**Management's Assertion on Compliance with ApplicableRegulation AB Servicing Criteria**

 

1.      3650 REIT LoanServicing LLC (the "**Asserting Party**") is responsible forassessing compliance with the servicing criteria applicable to it under paragraph(d) of Item 1122 of Regulation AB, as of and for the 12-month period endedDecember 31, 2022 (the "**Reporting Period**"), as set forth in **AppendixA** hereto. The transactions covered by this report, include commercialmortgage-asset-backed securities transactions, as listed on **Exhibit 1**hereto, for which the Asserting Party served as special servicer, and that wereregistered with the Securities and Exchange Commission pursuant to theSecurities Act of 1933 (the "**Platform**"); 

 

2.      The Asserting Partyhas engaged certain vendors, which are not servicers as defined in Item 1101(j)of Regulation AB (the "**Vendors**"), to perform specific, limitedor scripted activities, and the Asserting Party elects to take responsibilityfor assessing compliance with the servicing criteria or portion of theservicing criteria applicable to such Vendors' activities as set forth inAppendix A hereto;

 

3.      Except as setforth in paragraph 4 below, the Asserting Party used the criteria set forth inparagraph (d) of Item 1122 of Regulation AB to assess the compliance with theapplicable servicing criteria;

 

4.      The criterialisted in the column titled "Inapplicable Servicing Criteria" on **AppendixA**hereto are inapplicable to the Asserting Party based on the activities itperforms, directly or through its Vendors, with respect to the Platform;

 

5.      The AssertingParty has complied, in all material respects, with the applicable servicingcriteria as of December 31, 2022 and for the Reporting Period with respect tothe Platform taken as a whole;

 

6.      The AssertingParty has not identified and is not aware of any material instance ofnoncompliance by the Vendors with the applicable servicing criteria as ofDecember 31, 2022 and for the Reporting Period with respect to the Platformtaken as a whole;

 

7.      The AssertingParty has not identified any material deficiency in its policies and proceduresto monitor the compliance by the Vendors with the applicable servicing criteriaas of December 31, 2022 and for the Reporting Period with respect to thePlatform taken as a whole; and

 

8.      Deloitte &Touche LLP, an independent registered public accounting firm, has issued anattestation report on the Asserting Party's assessment of compliance with theapplicable servicing criteria for the Reporting Period.

 

 

February28, 2023

 

3650REIT Loan Servicing LLC,

aDelaware limited liability company

 

 

By:/s/ Peter LaPointe

Name:Peter LaPointe

Title: Managing Partner

 

 

**Exhibit 1**

 

| **Pooling and Servicing Agreements** | **Applicable Certification Period**   |
|--------------------------------------|---------------------------------------|
| CSAIL 2019-C15                       | January 1, 2022 to December 31, 2022  |
| CSAIL 2019-C17                       | January 1, 2022 to December 31, 2022  |
| CSAIL 2020-C19                       | January 1, 2022 to December 31, 2022  |
| CSMC 2020-TMIC                       | January 1, 2022 to December 31, 2022  |
| CSAIL 2021-C20                       | January 1, 2022 to December 31, 2022  |
| ALEN 2021-ACEN                       | January 1, 2022 to December 31, 2022  |
| 3650R 2021-PF1                       | January 1, 2022 to December 31, 2022  |
| TCO 2022-DPM                         | May 16, 2022 to December 31, 2022     |
| JPMCC 2022-NLP                       | May 16, 2022 to December 31, 2022     |
| BX 2022-PSB                          | August 15, 2022 to December 31, 2022  |
| INTOWN 2022-STAY                     | August 15, 2022 to December 31, 2022  |
| 3650R 2022-PF2                       | November 1, 2022 to December 31, 2022 |

 

 

**APPENDIX A**

 

|                                                                     | **SERVICING CRITERIA**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
|--------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
|                                                                     |  

 

**Reference**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |  

 

**Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | **Performed by Servicer** | **Inapplicable Servicing**

**Criteria** |   |
|                                                                     | **General Servicing Considerations**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
|                                                                     |  

 

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

**X** |   |   |
|                                                                     |  

 

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

**X1** |   |   |
|                                                                     |  

 

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

**X** |   |
|                                                                     |  

 

 

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

 

**X** |   |   |
|                                                                     |  

 

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

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

 

 

1122(d)(2)(i)                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | Payments on pool assets are deposited into the  appropriate custodial bank accounts and related bank clearing accounts no  more than two business days following receipt, or such other number of days  specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                              |   | **X2** |   |
|                                                                     |  

 

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

**X** |   |
|                                                                     |  

 

 

1122(d)(2)(iii)                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | Advances of funds or guarantees regarding  collections, cash flows or distributions, and any interest or other fees  charged for such advances, are made, reviewed and approved as specified in  the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |   | **X3** |   |
|                                                                     |  

 

 

1122(d)(2)(iv)                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | The related accounts for the transaction, such as  cash reserve accounts or accounts established as a form of  overcollateralization, are separately maintained (e.g., with respect to  commingling of cash) as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                      |   | **X2** |   |
|                                                                     |  

 

 

 

 

1122(d)(2)(v)                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | Each custodial account is maintained at a federally  insured depository institution as set forth in the transaction agreements.  For purposes of this criterion, "federally insured depository  institution" with respect to a foreign financial institution means a  foreign financial institution that meets the requirements of Rule 13k-1(b)(1)  of the Securities Exchange Act.                                                                                                                                                                                                                                                                                                                |   | **X2** |   |
|                                                                     |  

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

**X** |   |   |
|                                                                     |  

 

 

 

 

 

 

 

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

 

**X2** |   |
|                                                                     | **Investor Remittances and Reporting**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
|                                                                     |  

 

 

 

 

 

 

 

 

 

1122(d)(3)(i)                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | Reports to investors, including those to be filed  with the Commission, are maintained in accordance with the transaction  agreements and applicable Commission requirements. Specifically, such reports  (A) are prepared in accordance with timeframes and other terms set forth in  the transaction agreements; (B) provide information calculated in accordance  with the terms specified in the transaction agreements; (C) are filed with  the Commission as required by its rules and regulations; and (D) agree with  investors' or the trustee's records as to the total unpaid principal balance  and number of pool assets serviced by the Servicer.                                               |  

**X4** |   |   |
|                                                                     |  

 

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

**X** |   |
|                                                                     |  

 

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

 

**X** |   |
|                                                                     |  

 

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

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

 

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

**X5**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |   |   |
|  

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

 

 

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

 

 

 

1122(d)(4)(iv)                           | Payments on pool assets, including any payoffs, made  in accordance with the related pool asset documents are posted to the  Servicer's obligor records maintained no more than two business days after  receipt, or such other number of days specified in the transaction  agreements, and allocated to principal, interest or other items (e.g.,  escrow) in accordance with the related pool asset documents.                                                                                                                                                                            |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | **X6** |   |
|  

 

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

**X** |   |
|  

 

 

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

 

**X**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |   |   |
|  

 

 

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

 

**X**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |   |   |
|  

 

 

 

 

 

 

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

 

 

 

 

**X**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |   |   |
|  

 

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

**X** |   |
|  

 

 

 

 

 

 

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

 

 

 

**X** |   |
|  

 

 

 

 

 

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

 

 

**X** |   |
|  

 

 

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

 

**X** |   |
|  

 

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

**X** |   |
|  

 

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

**X** |   |
|  

 

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

**X** |   |

 

 

**X1**- 3650 REIT Loan Servicing LLC performs the activitiespertaining to this criterion, except for specific, limited activities performedby its third-party property managers relating to REO Property, if any. During the period of time addressed by this document, 3650 REIT Loan ServicingLLC was not servicing any REO properties; provided, however, in the event that3650 REIT Loan Servicing LLC services a REO asset it has policies andprocedures in place to service such asset in compliance with the applicable PSAand to supervise outside vendors who are assisting on the servicing of such REOasset to ensure said outside vendors’ activities comply with 3650 REIT LoanServicing LLC’s applicable policies and procedures. 3650 REIT Loan ServicingLLC has elected to take responsibility for assessing compliance with theseservicing criteria with respect to the activities of its third-party propertymanagers. The Asserting Party’s management hasdetermined that none of these vendors is considered a "servicer" asdefined in Item 1101(j) of Regulation AB, and the Asserting Party’s managementhas elected to take responsibility for assessing compliance with the servicingcriteria applicable to each vendor as permitted by the SEC's *Compliance andDisclosure Interpretation ("C&DI") 200.06, Vendors Engaged byServicers* (C&DI 200.06) (formerly SEC Manual of Publicly AvailableTelephone Interpretations 17.06). The Asserting Party has policies andprocedures in place designed to provide reasonable assurance that the vendors'activities comply in all material respects with the servicing criteriaapplicable to each vendor. The Asserting Party’s management is solelyresponsible for determining that it meets the SEC requirements to applyC&DI 200.06 for the vendors and related criteria.

 

**X2**- 3650 REIT Loan Servicing LLC performs the activitiesunder the criteria; however, the related criteria is marked inapplicable as3650 REIT Loan Servicing LLC did not have instances/activity for the year endedDecember 31, 2022 relating to the criteria.

** **

**X3**- 3650 REIT Loan Servicing LLC performs the activitiesunder the criteria for all transactions in Exhibit 1, excluding ALEN 2021-ACEN,TCO 2022-DPM, JPMCC 2022-NLP, INTOWN 2022-STAY and BX 2022-PSB; however, therelated criteria is marked inapplicable as 3650 REIT Loan Servicing LLC did nothave instances/activity for the year ended December 31, 2022 relating to thecriteria.

 

**X4**- Only items (A) and (B) of the Servicing Criteria areapplicable to 3650 REIT Loan Servicing LLC as special servicer. Items

(C)and (D) are inapplicable as the responsibility for filing reports with theCommission and agreeing totals to the Servicer records rests with the Trusteeand/or Certificate Administrator, as applicable.

** **

**X5-**3650 REIT Loan Servicing LLC performs the activitiesunder this criteria; however, 3650 REIT Loan Servicing LLC has engaged various vendors to perform the activitiesrequired by this servicing criteria. The Asserting Party’s management hasdetermined that none of these vendors is considered a "servicer" asdefined in Item 1101(j) of Regulation AB, and the Asserting Party’s managementhas elected to take responsibility for assessing compliance with the servicingcriteria applicable to each vendor as permitted by the SEC's *Complianceand Disclosure Interpretation ("C&DI") 200.06, Vendors Engaged byServicers*(C&DI 200.06) (formerly SEC Manual of Publicly AvailableTelephone Interpretations 17.06). The Asserting Party has policies andprocedures in place designed to provide reasonable assurance that the vendors'activities comply in all material respects with the servicing criteriaapplicable to each vendor. The Asserting Party’s management is solelyresponsible for determining that it meets the SEC requirements to applyC&DI 200.06 for the vendors and related criteria.

 

**X6**- 3650 REIT Loan Servicing LLC to date has notcollected any payments on pool assets in that each applicable securitization’smaster servicer has to date collected, deposited, and applies all suchpayments. Primary responsibility for processing borrower payments rests withthe Master Servicer. 3650 REIT Loan Servicing LLC may from time to time receivepayments on an exception basis related to services performed and fees chargedas Special Servicer related to Major Decisions, not related to payments on poolassets.