mortgage Loan (seeExhibit 33.7)

33.36     Pentalpha SurveillanceLLC, as Operating Advisor of the Newport Corporate Center Mortgage Loan (seeExhibit 33.8)

33.37     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the NewportCorporate Center Mortgage Loan (see Exhibit 33.9)

33.38     National Tax Search, LLC,as Servicing Function Participant of the Newport Corporate Center Mortgage Loan(see Exhibit 33.10)

33.39     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 9201 West Sunset Boulevard MortgageLoan (see Exhibit 33.1)

33.40     Rialto Capital Advisors,LLC, as Special Servicer of the 9201 West Sunset Boulevard Mortgage Loan (seeExhibit 33.3)

33.41     Wilmington Trust, National Association, as Trustee of the 9201 West SunsetBoulevard Mortgage Loan (Omitted. See Explanatory Notes.)

33.42     Wells Fargo Bank, NationalAssociation, as Custodian of the 9201 West Sunset Boulevard Mortgage Loan (seeExhibit 33.7)

33.43     Pentalpha SurveillanceLLC, as Operating Advisor of the 9201 West Sunset Boulevard Mortgage Loan (seeExhibit 33.8)

33.44     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the 9201 WestSunset Boulevard Mortgage Loan (see Exhibit 33.9)

33.45     National Tax Search, LLC,as Servicing Function Participant of the 9201 West Sunset Boulevard MortgageLoan (see Exhibit 33.10)

33.46     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Central Tower Mortgage Loan (seeExhibit 33.1)

33.47     Rialto Capital Advisors,as Special Servicer of the Central Tower Mortgage Loan (see Exhibit 33.3)

33.48     Wilmington Trust, National Association, as Trustee of the Central TowerMortgage Loan (Omitted. See Explanatory Notes.)

33.49     Wells Fargo Bank, NationalAssociation, as Custodian of the Central Tower Mortgage Loan (see Exhibit 33.7)

33.50     Pentalpha SurveillanceLLC, as Operating Advisor of the Central Tower Mortgage Loan (see Exhibit 33.8)

33.51     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Central TowerMortgage Loan (see Exhibit 33.9)

33.52     National Tax Search, LLC,as Servicing Function Participant of the Central Tower Mortgage Loan (seeExhibit 33.10)

33.53     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Westin Atlanta Airport Mortgage Loan(see Exhibit 33.1)

33.54     Rialto Capital Advisors,LLC, as Special Servicer of the Westin Atlanta Airport Mortgage Loan (seeExhibit 33.3)

33.55     Wilmington Trust, National Association, as Trustee of the Westin AtlantaAirport Mortgage Loan (Omitted. See Explanatory Notes.)

33.56     Wells Fargo Bank, NationalAssociation, as Custodian of the Westin Atlanta Airport Mortgage Loan (seeExhibit 33.7)

33.57     Pentalpha SurveillanceLLC, as Operating Advisor of the Westin Atlanta Airport Mortgage Loan (seeExhibit 33.8)

33.58     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Westin AtlantaAirport Mortgage Loan (see Exhibit 33.9)

33.59     National Tax Search, LLC,as Servicing Function Participant of the Westin Atlanta Airport Mortgage Loan(see Exhibit 33.10)

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

33.61     Rialto Capital Advisors,LLC, as Special Servicer of the ILPT Hawaii Portfolio Mortgage Loan (seeExhibit 33.3)

33.62     Wells Fargo Bank, National Association, as Trustee of the ILPT Hawaii PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.63     Wells Fargo Bank, NationalAssociation, as Custodian of the ILPT Hawaii Portfolio Mortgage Loan (seeExhibit 33.7)

33.64     Park Bridge LenderServices LLC, as Operating Advisor of the ILPT Hawaii Portfolio Mortgage Loan

33.65     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Great Wolf Lodge Southern CaliforniaMortgage Loan (see Exhibit 33.1)

33.66     Rialto Capital Advisors,LLC, as Special Servicer of the Great Wolf Lodge Southern California MortgageLoan (see Exhibit 33.3)

33.67     Wilmington Trust, National Association, as Trustee of the Great Wolf LodgeSouthern California Mortgage Loan (Omitted. See Explanatory Notes.)

33.68     Wells Fargo Bank, NationalAssociation, as Custodian of the Great Wolf Lodge Southern California MortgageLoan (see Exhibit 33.7)

33.69     Park Bridge LenderServices LLC, as Operating Advisor of the Great Wolf Lodge Southern CaliforniaMortgage Loan (see Exhibit 33.64)

33.70     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Great WolfLodge Southern California Mortgage Loan (see Exhibit 33.9)

33.71     National Tax Search, LLC,as Servicing Function Participant of the Great Wolf Lodge Southern CaliforniaMortgage Loan (see Exhibit 33.10)

34          Attestation reports onassessment of compliance with servicing criteria for asset-backed securities.

34.1       Wells Fargo Bank, NationalAssociation, as General Master Servicer

34.2       National Cooperative Bank,N.A., as NCB Master Servicer

34.3       Rialto Capital Advisors,LLC, as General Special Servicer

34.4       National Cooperative Bank,N.A., as NCB Special Servicer (see Exhibit 34.2)

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

34.6       Wells Fargo Bank, NationalAssociation, as Certificate Administrator

34.7       Wells Fargo Bank, NationalAssociation, as Custodian

34.8       Pentalpha SurveillanceLLC, as Operating Advisor

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

34.10     National Tax Search, LLC,as Servicing Function Participant

34.11     Wells Fargo Bank, NationalAssociation, as Primary Servicer of The Alhambra Mortgage Loan (see Exhibit34.1)

34.12     Rialto Capital Advisors,LLC, as Special Servicer of The Alhambra Mortgage Loan (see Exhibit 34.3)

34.13     Wilmington Trust, National Association, as Trustee of The Alhambra MortgageLoan (Omitted. See Explanatory Notes.)

34.14     Wells Fargo Bank, NationalAssociation, as Custodian of The Alhambra Mortgage Loan (see Exhibit 34.7)

34.15     Pentalpha SurveillanceLLC, as Operating Advisor of The Alhambra Mortgage Loan (see Exhibit 34.8)

34.16     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of The AlhambraMortgage Loan (see Exhibit 34.9)

34.17     National Tax Search, LLC,as Servicing Function Participant of The Alhambra Mortgage Loan (see Exhibit34.10)

34.18     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 350 Bush Street Mortgage Loan (seeExhibit 34.1)

34.19     Rialto Capital Advisors,LLC, as Special Servicer of the 350 Bush Street Mortgage Loan (see Exhibit34.3)

34.20     Wilmington Trust, National Association, as Trustee of the 350 Bush StreetMortgage Loan (Omitted. See Explanatory Notes.)

34.21     Wells Fargo Bank, NationalAssociation, as Custodian of the 350 Bush Street Mortgage Loan (see Exhibit34.7)

34.22     Pentalpha SurveillanceLLC, as Operating Advisor of the 350 Bush Street Mortgage Loan (see Exhibit34.8)

34.23     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the 350 Bush StreetMortgage Loan (see Exhibit 34.9)

34.24     National Tax Search, LLC,as Servicing Function Participant of the 350 Bush Street Mortgage Loan (seeExhibit 34.10)

34.25     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Ford Factory Mortgage Loan (see Exhibit34.1)

34.26     Rialto Capital Advisors,LLC, as Special Servicer of the Ford Factory Mortgage Loan (see Exhibit 34.3)

34.27     Wilmington Trust, National Association, as Trustee of the Ford Factory MortgageLoan (Omitted. See Explanatory Notes.)

34.28     Wells Fargo Bank, NationalAssociation, as Custodian of the Ford Factory Mortgage Loan (see Exhibit 34.7)

34.29     Pentalpha SurveillanceLLC, as Operating Advisor of the Ford Factory Mortgage Loan (see Exhibit 34.8)

34.30     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Ford FactoryMortgage Loan (see Exhibit 34.9)

34.31     National Tax Search, LLC,as Servicing Function Participant of the Ford Factory Mortgage Loan (seeExhibit 34.10)

34.32     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Newport Corporate Center Mortgage Loan(see Exhibit 34.1)

34.33     Situs Holdings, LLC, asSpecial Servicer of the Newport Corporate Center Mortgage Loan

34.34     Wilmington Trust, National Association, as Trustee of the Newport CorporateCenter Mortgage Loan (Omitted. See Explanatory Notes.)

34.35     Wells Fargo Bank, NationalAssociation, as Custodian of the Newport Corporate Center Mortgage Loan (seeExhibit 34.7)

34.36     Pentalpha SurveillanceLLC, as Operating Advisor of the Newport Corporate Center Mortgage Loan (seeExhibit 34.8)

34.37     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the NewportCorporate Center Mortgage Loan (see Exhibit 34.9)

34.38     National Tax Search, LLC,as Servicing Function Participant of the Newport Corporate Center Mortgage Loan(see Exhibit 34.10)

34.39     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 9201 West Sunset Boulevard MortgageLoan (see Exhibit 34.1)

34.40     Rialto Capital Advisors,LLC, as Special Servicer of the 9201 West Sunset Boulevard Mortgage Loan (seeExhibit 34.3)

34.41     Wilmington Trust, National Association, as Trustee of the 9201 West SunsetBoulevard Mortgage Loan (Omitted. See Explanatory Notes.)

34.42     Wells Fargo Bank, NationalAssociation, as Custodian of the 9201 West Sunset Boulevard Mortgage Loan (seeExhibit 34.7)

34.43     Pentalpha SurveillanceLLC, as Operating Advisor of the 9201 West Sunset Boulevard Mortgage Loan (seeExhibit 34.8)

34.44     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the 9201 WestSunset Boulevard Mortgage Loan (see Exhibit 34.9)

34.45     National Tax Search, LLC,as Servicing Function Participant of the 9201 West Sunset Boulevard MortgageLoan (see Exhibit 34.10)

34.46     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Central Tower Mortgage Loan (seeExhibit 34.1)

34.47     Rialto Capital Advisors,as Special Servicer of the Central Tower Mortgage Loan (see Exhibit 34.3)

34.48     Wilmington Trust, National Association, as Trustee of the Central TowerMortgage Loan (Omitted. See Explanatory Notes.)

34.49     Wells Fargo Bank, NationalAssociation, as Custodian of the Central Tower Mortgage Loan (see Exhibit 34.7)

34.50     Pentalpha SurveillanceLLC, as Operating Advisor of the Central Tower Mortgage Loan (see Exhibit 34.8)

34.51     CoreLogic Commercial Real EstateServices, Inc., as Servicing Function Participant of the Central Tower MortgageLoan (see Exhibit 34.9)

34.52     National Tax Search, LLC,as Servicing Function Participant of the Central Tower Mortgage Loan (seeExhibit 34.10)

34.53     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Westin Atlanta Airport Mortgage Loan(see Exhibit 34.1)

34.54     Rialto Capital Advisors,LLC, as Special Servicer of the Westin Atlanta Airport Mortgage Loan (seeExhibit 34.3)

34.55     Wilmington Trust, National Association, as Trustee of the Westin AtlantaAirport Mortgage Loan (Omitted. See Explanatory Notes.)

34.56     Wells Fargo Bank, NationalAssociation, as Custodian of the Westin Atlanta Airport Mortgage Loan (seeExhibit 34.7)

34.57     Pentalpha SurveillanceLLC, as Operating Advisor of the Westin Atlanta Airport Mortgage Loan (seeExhibit 34.8)

34.58     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Westin AtlantaAirport Mortgage Loan (see Exhibit 34.9)

34.59     National Tax Search, LLC,as Servicing Function Participant of the Westin Atlanta Airport Mortgage Loan(see Exhibit 34.10)

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

34.61     Rialto Capital Advisors,LLC, as Special Servicer of the ILPT Hawaii Portfolio Mortgage Loan (seeExhibit 34.3)

34.62     Wells Fargo Bank, National Association, as Trustee of the ILPT Hawaii PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.63     Wells Fargo Bank, NationalAssociation, as Custodian of the ILPT Hawaii Portfolio Mortgage Loan (seeExhibit 34.7)

34.64     Park Bridge LenderServices LLC, as Operating Advisor of the ILPT Hawaii Portfolio Mortgage Loan

34.65     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Great Wolf Lodge Southern CaliforniaMortgage Loan (see Exhibit 34.1)

34.66     Rialto Capital Advisors,LLC, as Special Servicer of the Great Wolf Lodge Southern California MortgageLoan (see Exhibit 34.3)

34.67     Wilmington Trust, National Association, as Trustee of the Great Wolf LodgeSouthern California Mortgage Loan (Omitted. See Explanatory Notes.)

34.68     Wells Fargo Bank, NationalAssociation, as Custodian of the Great Wolf Lodge Southern California MortgageLoan (see Exhibit 34.7)

34.69     Park Bridge LenderServices LLC, as Operating Advisor of the Great Wolf Lodge Southern CaliforniaMortgage Loan (see Exhibit 34.64)

34.70     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Great WolfLodge Southern California Mortgage Loan (see Exhibit 34.9)

34.71     National Tax Search, LLC,as Servicing Function Participant of the Great Wolf Lodge Southern CaliforniaMortgage Loan (see Exhibit 34.10)

35          Servicer compliance statements.

35.1       Wells Fargo Bank, NationalAssociation, as General Master Servicer

35.2       National Cooperative Bank,N.A., as NCB Master Servicer

35.3       Rialto Capital Advisors,LLC, as General Special Servicer

35.4       National Cooperative Bank,N.A., as NCB Special Servicer (see Exhibit 35.2)

35.5       Wells Fargo Bank, NationalAssociation, as Certificate Administrator

35.6       Wells Fargo Bank, NationalAssociation, as Primary Servicer of The Alhambra Mortgage Loan (see Exhibit35.1)

35.7       Rialto Capital Advisors,LLC, as Special Servicer of The Alhambra Mortgage Loan (see Exhibit 35.3)

35.8       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 350 Bush Street Mortgage Loan (seeExhibit 35.1)

35.9       Rialto Capital Advisors, LLC,as Special Servicer of the 350 Bush Street Mortgage Loan (see Exhibit 35.3)

35.10     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Ford Factory Mortgage Loan (see Exhibit35.1)

35.11     Rialto Capital Advisors,LLC, as Special Servicer of the Ford Factory Mortgage Loan (see Exhibit 35.3)

35.12     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Newport Corporate Center Mortgage Loan(see Exhibit 35.1)

35.13     Situs Holdings, LLC, as Special Servicer of the Newport Corporate CenterMortgage Loan (Omitted. See Explanatory Notes.)

35.14     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 9201 West Sunset Boulevard MortgageLoan (see Exhibit 35.1)

35.15     Rialto Capital Advisors,LLC, as Special Servicer of the 9201 West Sunset Boulevard Mortgage Loan (seeExhibit 35.3)

35.16     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Central Tower Mortgage Loan (seeExhibit 35.1)

35.17     Rialto Capital Advisors,as Special Servicer of the Central Tower Mortgage Loan (see Exhibit 35.3)

35.18     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Westin Atlanta Airport Mortgage Loan(see Exhibit 35.1)

35.19     Rialto Capital Advisors,LLC, as Special Servicer of the Westin Atlanta Airport Mortgage Loan (seeExhibit 35.3)

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

35.21     Rialto Capital Advisors,LLC, as Special Servicer of the ILPT Hawaii Portfolio Mortgage Loan (seeExhibit 35.3)

35.22     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Great Wolf Lodge Southern CaliforniaMortgage Loan (see Exhibit 35.1)

35.23     Rialto Capital Advisors,LLC, as Special Servicer of the Great Wolf Lodge Southern California MortgageLoan (see Exhibit 35.3)

99.1       MortgageLoan Purchase Agreement, dated as of May 21, 2019, between Banc of AmericaMerrill Lynch Commercial Mortgage Inc. and Bank of America, NationalAssociation (filed as Exhibit 99.3 to the registrant’s Current Report on Form8-K filed on May 31, 2019 under Commission File No. 333-228375-01 andincorporated by reference herein)

99.2       MortgageLoan Purchase Agreement, dated as of May 21, 2019, between Banc of AmericaMerrill Lynch Commercial Mortgage Inc. and Wells Fargo Bank, NationalAssociation (filed as Exhibit 99.1 to the registrant’s Current Report on Form8-K filed on May 31, 2019 under Commission File No. 333-228375-01 andincorporated by reference herein)

99.3       MortgageLoan Purchase Agreement, dated as of May 21, 2019, between Banc of AmericaMerrill Lynch Commercial Mortgage Inc. and Morgan Stanley Mortgage CapitalHoldings LLC (filed as Exhibit 99.2 to the registrant’s Current Report on Form8-K filed on May 31, 2019 under Commission File No. 333-228375-01 andincorporated by reference herein)

99.4       MortgageLoan Purchase Agreement, dated as of May 21, 2019, between Banc of AmericaMerrill Lynch Commercial Mortgage Inc. and National Cooperative Bank, N.A.(filed as Exhibit 99.4 to the registrant’s Current Report on Form 8-K filed onMay 31, 2019 under Commission File No. 333-228375-01 and incorporated byreference herein)

(b)   Theexhibits required to be filed by the Registrant pursuant to Item 601 ofRegulation S-K are listed above.

(c)   NotApplicable.

 

**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.

Banc of America Merrill LynchCommercial Mortgage Inc.(Depositor)

/s/ LelandF. Bunch, III

Leland F.Bunch, III, President and Chief Executive Officer

(senior officer in charge ofsecuritization of the depositor)

Date: March 20, 2020