**UNITED STATESSECURITIES AND EXCHANGE COMMISSION**

**Washington, D.C. 20549**

**FORM 10-K**

(Mark One)

**x****   ANNUAL REPORT PURSUANT TOSECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934**

**For the fiscal year ended December 31, 2023or**

**o****    TRANSITION REPORTPURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934**

**For the transition period from _____ to _____Commission file number of the issuing entity: 333-226486-06**

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

**Wells Fargo Commercial MortgageTrust 2019-C51**

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

** **

**Central Index Key Number of the depositor: 0000850779**

**Wells Fargo Commercial MortgageSecurities, Inc.**

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

** **

**Central Index Key Number of the sponsor: 0000740906**

**Wells Fargo Bank, NationalAssociation**

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

** **

**Central Index Key Number of the sponsor: 0001592182**

**LMF Commercial, LLC**

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

**(formerly known as Rialto Mortgage Finance, LLC)**

** **

**Central Index Key Number of the sponsor: 0001549574**

**Barclays Capital Real Estate Inc.**

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

** **

**Central Index Key Number of the sponsor: 0001685185**

**UBS AG, acting through its branchlocated at 1285 Avenue of the Americas, New York, New York**

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

** **

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

**C-III Commercial Mortgage LLC**

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

** **

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

**the issuing entity)** | **38-4117348**

**38-4117349**

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

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

**c/o Computershare Trust Company, National Association, as agent for**

**Wells Fargo Bank, National Association**

**as Certificate Administrator**

**9062 Old Annapolis Road**

**Columbia, MD**

**(Address of principal executive offices of the issuingentity)**

**21045**

**(Zip Code)**

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

**(704) 374-6161**

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

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

 

 

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

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

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

Indicate by check mark whether the registrant (1) has filedall reports required to be filed by Section 13 or 15(d) of the SecuritiesExchange Act of 1934 during the preceding 12 months (or for such shorter periodthat the registrant was required to file such reports), and (2) has beensubject to such filing requirements for the past 90 days.  ⌧ Yes o No

Indicate by check mark whether the registrant has submitted electronicallyevery Interactive Data File required to be submitted 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 suchfiles).

Not applicable.

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

Large acceleratedfiler        o                                                                                                       Accelerated filer                                     o

Non-acceleratedfiler          ⌧                                                                                                      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 has filed areport on and attestation to its management’s assessment of the effectivenessof its internal control over financial reporting under Section 404(b) of theSarbanes-Oxley Act (15 U.S.C. 7262(b)) by the registered public accounting firmthat prepared or issued its audit report. o

If securities are registered pursuant to Section 12(b) of theAct, indicate by check mark whether the financial statements of the registrantincluded in the filing reflect the correction of an error to previously issuedfinancial statements. o

Indicate by check mark whether any of those error correctionsare restatements that required a recovery analysis of incentive-basedcompensation received by any of the registrant’s executive officers during therelevant recovery period pursuant to §240.10D-1(b). o

Indicate by check mark whether the registrant is a shellcompany (as defined in Rule 12b-2 of the Act).  o Yes ⌧No

State the aggregate market value of the voting and non-votingcommon equity held by non-affiliates computed by reference to the price atwhich the common equity was last sold, or the average bid and asked price ofsuch common equity, as of the last business day of the registrant’s mostrecently completed second fiscal quarter.

Not applicable.

Indicate by check mark whether the registrant has filed all documentsand reports required to be filed by Section 12, 13 or 15(d) of the SecuritiesExchange Act of 1934 subsequent to the distribution of securities under a planconfirmed by a court.  o Yes o No

Not applicable.

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

Not applicable.

**DOCUMENTS INCORPORATED BY REFERENCE**

** **

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

Not applicable.

 

** **

**EXPLANATORY NOTES**

The Nova Place Mortgage Loan, the El ConCenter Mortgage Loan, the 450-460 Park Avenue South Mortgage Loan and theExchangeRight Net Leased Portfolio #27 Mortgage Loan, which constitutedapproximately 9.7%, 6.2%, 6.2% and 5.6%, respectively, of the asset pool of theissuing entity as of its cut-off date, are each an asset of the issuing entityand are each part of a loan combination that includes (a) with respect to theNova Place Mortgage Loan, two other *pari passu* loans, which are notassets of the issuing entity, (b) with respect to the El Con Center MortgageLoan, one other *pari passu* loan, which is not an asset of the issuingentity, (c) with respect to the 450-460 Park Avenue South Mortgage Loan, oneother *pari passu* loan, which is not an asset of the issuing entity and(d) with respect to the ExchangeRight Net Leased Portfolio #27 Mortgage Loan,one other *pari passu* loan, which is not an asset of the issuing entity.These loan combinations, including the Nova Place Mortgage Loan, the El ConCenter Mortgage Loan, the 450-460 Park Avenue South Mortgage Loan and theExchangeRight Net Leased Portfolio #27 Mortgage Loan, are being serviced andadministered 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 Hilton at University Place Mortgage Loan,which constituted approximately 1.5% of the asset pool of the issuing entity asof its cut-off date.  The Hilton at University Place Mortgage Loan is anasset of the issuing entity and is part of a loan combination that includes theHilton at University Place Mortgage Loan and one other *pari passu* loan,which is not an asset of the issuing entity. The other *pari passu*portion of the loan combination was securitized in the Wells Fargo CommercialMortgage Trust 2019-C50 transaction, Commission File Number 333-226486-05 (the“WFCM 2019-C50 Transaction”). This loan combination, including theHilton at University Place Mortgage Loan, is being serviced and administeredpursuant to the pooling and servicing agreement for the WFCM 2019-C50Transaction, which is incorporated by reference as Exhibit 4.2 to this AnnualReport on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Patuxent Crossing Mortgage Loan and theWolverine Portfolio Mortgage Loan, which constituted approximately 2.3% and0.5%, respectively, of the asset pool of the issuing entity as of its cut-offdate.  The Patuxent Crossing Mortgage Loan and the Wolverine PortfolioMortgage Loan are each an asset of the issuing entity and are each part of aloan combination that includes (a) with respect to the Patuxent Crossing MortgageLoan, one other *pari passu* loan, which is not an asset of the issuingentity or (b) with respect to the Wolverine Portfolio Mortgage Loan, eightother *pari passu* loans, which are not assets of the issuing entity. A *paripassu* portion of each loan combination was securitized in the BBCMSMortgage Trust 2019-C3 transaction, Commission File Number 333-226850-02 (the “BBCMS2019-C3 Transaction”). These loan combinations, including the PatuxentCrossing Mortgage Loan and the Wolverine Portfolio Mortgage Loan, are beingserviced and administered pursuant to the pooling and servicing agreement forthe BBCMS 2019-C3 Transaction, which is incorporated by reference as Exhibit4.3 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the CIRE Equity Retail & IndustrialPortfolio Mortgage Loan, which constituted approximately 3.0% of the asset poolof the issuing entity as of its cut-off date.  The CIRE Equity Retail& Industrial Portfolio Mortgage Loan is an asset of the issuing entity andis part of a loan combination that includes the CIRE Equity Retail &Industrial Portfolio Mortgage Loan and five other *pari passu* loans,which are not assets of the issuing entity. This loan combination, includingthe CIRE Equity Retail & Industrial Portfolio Mortgage Loan, was serviced underthe Pooling and Servicing Agreement for the issuing entity prior to the closingof the securitization of a *pari passu* portion of the CIRE Equity Retail& Industrial Portfolio  loan combination in the Benchmark 2019-B12Mortgage Trust transaction, Commission File Number 333-228597-01 (the “Benchmark2019-B12 Transaction”).  After the closing of the Benchmark 2019-B12Transaction on August 8, 2019, this loan combination, including the CIRE EquityRetail & Industrial Portfolio Mortgage Loan was, and will continue to be,serviced and administered pursuant to the pooling and servicing agreement withrespect to the Benchmark 2019-B12 Transaction, which is incorporated byreference as Exhibit 4.4 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the 188 Spear Street Mortgage Loan, whichconstituted approximately 6.4% of the asset pool of the issuing entity as ofits cut-off date.  The 188 Spear Street Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the 188 SpearStreet Mortgage Loan and two other *pari passu* loans, which are notassets of the issuing entity. This loan combination, including the 188 SpearStreet Mortgage Loan, was serviced under the Pooling and Servicing Agreementfor the issuing entity prior to the closing of the securitization of a *paripassu* portion of the 188 Spear Street loan combination in the BBCMSMortgage Trust 2019-C4 transaction, Commission File Number 333-226850-03 (the “BBCMS2019-C4 Transaction”).  After the closing of the BBCMS 2019-C4Transaction on August 28, 2019, this loan combination, including the 188 SpearStreet Mortgage Loan was, and will continue to be, serviced and administeredpursuant to the pooling and servicing agreement with respect to the BBCMS2019-C4 Transaction, which is incorporated by reference as Exhibit 4.5 to thisAnnual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to The Chantilly Office Portfolio Mortgage Loan,which constituted approximately 3.1% of the asset pool of the issuing entity asof its cut-off date.  The Chantilly Office Portfolio Mortgage Loan is anasset of the issuing entity and is part of a loan combination that includes TheChantilly Office Portfolio Mortgage Loan and two other *pari passu* loans,which are not assets of the issuing entity. This loan combination, includingThe Chantilly Office Portfolio Mortgage Loan, was serviced under the Poolingand Servicing Agreement for the issuing entity prior to the closing of thesecuritization of a *pari passu* portion of The Chantilly Office Portfolioloan combination in the UBS Commercial Mortgage Trust 2019-C17 transaction,Commission File Number 333-227784-04 (the “UBS 2019-C17 Transaction”). After the closing of the UBS 2019-C17 Transaction on October 15, 2019, thisloan combination, including The Chantilly Office Portfolio Mortgage Loan was,and will continue to be, serviced and administered pursuant to the pooling andservicing agreement with respect to the UBS 2019-C17 Transaction, which isincorporated by reference as Exhibit 4.6 to this Annual Report on Form 10-K.

The master servicer of a poolingand servicing agreement or trust and servicing agreement also functions as theprimary servicer of the related mortgage loans serviced and 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 188 Spear Street Mortgage Loan, The Chantilly Office PortfolioMortgage Loan and the Hilton at University Place Mortgage Loan. As a result,Wells Fargo Bank, National Association is a “servicer” as defined in Item1108(a)(2)(iii) of Regulation AB, in the capacities described above, because itis servicing mortgage loans that constituted 10% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria, accountants’ attestation reports and servicercompliance statements delivered by Wells Fargo Bank, National Association inthe capacities described above are listed in the Exhibit Index.

Wells Fargo Bank, NationalAssociation is the custodian of the mortgage loans serviced under the Poolingand Servicing Agreement, the 188 Spear Street Mortgage Loan, The ChantillyOffice Portfolio Mortgage Loan, the Patuxent Crossing Mortgage Loan, the Hiltonat University Place Mortgage Loan and the Wolverine Portfolio MortgageLoan.  As a result, Wells Fargo Bank, National Association is a servicingfunction participant in the capacities described above, because it is servicingmortgage loans that constituted 5% or more of the assets of the issuing entityas of its cut-off date. The assessments of compliance with applicable servicingcriteria and accountants’ attestation reports delivered by Wells Fargo Bank,National Association in the capacities described above are listed in theExhibit Index.

Pentalpha Surveillance LLC is theoperating advisor of the mortgage loans serviced under the Pooling andServicing Agreement, The Chantilly Office Portfolio Mortgage Loan, the CIREEquity Retail & Industrial Portfolio Mortgage Loan, the Patuxent CrossingMortgage Loan and the Wolverine Portfolio Mortgage Loan.  As a result,Pentalpha Surveillance LLC is a servicing function participant in thecapacities described above, because it is servicing mortgage loans thatconstituted 5% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria andaccountants’ attestation reports delivered by Pentalpha Surveillance LLC in thecapacities described above are listed in the Exhibit Index.

Rialto Capital Advisors, LLC isthe special servicer of the 188 Spear Street Mortgage Loan, The ChantillyOffice Portfolio Mortgage Loan and the Hilton at University Place MortgageLoan. As a result, Rialto Capital Advisors, LLC is a “servicer” as defined inItem 1108(a)(2)(iii) of Regulation AB, in the capacities described above,because it is servicing mortgage loans that constituted 10% or more of theassets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria, accountants’ attestation reportsand servicer compliance statements delivered by Rialto Capital Advisors, LLC inthe capacities described above are listed in the Exhibit Index.

Park Bridge Lender Services LLC isthe operating advisor of the 188 Spear Street Mortgage Loan and the Hilton atUniversity Place Mortgage Loan.  As a result, Park Bridge Lender ServicesLLC 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 Park Bridge Lender Services LLC in the capacitiesdescribed above are listed in the Exhibit Index.

Midland Loan Services, a Divisionof PNC Bank, National Association is the primary servicer of the WolverinePortfolio Mortgage Loan, the Patuxent Crossing Mortgage Loan and the CIREEquity Retail & Industrial Portfolio Mortgage Loan and the special servicerof the Wolverine Portfolio Mortgage Loan, the Patuxent Crossing Mortgage Loanand the CIRE Equity Retail & Industrial Portfolio Mortgage Loan prior toMay 10, 2023.  These mortgage loans constitute more than 5%, but less than10%, of the pool assets of the issuing entity.  Therefore, the Depositorincluded in this Annual Report on Form 10-K an assessment of compliance withapplicable servicing criteria for Midland Loan Services, a Division of PNCBank, National Association and an accountants’ attestation report pursuant toItem 1122 of Regulation AB because Midland Loan Services, a Division of PNC Bank,National Association is servicing more than 5% of the pool assets. However, the Depositor is not required to include in this Annual Report on Form10-K a servicer compliance statement pursuant to Item 1123 of Regulation AB ofMidland Loan Services, a Division of PNC Bank, National Association becauseMidland Loan Services, a Division of PNC Bank, National Association is anunaffiliated servicer servicing less than 10% of pool assets.

K-StarAsset Management LLC is the special servicer of the CIRE Equity Retail &Industrial Portfolio Mortgage Loan, the Patuxent Crossing Mortgage Loan and theWolverine Portfolio Mortgage Loan, which constituted approximately 3.0%,2.3% and 0.5%, respectively, of the asset pool of the issuing entity as of itscut-off date. In accordance with the Compliance and Disclosure Interpretations,Section 200.03 (Rules 13a-18 and 15d-18, Servicer’s Assessment of Compliance),this percentage must be reduced pro rata because it was only acting as specialservicer of the CIRE Equity Retail & Industrial Portfolio Mortgage Loan,the Patuxent Crossing Mortgage Loan and the Wolverine Portfolio Mortgage Loanfrom May 10, 2023 to December 31, 2023. As a result, it falls below the deminimis requirements in Item 1122 of Regulation AB and no such assessment orattestation is required.

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

Wilmington Trust, NationalAssociation acts as trustee of  the mortgage loans serviced under thePooling and Servicing Agreement, the Hilton at University Place Mortgage Loan,the CIRE Equity Retail & Industrial Portfolio Mortgage Loan, the 188 SpearStreet Mortgage Loan and The Chantilly Office Portfolio Mortgage Loan. Pursuant to the Pooling and Servicing Agreement, the pooling and servicingagreement for the WFCM 2019-C50 Transaction, the pooling and servicingagreement for the Benchmark 2019-B12 Transaction, the pooling and servicingagreement for the BBCMS 2019-C4 Transaction and the pooling and servicingagreement for the UBS 2019-C17 Transaction, the trustee is required to providean assessment of compliance with applicable servicing criteria solely withrespect to Item 1122(d)(2)(iii) of Regulation AB (regarding advances of fundsor guarantees regarding collections, cash flows or distributions, and anyinterest or other fees charged for such advances, are made, reviewed and approvedas specified in the transaction agreements). However, during the reportingperiod, the trustee did not perform any servicing function with respect to theservicing criteria specified in Item 1122(d)(2)(iii) of Regulation AB. The master servicer or the special servicer, to the extent required, performedthe servicing function identified with respect to Item 1122(d)(2)(iii) ofRegulation AB, and each such party included Item 1122(d)(2)(iii) of RegulationAB in the assessment of compliance with applicable servicing criteria andaccountant’s attestation report for the subject transaction.  As a result,this Annual Report on Form 10-K does not include an assessment of compliancewith applicable servicing criteria of the trustee. One or more other servicersof  the mortgage loans serviced under the Pooling and Servicing Agreement,the Hilton at University Place Mortgage Loan, the CIRE Equity Retail &Industrial Portfolio Mortgage Loan, the 188 Spear Street Mortgage Loan and TheChantilly Office Portfolio Mortgage Loan have delivered one or more assessmentsof compliance 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 Solutions, LLC.  Thisentity was engaged by the master servicer under the Pooling and ServicingAgreement and the primary servicer of the Hilton at University Place MortgageLoan, the 188 Spear Street Mortgage Loan and The Chantilly Office PortfolioMortgage Loan to remit tax payments received from the escrow accounts ofborrowers to local taxing authorities, to report tax amounts due, to verify taxparcel information, and to verify non-escrow tax payments. These servicingfunctions are included within the servicing criteria set forth in Items1122(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, this vendoris a “servicer” for the purposes of Item 1122 of Regulation AB.  *See*Compliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

This AnnualReport on Form 10-K includes an assessment of compliance with applicable servicingcriteria, accountants’ attestation report and servicer compliance statementfrom Computershare Trust Company, National Association (“CTCNA”). CTCNA was engaged by Wells Fargo Bank, National Association (“Wells Fargo”),in its capacity as certificate administrator and custodian, to perform certainspecified servicing functions identified in the assessment of compliance withapplicable servicing criteria and accountants’ attestation reports.  WellsFargo engaged CTCNA in connection with the sale of Wells Fargo’s corporatetrust services business to CTCNA and its affiliates.  Further, under theprinciples-based definition of “servicer” set forth in Item 1101(j) ofRegulation AB that looks to the functions that an entity performs, this partyis a “servicer” for the purposes of Item 1123 of Regulation AB.  *See*Compliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

The assessments of compliance withapplicable servicing criteria, accountants’ attestation reports and servicercompliance statements of the certificate administrator of the Hilton atUniversity Place Mortgage Loan, the Patuxent Crossing Mortgage Loan, theWolverine Portfolio Mortgage Loan, the 188 Spear Street Mortgage Loan, TheChantilly Office Portfolio Mortgage Loan and the CIRE Equity Retail &Industrial Portfolio Mortgage Loan are omitted from this Annual Report on Form10-K as the certificate administrator pursuant to the related pooling andservicing agreement or trust and servicing agreement does not perform any activitiesthat address servicing criteria with respect to the issuing entity and becausethey are each not a “servicer” that meets the criteria in Item 1108(a)(2)(i)through (iii) of Regulation AB.

With respect to the *pari passu*loan combinations that include the Patuxent Crossing Mortgage Loan, theWolverine Portfolio Mortgage Loan and the CIRE Equity Retail & IndustrialPortfolio Mortgage Loan, (i) the report on assessment of compliance withservicing criteria and attestation report on assessment of compliance withservicing criteria of Citibank, N.A. as custodian of the CIRE Equity Retail& Industrial Portfolio Mortgage Loan, listed on the Exhibit Index areomitted from this Annual Report on Form 10-K as they are not required to beincluded on this Annual Report on Form 10-K per Instruction 3 to Item 1122 ofRegulation AB because it is a party performing activities that addressservicing criteria relating to 5% or less of the assets of the issuing entity,and the report on assessment of compliance with servicing criteria andattestation report on assessment of compliance with servicing criteria ofK-Star Asset Management LLC as special servicer of the CIRE Equity Retail &Industrial Portfolio Mortgage Loan, the Patuxent Crossing Mortgage Loan and theWolverine Portfolio Mortgage Loan on and after May 10, 2023 listed on theExhibit Index are omitted from this Annual Report on Form 10-K for the reasonsset forth in the Explanatory Notes above; and (ii) the servicer compliancestatements of Midland Loan Services, a Division of PNC Bank, NationalAssociation as primary servicer of the PatuxentCrossing Mortgage Loan, the Wolverine Portfolio Mortgage Loan and the CIREEquity Retail & Industrial Portfolio Mortgage Loan and special servicerof the Patuxent Crossing Mortgage Loan, the Wolverine Portfolio Mortgage Loanand the CIRE Equity Retail & Industrial Portfolio Mortgage Loan prior toMay 10, 2023 and K-Star Asset Management LLC as special servicer of thePatuxent Crossing Mortgage Loan, the Wolverine Portfolio Mortgage Loan and theCIRE Equity Retail & Industrial Portfolio Mortgage Loan on and after May10, 2023, 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 1C.  Cybersecurity.**

Omitted.

**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.  [Reserved]**

**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.

**Item 9C.  Disclosure Regarding Foreign Jurisdictionsthat Prevent Inspections.**

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 Accountant 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 DerivativesInstruments (Financial Information).**

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

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

The registrant knows of 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,certificate administrator and custodian. 

In December 2014, Phoenix Light SFLimited (Phoenix Light) and certain related entities filed a complaint in theUnited States District Court for the Southern District of New York allegingclaims against Wells Fargo Bank, N.A., in its capacity as trustee for a numberof residential mortgage-backed securities (RMBS) trusts. Complaints raisingsimilar allegations have been filed by Commerzbank AG in the Southern Districtof New York, IKB International and IKB Deutsche Industriebank (together, IKB)in New York state court, and Park Royal I LLC and Park Royal II LLC in New Yorkstate court. In each case, the plaintiffs allege that Wells Fargo Bank, N.A.,as trustee, caused losses to investors, and plaintiffs assert causes of actionbased upon, among other things, the trustee’s alleged failure to notify andenforce repurchase obligations of mortgage loan sellers for purported breachesof representations and warranties, notify investors of alleged events ofdefault, and abide by appropriate standards of care following alleged events ofdefault. In July 2022, the district court dismissed Phoenix Light’s claims andcertain of the claims asserted by Commerzbank AG, and subsequently enteredjudgment in each case in favor of Wells Fargo Bank, N.A. In August 2022,Phoenix Light and Commerzbank AG each appealed the district court’s decision tothe United States Court of Appeals for the Second Circuit. Phoenix Lightdismissed its appeal in May 2023, terminating its case. In November 2023, WellsFargo Bank, N.A. entered into an agreement with IKB to resolve IKB’s claims.Wells Fargo Bank, N.A. previously settled two class actions filed byinstitutional investors and an action filed by the National Credit UnionAdministration with similar allegations.

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

The information regarding this Item has been previouslyprovided in the prospectus of the Registrant relating to the issuing entityfiled on July 11, 2019 pursuant to Rule 424(b)(2).

**Item 1122 of Regulation AB, Compliance with ApplicableServicing Criteria.**

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the mortgage loans are attachedhereto under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit AAto the Pooling and Servicing Agreement incorporated by reference as Exhibit 4.1to this Annual Report on Form 10-K is a chart identifying the entitiesparticipating in a servicing function for the transaction responsible for eachapplicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Hilton at University PlaceMortgage Loan, which is being serviced and administered pursuant to the poolingand servicing agreement for the WFCM 2019-C50 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit AA to thepooling and servicing agreement for the WFCM 2019-C50 Transaction incorporatedby reference as Exhibit 4.2 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the WFCM2019-C50 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Patuxent Crossing Mortgage Loanand the Wolverine Portfolio Mortgage Loan, which are being serviced andadministered pursuant to the pooling and servicing agreement for the BBCMS2019-C3 Transaction, are attached hereto under Item 15 to this Annual Report onForm 10-K. Attached as Exhibit AA to the pooling and servicing agreement forthe BBCMS 2019-C3 Transaction incorporated by reference as Exhibit 4.3 to thisAnnual Report on Form 10-K is a chart identifying the entities participating ina servicing function for the BBCMS 2019-C3 Transaction responsible for eachapplicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the CIRE Equity Retail &Industrial Portfolio Mortgage Loan, which is being serviced and administeredpursuant to the pooling and servicing agreement for the Benchmark 2019-B12Transaction, are attached hereto under Item 15 to this Annual Report on Form10-K. Attached as Exhibit O to the pooling and servicing agreement for theBenchmark 2019-B12 Transaction incorporated by reference as Exhibit 4.4 to thisAnnual Report on Form 10-K is a chart identifying the entities participating ina servicing function for the Benchmark 2019-B12 Transaction responsible foreach applicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the 188 Spear Street Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the BBCMS 2019-C4 Transaction, are attached hereto under Item 15 tothis Annual Report on Form 10-K. Attached as Exhibit AA to the pooling andservicing agreement for the BBCMS 2019-C4 Transaction incorporated by referenceas Exhibit 4.5 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the BBCMS 2019-C4Transaction responsible for each applicable servicing criteria set forth inItem 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to The Chantilly Office PortfolioMortgage Loan, which is being serviced and administered pursuant to the poolingand servicing agreement for the UBS 2019-C17 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit Z to thepooling and servicing agreement for the UBS 2019-C17 Transaction incorporatedby reference as Exhibit 4.6 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the UBS2019-C17 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

**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. Exhibit and Financial Statement Schedules**

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

(1) Not applicable

(2) Not applicable

(3) See below

4.1          Poolingand Servicing Agreement, dated as of July 1, 2019, by and among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, C-III Asset Management LLC, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Pentalpha SurveillanceLLC, as Operating Advisor and as Asset Representations Reviewer (filed asExhibit 4.1 to the registrant’s Current Report on Form 8-K/A filed on August15, 2019 under Commission File No. 333-226486-06 and incorporated by referenceherein).

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

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

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

4.5          Poolingand Servicing Agreement, dated as of August 1, 2019, by and among BarclaysCommercial Mortgage Securities LLC, as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, Rialto Capital Advisors, LLC, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Park Bridge LenderServices LLC, as Operating Advisor and as Asset Representations Reviewer (filedas Exhibit 99.1 to the registrant’s Current Report on Form 8-K filed onSeptember 3, 2019 under Commission File No. 333-226486-06 and incorporated byreference herein).

4.6          Poolingand Servicing Agreement, dated as of October 1, 2019, by and among UBSCommercial Mortgage Securitization Corp., as Depositor, Wells Fargo Bank,National Association, as Master Servicer, Rialto Capital Advisors, LLC asSpecial Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator, Wilmington Trust, National Association, as Trustee, andPentalpha Surveillance LLC, as Operating Advisor and as Asset RepresentationsReviewer (filed as Exhibit 99.1 to the registrant’s Current Report on Form 8-Kfiled on October 21, 2019 under Commission File No. 333-226486-06 andincorporated by reference herein).

31           Rule 13a-14(d)/15d-14(d) Certifications.

33           Reports on assessment of compliance with servicing criteria for asset-backedsecurities.

33.1        Wells Fargo Bank, National Association, as MasterServicer

33.2        Greystone Servicing Company LLC (as successor toC-III Asset Management LLC), as Special Servicer

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

33.4        Wells Fargo Bank, National Association, asCertificate Administrator

33.5        Wells Fargo Bank, National Association, as Custodian

33.6        Pentalpha Surveillance LLC, as Operating Advisor

33.7        CoreLogic Solutions, LLC, as Servicing FunctionParticipant

33.8         Computershare Trust Company, National Association, asServicing Function Participant for the Certificate Administrator

33.9        Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian

33.10      Wells Fargo Bank, National Association, as PrimaryServicer of the Nova Place Mortgage Loan (see Exhibit 33.1)

33.11      Greystone Servicing Company LLC (as successor toC-III Asset Management LLC), as Special Servicer of the Nova Place MortgageLoan (see Exhibit 33.2)

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

33.13      Wells Fargo Bank, National Association, asCustodian of the Nova Place Mortgage Loan (see Exhibit 33.5)

33.14      Pentalpha Surveillance LLC, as Operating Advisor ofthe Nova Place Mortgage Loan (see Exhibit 33.6)

33.15      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Nova Place Mortgage Loan (see Exhibit 33.7)

33.16       Computershare Trust Company, National Association, asServicing Function Participant for the Custodian (see Exhibit 33.9)

33.17      Wells Fargo Bank, National Association, as PrimaryServicer of the 450-460 Park Avenue South Mortgage Loan (see Exhibit 33.1)

33.18      Greystone Servicing Company LLC (as successor toC-III Asset Management LLC), as Special Servicer of the 450-460 Park AvenueSouth Mortgage Loan (see Exhibit 33.2)

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

33.20      Wells Fargo Bank, National Association, asCustodian of the 450-460 Park Avenue South Mortgage Loan (see Exhibit 33.5)

33.21      Pentalpha Surveillance LLC, as Operating Advisor ofthe 450-460 Park Avenue South Mortgage Loan (see Exhibit 33.6)

33.22      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 450-460 Park Avenue South Mortgage Loan (see Exhibit 33.7)

33.23      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.9)

33.24      Wells Fargo Bank, National Association, as PrimaryServicer of the El Con Center Mortgage Loan (see Exhibit 33.1)

33.25      Greystone Servicing Company LLC (as successor toC-III Asset Management LLC), as Special Servicer of the El Con Center MortgageLoan (see Exhibit 33.2)

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

33.27      Wells Fargo Bank, National Association, asCustodian of the El Con Center Mortgage Loan (see Exhibit 33.5)

33.28      Pentalpha Surveillance LLC, as Operating Advisor ofthe El Con Center Mortgage Loan (see Exhibit 33.6)

33.29      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the El Con Center Mortgage Loan (see Exhibit 33.7)

33.30      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.9)

33.31      Wells Fargo Bank, National Association, as PrimaryServicer of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan (seeExhibit 33.1)

33.32      Greystone Servicing Company LLC (as successor to C-IIIAsset Management LLC), as Special Servicer of the ExchangeRight Net LeasedPortfolio #27 Mortgage Loan (see Exhibit 33.2)

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

33.34      Wells Fargo Bank, National Association, asCustodian of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan (seeExhibit 33.5)

33.35      Pentalpha Surveillance LLC, as Operating Advisor ofthe ExchangeRight Net Leased Portfolio #27 Mortgage Loan (see Exhibit 33.6)

33.36      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan (seeExhibit 33.7)

33.37      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.9)

33.38      Wells Fargo Bank, National Association, as PrimaryServicer of the Hilton at University Place Mortgage Loan (see Exhibit 33.1)

33.39      Rialto Capital Advisors, LLC, as Special Servicerof the Hilton at University Place Mortgage Loan

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

33.41      Wells Fargo Bank, National Association, asCustodian of the Hilton at University Place Mortgage Loan (see Exhibit 33.5)

33.42      Park Bridge Lender Services LLC, as OperatingAdvisor of the Hilton at University Place Mortgage Loan

33.43      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Hilton at University Place Mortgage Loan (see Exhibit 33.7)

33.44      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.9)

33.45      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Patuxent Crossing MortgageLoan

33.46      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Patuxent Crossing MortgageLoan prior to May 10, 2023 (see Exhibit 33.45)

33.47      K-Star Asset Management LLC, as Special Servicer of the Patuxent CrossingMortgage Loan on and after May 10, 2023 (Omitted. See Explanatory Notes.)

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

33.49      Wells Fargo Bank, National Association, asCustodian of the Patuxent Crossing Mortgage Loan (see Exhibit 33.5)

33.50      Pentalpha Surveillance LLC, as Operating Advisor ofthe Patuxent Crossing Mortgage Loan (see Exhibit 33.6)

33.51      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.9)

33.52      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Wolverine Portfolio MortgageLoan (see Exhibit 33.45)

33.53      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Wolverine Portfolio MortgageLoan prior to May 10, 2023 (see Exhibit 33.45)

33.54      K-Star Asset Management LLC, as Special Servicer of the Wolverine PortfolioMortgage Loan on and after May 10, 2023 (Omitted. See Explanatory Notes.)

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

33.56      Wells Fargo Bank, National Association, asCustodian of the Wolverine Portfolio Mortgage Loan (see Exhibit 33.5)

33.57      Pentalpha Surveillance LLC, as Operating Advisor ofthe Wolverine Portfolio Mortgage Loan (see Exhibit 33.6)

33.58      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.9)

33.59      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the CIRE Equity Retail &Industrial Portfolio Mortgage Loan (see Exhibit 33.45)

33.60      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the CIRE Equity Retail &Industrial Portfolio Mortgage Loan prior to May 10, 2023 (see Exhibit 33.45)

33.61      K-Star Asset Management LLC, as Special Servicer of the CIRE Equity Retail& Industrial Portfolio Mortgage Loan on and after May 10, 2023 (Omitted.See Explanatory Notes.)

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

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

33.64      Pentalpha Surveillance LLC, as Operating Advisor ofthe CIRE Equity Retail & Industrial Portfolio Mortgage Loan (see Exhibit33.6)

33.65      Wells Fargo Bank, National Association, as PrimaryServicer of the 188 Spear Street Mortgage Loan (see Exhibit 33.1)

33.66      Rialto Capital Advisors, LLC, as Special Servicerof the 188 Spear Street Mortgage Loan (see Exhibit 33.39)

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

33.68      Wells Fargo Bank, National Association, asCustodian of the 188 Spear Street Mortgage Loan (see Exhibit 33.5)

33.69      Park Bridge Lender Services LLC, as Operating Advisorof the 188 Spear Street Mortgage Loan (see Exhibit 33.42)

33.70      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 188 Spear Street Mortgage Loan (see Exhibit 33.7)

33.71      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.9)

33.72      Wells Fargo Bank, National Association, as PrimaryServicer of The Chantilly Office Portfolio Mortgage Loan (see Exhibit 33.1)

33.73      Rialto Capital Advisors, LLC, as Special Servicerof The Chantilly Office Portfolio Mortgage Loan (see Exhibit 33.39)

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

33.75      Wells Fargo Bank, National Association, as Custodianof The Chantilly Office Portfolio Mortgage Loan (see Exhibit 33.5)

33.76      Pentalpha Surveillance LLC, as Operating Advisor ofThe Chantilly Office Portfolio Mortgage Loan (see Exhibit 33.6)

33.77      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of The Chantilly Office Portfolio Mortgage Loan (see Exhibit 33.7)

33.78      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.9)

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

34.1        Wells Fargo Bank, National Association, as MasterServicer

34.2        Greystone Servicing Company LLC (as successor toC-III Asset Management LLC), as Special Servicer

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

34.4        Wells Fargo Bank, National Association, asCertificate Administrator

34.5        Wells Fargo Bank, National Association, asCustodian

34.6        Pentalpha Surveillance LLC, as Operating Advisor

34.7        CoreLogic Solutions, LLC, as Servicing FunctionParticipant

34.8        Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator

34.9        Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian

34.10      Wells Fargo Bank, National Association, as PrimaryServicer of the Nova Place Mortgage Loan (see Exhibit 34.1)

34.11      Greystone Servicing Company LLC (as successor toC-III Asset Management LLC), as Special Servicer of the Nova Place MortgageLoan (see Exhibit 34.2)

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

34.13      Wells Fargo Bank, National Association, asCustodian of the Nova Place Mortgage Loan (see Exhibit 34.5)

34.14      Pentalpha Surveillance LLC, as Operating Advisor ofthe Nova Place Mortgage Loan (see Exhibit 34.6)

34.15      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Nova Place Mortgage Loan (see Exhibit 34.7)

34.16      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.9)

34.17      Wells Fargo Bank, National Association, as PrimaryServicer of the 450-460 Park Avenue South Mortgage Loan (see Exhibit 34.1)

34.18      Greystone Servicing Company LLC (as successor toC-III Asset Management LLC), as Special Servicer of the 450-460 Park AvenueSouth Mortgage Loan (see Exhibit 34.2)

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

34.20      Wells Fargo Bank, National Association, asCustodian of the 450-460 Park Avenue South Mortgage Loan (see Exhibit 34.5)

34.21      Pentalpha Surveillance LLC, as Operating Advisor ofthe 450-460 Park Avenue South Mortgage Loan (see Exhibit 34.6)

34.22      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 450-460 Park Avenue South Mortgage Loan (see Exhibit 34.7)

34.23      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.9)

34.24      Wells Fargo Bank, National Association, as PrimaryServicer of the El Con Center Mortgage Loan (see Exhibit 34.1)

34.25      Greystone Servicing Company LLC (as successor toC-III Asset Management LLC), as Special Servicer of the El Con Center MortgageLoan (see Exhibit 34.2)

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

34.27      Wells Fargo Bank, National Association, asCustodian of the El Con Center Mortgage Loan (see Exhibit 34.5)

34.28      Pentalpha Surveillance LLC, as Operating Advisor ofthe El Con Center Mortgage Loan (see Exhibit 34.6)

34.29      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the El Con Center Mortgage Loan (see Exhibit 34.7)

34.30      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.9)

34.31      Wells Fargo Bank, National Association, as PrimaryServicer of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan (seeExhibit 34.1)

34.32      Greystone Servicing Company LLC (as successor toC-III Asset Management LLC), as Special Servicer of the ExchangeRight NetLeased Portfolio #27 Mortgage Loan (see Exhibit 34.2)

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

34.34      Wells Fargo Bank, National Association, asCustodian of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan (seeExhibit 34.5)

34.35      Pentalpha Surveillance LLC, as Operating Advisor ofthe ExchangeRight Net Leased Portfolio #27 Mortgage Loan (see Exhibit 34.6)

34.36      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan (seeExhibit 34.7)

34.37      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.9)

34.38      Wells Fargo Bank, National Association, as PrimaryServicer of the Hilton at University Place Mortgage Loan (see Exhibit 34.1)

34.39      Rialto Capital Advisors, LLC, as Special Servicerof the Hilton at University Place Mortgage Loan

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

34.41      Wells Fargo Bank, National Association, asCustodian of the Hilton at University Place Mortgage Loan (see Exhibit 34.5)

34.42      Park Bridge Lender Services LLC, as OperatingAdvisor of the Hilton at University Place Mortgage Loan

34.43      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Hilton at University Place Mortgage Loan (see Exhibit 34.7)

34.44      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.9)

34.45      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Patuxent Crossing MortgageLoan

34.46      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Patuxent Crossing MortgageLoan prior to May 10, 2023 (see Exhibit 34.45)

34.47      K-Star Asset Management LLC, as Special Servicer of the Patuxent CrossingMortgage Loan on and after May 10, 2023 (Omitted. See Explanatory Notes.)

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

34.49      Wells Fargo Bank, National Association, asCustodian of the Patuxent Crossing Mortgage Loan (see Exhibit 34.5)

34.50      Pentalpha Surveillance LLC, as Operating Advisor ofthe Patuxent Crossing Mortgage Loan (see Exhibit 34.6)

34.51      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.9)

34.52      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Wolverine Portfolio MortgageLoan (see Exhibit 34.45)

34.53      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Wolverine Portfolio MortgageLoan prior to May 10, 2023 (see Exhibit 34.45)

34.54      K-Star Asset Management LLC, as Special Servicer of the Wolverine PortfolioMortgage Loan on and after May 10, 2023 (Omitted. See Explanatory Notes.)

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

34.56      Wells Fargo Bank, National Association, asCustodian of the Wolverine Portfolio Mortgage Loan (see Exhibit 34.5)

34.57      Pentalpha Surveillance LLC, as Operating Advisor ofthe Wolverine Portfolio Mortgage Loan (see Exhibit 34.6)

34.58      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.9)

34.59      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the CIRE Equity Retail &Industrial Portfolio Mortgage Loan (see Exhibit 34.45)

34.60      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the CIRE Equity Retail &Industrial Portfolio Mortgage Loan prior to May 10, 2023 (see Exhibit 34.45)

34.61      K-Star Asset Management LLC, as Special Servicer of the CIRE Equity Retail& Industrial Portfolio Mortgage Loan on and after May 10, 2023 (Omitted.See Explanatory Notes.)

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

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

34.64      Pentalpha Surveillance LLC, as Operating Advisor ofthe CIRE Equity Retail & Industrial Portfolio Mortgage Loan (see Exhibit34.6)

34.65      Wells Fargo Bank, National Association, as PrimaryServicer of the 188 Spear Street Mortgage Loan (see Exhibit 34.1)

34.66      Rialto Capital Advisors, LLC, as Special Servicerof the 188 Spear Street Mortgage Loan (see Exhibit 34.39)

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

34.68      Wells Fargo Bank, National Association, asCustodian of the 188 Spear Street Mortgage Loan (see Exhibit 34.5)

34.69      Park Bridge Lender Services LLC, as Operating Advisorof the 188 Spear Street Mortgage Loan (see Exhibit 34.42)

34.70      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 188 Spear Street Mortgage Loan (see Exhibit 34.7)

34.71      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.9)

34.72      Wells Fargo Bank, National Association, as PrimaryServicer of The Chantilly Office Portfolio Mortgage Loan (see Exhibit 34.1)

34.73      Rialto Capital Advisors, LLC, as Special Servicerof The Chantilly Office Portfolio Mortgage Loan (see Exhibit 34.39)

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

34.75      Wells Fargo Bank, National Association, as Custodianof The Chantilly Office Portfolio Mortgage Loan (see Exhibit 34.5)

34.76      Pentalpha Surveillance LLC, as Operating Advisor ofThe Chantilly Office Portfolio Mortgage Loan (see Exhibit 34.6)

34.77      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of The Chantilly Office Portfolio Mortgage Loan (see Exhibit 34.7)

34.78      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.9)

35           Servicer compliance statements.

35.1        Wells Fargo Bank, National Association, as MasterServicer

35.2        Greystone Servicing Company LLC (as successor to C-IIIAsset Management LLC), as Special Servicer

35.3        Wells Fargo Bank, National Association, asCertificate Administrator

35.4        Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator

35.5        Wells Fargo Bank, National Association, as PrimaryServicer of the Nova Place Mortgage Loan (see Exhibit 35.1)

35.6        Greystone Servicing Company LLC (as successor toC-III Asset Management LLC), as Special Servicer of the Nova Place MortgageLoan (see Exhibit 35.2)

35.7        Wells Fargo Bank, National Association, as PrimaryServicer of the 450-460 Park Avenue South Mortgage Loan (see Exhibit 35.1)

35.8        Greystone Servicing Company LLC (as successor toC-III Asset Management LLC), as Special Servicer of the 450-460 Park AvenueSouth Mortgage Loan (see Exhibit 35.2)

35.9        Wells Fargo Bank, National Association, as PrimaryServicer of the El Con Center Mortgage Loan (see Exhibit 35.1)

35.10      Greystone Servicing Company LLC (as successor toC-III Asset Management LLC), as Special Servicer of the El Con Center MortgageLoan (see Exhibit 35.2)

35.11      Wells Fargo Bank, National Association, as PrimaryServicer of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan (seeExhibit 35.1)

35.12      Greystone Servicing Company LLC (as successor toC-III Asset Management LLC), as Special Servicer of the ExchangeRight NetLeased Portfolio #27 Mortgage Loan (see Exhibit 35.2)

35.13      Wells Fargo Bank, National Association, as PrimaryServicer of the Hilton at University Place Mortgage Loan (see Exhibit 35.1)

35.14      Rialto Capital Advisors, LLC, as Special Servicerof the Hilton at University Place Mortgage Loan

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

35.16      Midland Loan Services, a Division of PNC Bank, National Association, as SpecialServicer of the Patuxent Crossing Mortgage Loan prior to May 10, 2023 (Omitted.See Explanatory Notes.)  

35.17      K-Star Asset Management LLC, as Special Servicer of the Patuxent Crossing MortgageLoan on and after May 10, 2023 (Omitted. See Explanatory Notes.)

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

35.19      Midland Loan Services, a Division of PNC Bank, National Association, as SpecialServicer of the Wolverine Portfolio Mortgage Loan prior to May 10, 2023(Omitted. See Explanatory Notes.)  

35.20      K-Star Asset Management LLC, as Special Servicer of the Wolverine PortfolioMortgage Loan on and after May 10, 2023 (Omitted. See Explanatory Notes.)

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

35.22      Midland Loan Services, a Division of PNC Bank, National Association, as SpecialServicer of the CIRE Equity Retail & Industrial Portfolio Mortgage Loanprior to May 10, 2023 (Omitted. See Explanatory Notes.)  

35.23      K-Star Asset Management LLC, as Special Servicer of the CIRE Equity Retail& Industrial Portfolio Mortgage Loan on and after May 10, 2023 (Omitted.See Explanatory Notes.)

35.24      Wells Fargo Bank, National Association, as PrimaryServicer of the 188 Spear Street Mortgage Loan (see Exhibit 35.1)

35.25      Rialto Capital Advisors, LLC, as Special Servicerof the 188 Spear Street Mortgage Loan (see Exhibit 35.14)

35.26      Wells Fargo Bank, National Association, as PrimaryServicer of The Chantilly Office Portfolio Mortgage Loan (see Exhibit 35.1)

35.27      Rialto Capital Advisors, LLC, as Special Servicerof The Chantilly Office Portfolio Mortgage Loan (see Exhibit 35.14)

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

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

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

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

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

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

99.7        AgreementBetween Note Holders, dated as of June 14, 2019, by and between BarclaysCapital Real Estate Inc., as Initial Note A-1 Holder, Barclays Capital RealEstate Inc., as Initial Note A-2 Holder, and Barclays Capital Real Estate Inc.,as Initial Note A-3 Holder (filed as Exhibit 99.9 to the registrant’s CurrentReport on Form 8-K/A filed on August 21, 2019 under Commission File No.333-226486-06 and incorporated by reference herein).

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

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

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

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

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

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

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

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

 (b)  The exhibits required to be filed by theRegistrant pursuant to Item 601 of Regulation S-K are listed above.

(c)    Not Applicable.

 

**SIGNATURES**

Pursuant to the requirements of Section 13 or 15(d) of theSecurities Exchange Act of 1934, the registrant has duly caused this report tobe signed on its behalf by the undersigned, thereunto duly authorized.

Wells Fargo Commercial MortgageSecurities, Inc.(Depositor)

/s/ AnthonySfarra

AnthonySfarra, President

(senior officer in charge ofsecuritization of the depositor)

Date: March 14, 2024