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

 

1.       3650 REIT Loan Servicing LLC (the “**AssertingParty**”) is responsible for assessing compliance with the servicing criteriaapplicable to it under paragraph (d) of Item 1122 of Regulation AB, as of andfor the 12-month period ended December 31, 2021 (the “**Reporting Period**”),as set forth in **Appendix A** hereto. The transactions covered by thisreport, include commercial mortgage-asset-backed securities transactions, aslisted on **Exhibit 1** hereto, for which the Asserting Party served asspecial servicer, and that were registered with the Securities and ExchangeCommission pursuant to the Securities Act of 1933 (the “**Platform**”); 

 

2.       The Asserting Party has engagedcertain vendors, which are not servicers as defined in Item 1101(j) ofRegulation AB (the “**Vendors**”), to perform specific, limited or scriptedactivities, and the Asserting Party elects to take responsibility for assessingcompliance with the servicing criteria or portion of the servicing criteriaapplicable to such Vendors’ activities as set forth in Appendix A hereto;

 

3.       Except as set forth in paragraph 4below, the Asserting Party used the criteria set forth in paragraph (d) of Item1122 of Regulation AB to assess the compliance with the applicable servicingcriteria;

 

4.       The criteria listed in the columntitled “Inapplicable Servicing Criteria” on **Appendix A** hereto areinapplicable to the Asserting Party based on the activities it performs,directly or through its Vendors, with respect to the Platform;

 

5.       The Asserting Party has complied,in all material respects, with the applicable servicing criteria as of December31, 2021 and for the Reporting Period with respect to the Platform taken as awhole;

 

6.       The Asserting Party has notidentified and is not aware of any material instance of noncompliance by theVendors with the applicable servicing criteria as of December 31, 2021 and forthe Reporting Period with respect to the Platform taken as a whole;

 

7.       The Asserting Party has notidentified any material deficiency in its policies and procedures to monitorthe compliance by the Vendors with the applicable servicing criteria as ofDecember 31, 2021 and for the Reporting Period with respect to the Platformtaken as a whole; and

 

8.       Deloitte & Touche LLP, anindependent registered public accounting firm, has issued an attestation reporton the Asserting Party's assessment of compliance with the applicable servicingcriteria for the Reporting Period.

 

 

February 23, 2022

 

3650 REIT Loan Servicing LLC,

a Delaware limited liabilitycompany

 

By: /s/ Peter LaPointe

Name: Peter LaPointe

Title: Managing Partner

 

 

**Exhibit 1**

 

| **Pooling and Servicing Agreements** | **Applicable Certification Period**   |
|--------------------------------------|---------------------------------------|
| CSAIL 2019-C15                       | January 1, 2021 to December 31, 2021  |
| CSAIL 2019-C17                       | January 1, 2021 to December 31, 2021  |
| CSAIL 2020-C19                       | January 1, 2021 to December 31, 2021  |
| CSMC 2020-TMIC                       | January 1, 2021 to December 31, 2021  |
| CSAIL 2021-C20                       | March 1, 2021 to December 31, 2021    |
| ALEN 2021-ACEN                       | March 24, 2021 to December 31, 2021   |
| 3650R 2021-PF1                       | November 1, 2021 to December 31, 2021 |

 

 

 

| ** **                                                               | **APPENDIX  A**

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

** **

**Reference**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | ** **

** **

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

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

 

1122(d)(1)(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)(1)(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)(1)(iii)                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | Any requirements in the transaction  agreements to maintain a back-up servicer for the pool assets are maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |   | ** **

**X** |   |
|                                                                     |  

 

 

1122(d)(1)(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                      |   | **X4** |   |
|                                                                     |  

 

 

 

 

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.                                                                                                                                                                                                                                                                                                                | ** **

** ** | **X4** |   |
|                                                                     |  

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. |  

 

 

 

  |  

 

**X4** |   |
| ** **                                                               | **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.                                              | ** **

**X5** |   |   |
|                                                                     |  

 

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.                                                                                                                                                                                                                                                                                                                                                                                                                                                          | ** **

**X6**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |   |   |
|  

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.                                                                                                                                                                                                                                                                                                                                                                                                                |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | **X7** |   |
|  

 

 

 

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.                                                                                                                                                                            | ** **

** **                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | **X8** |   |
|  

 

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. Duringthe period of time addressed by this document, 3650 REIT Loan Servicing LLC wasnot servicing any REO properties; provided, however, in the event that 3650REIT Loan Servicing LLC services a REO asset it has policies and procedures inplace to service such asset in compliance with the applicable PSA and tosupervise outside vendors who are assisting on the servicing of such REO assetto ensure said outside vendors’ activities comply with 3650 REIT Loan ServicingLLC’s applicable policies and procedures. 3650 REIT Loan Servicing LLC haselected to take responsibility for assessing compliance with these servicingcriteria with respect to the activities of its third-party property managers.

 

**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, 2021 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;however, the related criteria is marked inapplicable as 3650 REIT LoanServicing LLC did not have instances/activity for the year ended December 31,2021, relating to the criteria.

 

**X4-** 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, 2021 relating to the criteria.

 

**X5-** 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.

 

**X6-** 3650 REIT Loan Servicing LLC performs the activitiesunder the criteria; however, 3650 REIT Loan Servicing LLC relies on outsidecounsel to collect, maintain, distribute, and (when applicable) return to theapplicable document custodian collateral and security on pool assets asrequired per the transaction agreements or mortgage loan documents. 

 

**X7-** 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, 2021 relating to the criteria.

 

**X8-** 3650 REIT Loan Servicing LLC to date has not collectedany payments on pool assets in that each applicable securitization’s masterservicer has to date collected, deposited, and applies all such payments.Primary responsibility for processing borrower payments rests with the MasterServicer. 3650 REIT Loan Servicing LLC may from time to time receive paymentson an exception basis related to services performed and fees charged as SpecialServicer related to Major Decisions, not related to payments on pool assets.