**UNITED STATESSECURITIES AND EXCHANGE COMMISSION**

**Washington, D.C. 20549**

**FORM 10-K**

(Mark One)

**x****  ANNUAL REPORT PURSUANT TO SECTION13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934**

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

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

**For the transition period from _____ to _____Commission file number of the issuing entity: 333-226486-07**

**Central Index Key Number of the issuing entity:0001780859**

**BANK 2019-BNK19**

**(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: 0001102113**

**Bank of America, NationalAssociation**

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

** **

**Central Index Key Number of the sponsor: 0001541557**

**Morgan Stanley Mortgage CapitalHoldings LLC**

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

** **

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

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

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

** **

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

**the issuing entity)** | **38-4123620**

**38-4123621**

**38-7221343**

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

**21045**

**(Zip Code)**

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

**(704) 374-6161**

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

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

 

 

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

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

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

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

Indicate by check mark whether the registrant has submittedelectronically every Interactive Data File required to be submitted pursuant toRule 405 of Regulation S-T (Section 232.405 of this chapter) during thepreceding 12 months (or for such shorter period that the registrant wasrequired to submit such files).

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                                                                                                       Acceleratedfiler                                     o

Non-acceleratedfiler          ⌧                                                                                                       Smaller reporting company                    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 alldocuments and reports required to be filed by Section 12, 13 or 15(d) of theSecurities Exchange Act of 1934 subsequent to the distribution of securitiesunder a plan confirmed by a court.  oYes oNo

Not applicable.

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

Not applicable.

**DOCUMENTS INCORPORATED BY REFERENCE**

** **

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

Not applicable.

 

** **

**EXPLANATORY NOTES**

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Waterford Lakes Town Center Mortgage Loan,which constituted approximately 6.9% of the asset pool of the issuing entity asof its cut-off date.  The Waterford Lakes Town Center Mortgage Loan is anasset of the issuing entity and is part of a loan combination that includes theWaterford Lakes Town Center Mortgage Loan and two other *pari passu*loans, which are not assets of the issuing entity. A *pari passu* portionof the loan combination was securitized in the GS Mortgage Securities Trust2019-GC39 transaction, Commission File Number 333-226082-02 (the “GSMS2019-GC39 Transaction”). This loan combination, including the WaterfordLakes Town Center Mortgage Loan, is being serviced and administered pursuant tothe pooling and servicing agreement for the GSMS 2019-GC39 Transaction, whichis incorporated by reference as Exhibit 4.2 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the 350 Bush Street Mortgage Loan, The AlhambraMortgage Loan and the Ford Factory Mortgage Loan, which constitutedapproximately 6.5%, 3.8% and 3.1%, respectively, of the asset pool of theissuing entity as of its cut-off date.  The 350 Bush Street Mortgage Loan,The Alhambra Mortgage Loan and the Ford Factory Mortgage Loan are each an assetof the issuing entity and are each part of a loan combination that includes the350 Bush Street Mortgage Loan, The Alhambra Mortgage Loan or the Ford FactoryMortgage Loan and one other *pari passu* loan, each of which is not anasset of the issuing entity. The other *pari passu* portion of each loancombination was securitized in the BANK 2019-BNK18 transaction, Commission FileNumber 333-228375-01 (the “BANK 2019-BNK18 Transaction”). These loan combinations,including the 350 Bush Street Mortgage Loan, The Alhambra Mortgage Loan and theFord Factory Mortgage Loan, are being serviced and administered pursuant to thepooling and servicing agreement for the BANK 2019-BNK18 Transaction, which isincorporated by reference as Exhibit 4.3 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Nova Place Mortgage Loan and the 450-460Park Avenue South Mortgage Loan, which constituted approximately 5.3% and 2.3%,respectively, of the asset pool of the issuing entity as of its cut-offdate.  The Nova Place Mortgage Loan and the 450-460 Park Avenue SouthMortgage Loan are each an asset of the issuing entity and are each part of aloan combination that includes the Nova Place Mortgage Loan or the 450-460 ParkAvenue South Mortgage Loan and one other *pari passu* loan, each of whichis not an asset of the issuing entity. The other *pari passu* portion ofeach loan combination was securitized in the Wells Fargo Commercial MortgageTrust 2019-C51 transaction, Commission File Number 333-226486-06 (the “WFCM2019-C51 Transaction”). These loan combinations, including the Nova PlaceMortgage Loan and the 450-460 Park Avenue South Mortgage Loan, are beingserviced and administered pursuant to the pooling and servicing agreement forthe WFCM 2019-C51 Transaction, which is incorporated by reference as Exhibit4.4 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 Moffett Towers - Buildings 3 & 4Mortgage Loan, which constituted approximately 3.8% of the asset pool of theissuing entity as of its cut-off date.  The Moffett Towers - Buildings 3& 4 Mortgage Loan is an asset of the issuing entity and is part of a loancombination that includes the Moffett Towers - Buildings 3 & 4 MortgageLoan, ten other *pari passu* loans and three subordinate companion loans,which are not assets of the issuing entity. A *pari passu* portion of theloan combination was securitized in the MFTII 2019-B3B4 Mortgage Trusttransaction (the “MFTII 2019-B3B4 Transaction”). This loan combination,including the Moffett Towers - Buildings 3 & 4 Mortgage Loan, is beingserviced and administered pursuant to the trust and servicing agreement for theMFTII 2019-B3B4 Transaction, which is incorporated by reference as Exhibit 4.5to 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 30 Hudson Yards Mortgage Loan, whichconstituted approximately 6.5% of the asset pool of the issuing entity as ofits cut-off date.  The 30 Hudson Yards Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the 30 HudsonYards Mortgage Loan, twenty-four other *pari passu* loans and threesubordinate companion loans, which are not assets of the issuing entity. A *paripassu* portion of the loan combination was securitized in the Hudson Yards2019-30HY Mortgage Trust transaction (the “Hudson Yards 2019-30HYTransaction”). This loan combination, including the 30 Hudson YardsMortgage Loan, is being serviced and administered pursuant to the trust andservicing agreement for the Hudson Yards 2019-30HY Transaction, which isincorporated by reference as Exhibit 4.6 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 Grand Canal Shoppes Mortgage Loan, whichconstituted approximately 7.7% of the asset pool of the issuing entity as ofits cut-off date.  The Grand Canal Shoppes Mortgage Loan is an asset ofthe issuing entity and is part of a loan combination that includes the GrandCanal Shoppes Mortgage Loan, twenty-one other *pari passu* loans and onesubordinate companion loan, which are not assets of the issuing entity. A *paripassu* portion of the loan combination was securitized in the Morgan StanleyCapital I Trust 2019-H7 transaction, Commission File Number 333-227446-05 (the“MSC 2019-H7 Transaction”). This loan combination, including the GrandCanal Shoppes Mortgage Loan, is being serviced and administered pursuant to thepooling and servicing agreement for the MSC 2019-H7 Transaction, which isincorporated by reference as Exhibit 4.7 to this Annual Report on Form 10-K.

The Exhibit Index describes exhibitsprovided by certain parties (in their capacities indicated on the ExhibitIndex) with respect to the Eleven Seventeen Perimeter Mortgage Loan and thePolo Towne Crossing SC Mortgage Loan, which constituted approximately 1.2% and1.1%, respectively, of the asset pool of the issuing entity as of its cut-offdate.  The Eleven Seventeen Perimeter Mortgage Loan and Polo TowneCrossing SC Mortgage Loan are each an asset of the issuing entity and are eachpart of a loan combination that includes (a) with respect to the ElevenSeventeen Perimeter Mortgage Loan, three other *pari passu* loans, whichare not assets of the issuing entity or (b) with respect to the Polo TowneCrossing SC Mortgage Loan, two other *pari passu* loans, which are notassets of the issuing entity.  These loan combinations were serviced under(a) with respect to the loan combination that includes the Eleven SeventeenPerimeter Mortgage Loan, the pooling and servicing agreement for the MSC2019-H7 Transaction and (b) with respect to the loan combination that includesthe Polo Towne Crossing SC Mortgage Loan, the Pooling and Servicing Agreementfor the issuing entity, prior to the closing of the securitization of a *paripassu* portion of the Eleven Seventeen Perimeter loan combination and the PoloTowne Crossing SC loan combination in the BANK 2019-BNK20 transaction,Commission File Number 333-227446-06 (the “BANK 2019-BNK20 Transaction”). After the closing of the BANK 2019-BNK20 Transaction on September 26, 2019,these loan combinations, including the Eleven Seventeen Perimeter Mortgage Loanand the Polo Towne Crossing SC Mortgage Loan were, and will continue to be,serviced and administered pursuant to the pooling and servicing agreement withrespect to the BANK 2019-BNK20 Transaction, which is incorporated by referenceas Exhibit 4.8 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.

Park Bridge Lender Services LLC isthe operating advisor of the mortgage loans serviced under the Pooling andServicing Agreement, the Waterford Lakes Town Center Mortgage Loan, the ElevenSeventeen Perimeter Mortgage Loan and the Polo Towne Crossing SC MortgageLoan.  As a result, Park Bridge Lender Services LLC is a servicingfunction participant in the capacities described above, because it is servicingmortgage loans that constituted 5% or more of the assets of the issuing entityas of its cut-off date. The assessments of compliance with applicable servicingcriteria and accountants’ attestation reports delivered by Park Bridge LenderServices LLC in the capacities described above are listed in the Exhibit Index.

LNR Partners, LLC is the specialservicer of the mortgage loans serviced under the Pooling and ServicingAgreement, the Eleven Seventeen Perimeter Mortgage Loan and the Polo TowneCrossing SC Mortgage Loan. As a result, LNR Partners, LLC is a “servicer” asdefined in Item 1108(a)(2)(iii) of Regulation AB, in the capacities describedabove, because it is servicing mortgage loans that constituted 10% or more ofthe assets 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 LNR Partners, LLC in thecapacities described above are listed in the Exhibit Index.

Midland Loan Services, a Divisionof PNC Bank, National Association is the primary servicer of the Grand CanalShoppes Mortgage Loan and the Waterford Lakes Town Center Mortgage Loan. As aresult, Midland Loan Services, a Division of PNC Bank, National Association isa “servicer” as defined in Item 1108(a)(2)(iii) of Regulation AB, in thecapacities described above, because it is servicing mortgage loans thatconstituted 10% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby Midland Loan Services, a Division of PNC Bank, National Association in thecapacities described above are listed in the Exhibit Index.

KeyBank National Association isthe special servicer of the Waterford Lakes Town Center Mortgage Loan and theprimary servicer of the Moffett Towers - Buildings 3 & 4 Mortgage Loan. Asa result, KeyBank 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 KeyBank National Association in thecapacities described above are listed in the Exhibit Index.

Wells Fargo Bank, NationalAssociation is the general master servicer and certificate administrator of themortgage loans serviced under the Pooling and Servicing Agreement and theprimary servicer of the 30 Hudson Yards Mortgage Loan, the 350 Bush StreetMortgage Loan, the Nova Place Mortgage Loan, The Alhambra Mortgage Loan, theFord Factory Mortgage Loan, the 450-460 Park Avenue South Mortgage Loan, theEleven Seventeen Perimeter Mortgage Loan and the Polo Towne Crossing SCMortgage Loan. As a result, Wells Fargo Bank, National Association  is a“servicer” as defined in Item 1108(a)(2)(iii) of Regulation AB, in thecapacities described above, because it is servicing mortgage loans thatconstituted 10% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby Wells Fargo Bank, National Association  in the capacities describedabove are listed in the Exhibit Index.

Wells Fargo Bank, NationalAssociation is the custodian of the Grand Canal Shoppes Mortgage Loan, theWaterford Lakes Town Center Mortgage Loan, the 350 Bush Street Mortgage Loan,the 30 Hudson Yards Mortgage Loan, the Nova Place Mortgage Loan, the MoffettTowers - Buildings 3 & 4 Mortgage Loan, The Alhambra Mortgage Loan, theFord Factory Mortgage Loan, the 450-460 Park Avenue South Mortgage Loan, theEleven Seventeen Perimeter Mortgage Loan and the Polo Towne Crossing SCMortgage Loan.  As a result, Wells Fargo Bank, National Association is a servicing function participant in the capacities described above, becauseit is servicing mortgage loans that constituted 5% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria and accountants’ attestation reports delivered byWells Fargo Bank, National Association  in the capacities described aboveare listed in the Exhibit Index.

Rialto Capital Advisors, LLC isthe special servicer of the 350 Bush Street Mortgage Loan, The AlhambraMortgage Loan and the Ford Factory Mortgage Loan. As a result, Rialto CapitalAdvisors, LLC is a “servicer” as defined in Item 1108(a)(2)(iii) of RegulationAB, in the capacities described above, because it is servicing mortgage loansthat constituted 10% or more of the assets of the issuing entity as of itscut-off date. The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby Rialto Capital Advisors, LLC in the capacities described above are listed inthe Exhibit Index.

Pentalpha Surveillance LLC is theoperating advisor of the Grand Canal Shoppes Mortgage Loan, the 350 Bush StreetMortgage Loan, the Nova Place Mortgage Loan, The Alhambra Mortgage Loan, theFord Factory Mortgage Loan and the 450-460 Park Avenue South MortgageLoan.  As a result, Pentalpha Surveillance LLC is a servicing functionparticipant in the capacities described above, because it is servicing mortgageloans that constituted 5% or more of the assets of the issuing entity as of itscut-off date. The assessments of compliance with applicable servicing criteriaand accountants’ attestation reports delivered by Pentalpha Surveillance LLC inthe capacities described above are listed in the Exhibit Index.

Greystone Servicing Company LLC(as successor to C-III Asset Management LLC) is the special servicer of the450-460 Park Avenue South Mortgage Loan and the Nova Place Mortgage Loan. These mortgage loans constitute more than 5%, but less than 10%, of the poolassets of the issuing entity.  Therefore, the Depositor included in thisAnnual Report on Form 10-K an assessment of compliance with applicableservicing criteria for Greystone Servicing Company LLC (as successor to C-IIIAsset Management LLC) and an accountants’ attestation report pursuant to Item1122 of Regulation AB because Greystone Servicing Company LLC (as successor toC-III Asset Management LLC) 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 ofGreystone Servicing Company LLC (as successor to C-III Asset Management LLC)because Greystone Servicing Company LLC (as successor to C-III Asset ManagementLLC) is an unaffiliated servicer servicing less than 10% of pool assets.

Situs Holdings, LLC is the specialservicer of the Grand Canal Shoppes Mortgage Loan, the 30 Hudson Yards MortgageLoan and the Moffett Towers - Buildings 3 & 4 Mortgage Loan. As a result,Situs Holdings, LLC is a “servicer” as defined in Item 1108(a)(2)(iii) ofRegulation AB, in the capacities described above, because it is servicingmortgage loans that constituted 10% or more of the assets of the issuing entityas of its cut-off date. The assessments of compliance with applicable servicingcriteria, accountants’ attestation reports and servicer compliance statementsdelivered by Situs Holdings, LLC in the capacities described above are listedin the Exhibit Index.

Wilmington Trust, NationalAssociation acts as trustee of  the mortgage loans serviced under thePooling and Servicing Agreement, the 350 Bush Street Mortgage Loan, TheAlhambra Mortgage Loan, the Ford Factory Mortgage Loan, the Nova Place MortgageLoan, the 450-460 Park Avenue South Mortgage Loan, the 30 Hudson Yards MortgageLoan, the Eleven Seventeen Perimeter Mortgage Loan and the Polo Towne CrossingSC Mortgage Loan.  Pursuant to the Pooling and Servicing Agreement, thepooling and servicing agreement for the BANK 2019-BNK18 Transaction, thepooling and servicing agreement for the WFCM 2019-C51 Transaction, the trustand servicing agreement for the Hudson Yards 2019-30HY Transaction and thepooling and servicing agreement for the BANK 2019-BNK20 Transaction, thetrustee is required to provide an assessment of compliance with applicableservicing criteria solely with respect to Item 1122(d)(2)(iii) of Regulation AB(regarding advances of funds or guarantees regarding collections, cash flows ordistributions, and any interest or other fees charged for such advances, aremade, reviewed and approved as specified in the transaction agreements).However, during the reporting period, the trustee did not perform any servicingfunction with respect to the servicing criteria specified in Item1122(d)(2)(iii) of Regulation AB.  The master servicer or the specialservicer, to the extent required, performed the servicing function identifiedwith respect to Item 1122(d)(2)(iii) of Regulation AB, and each such partyincluded Item 1122(d)(2)(iii) of Regulation AB in the assessment of compliancewith applicable servicing criteria and accountant’s attestation report for thesubject transaction.  As a result, this Annual Report on Form 10-K doesnot include an assessment of compliance with applicable servicing criteria ofthe trustee. One or more other servicers of  the mortgage loans servicedunder the Pooling and Servicing Agreement, the 350 Bush Street Mortgage Loan,The Alhambra Mortgage Loan, the Ford Factory Mortgage Loan, the Nova Place MortgageLoan, the 450-460 Park Avenue South Mortgage Loan, the 30 Hudson Yards MortgageLoan, the Eleven Seventeen Perimeter Mortgage Loan and the Polo Towne CrossingSC Mortgage Loan have delivered one or more assessments of compliance withrespect to Item 1122(d)(2)(iii) of Regulation AB.

Wells Fargo Bank, NationalAssociation acts as trustee of the Waterford Lakes Town Center Mortgage Loan,the Moffett Towers - Buildings 3 & 4 Mortgage Loan and the Grand CanalShoppes Mortgage Loan.  Pursuant to the pooling and servicing agreementfor the GSMS 2019-GC39 Transaction, the trust and servicing agreement for theMFTII 2019-B3B4 Transaction and the pooling and servicing agreement for the MSC2019-H7 Transaction, the trustee is required to provide an assessment ofcompliance with applicable servicing criteria solely with respect to Item1122(d)(2)(iii) of Regulation AB (regarding advances of funds or guaranteesregarding collections, cash flows or distributions, and any interest or otherfees charged for such advances, are made, reviewed and approved as specified inthe transaction agreements). However, during the reporting period, the trusteedid not perform any servicing function with respect to the servicing criteriaspecified in Item 1122(d)(2)(iii) of Regulation AB.  The master serviceror the special servicer, to the extent required, performed the servicingfunction identified with respect to Item 1122(d)(2)(iii) of Regulation AB, andeach such party included Item 1122(d)(2)(iii) of Regulation AB in the assessmentof compliance with applicable servicing criteria and accountant’s attestationreport for the subject transaction.  As a result, this Annual Report onForm 10-K does not include an assessment of compliance with applicableservicing criteria of the trustee. One or more other servicers of the WaterfordLakes Town Center Mortgage Loan, the Moffett Towers - Buildings 3 & 4Mortgage Loan and the Grand Canal Shoppes Mortgage Loan have delivered one ormore assessments of compliance with respect to Item 1122(d)(2)(iii) ofRegulation 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 general master servicer under the Pooling andServicing Agreement and the primary servicer of the 30 Hudson Yards MortgageLoan, the 350 Bush Street Mortgage Loan, the Nova Place Mortgage Loan, TheAlhambra Mortgage Loan, the Ford Factory Mortgage Loan, the 450-460 Park AvenueSouth Mortgage Loan, the Eleven Seventeen Perimeter Mortgage Loan and the PoloTowne Crossing SC Mortgage Loan to remit tax payments received from the escrowaccounts of borrowers to local taxing authorities, to report tax amounts due,to verify tax parcel information, and to verify non-escrow tax payments. Theseservicing functions are included within the servicing criteria set forth inItems 1122(d)(4)(xi) and 1122(d)(4)(xii) of Regulation AB.  Therefore,under the principles-based definition of “servicer” set forth in Item 1101(j)of Regulation AB that looks to the functions that an entity performs, thisvendor is a “servicers” for the purposes of Item 1122 of Regulation AB.  *See*Compliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

This Annual Report on Form 10-Kincludes an assessment of compliance with applicable servicing criteria,accountants’ attestation report and servicer compliance statement fromComputershare Trust Company, National Association (“CTCNA”).  CTCNAwas 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)).

Theassessments of compliance with applicable servicing criteria, accountants’attestation reports and servicer compliance statements of the certificateadministrator of the Waterford Lakes Town Center Mortgage Loan, the 350 BushStreet Mortgage Loan, The Alhambra Mortgage Loan, the Ford Factory MortgageLoan, the Nova Place Mortgage Loan, the 450-460 Park Avenue South MortgageLoan, the Moffett Towers - Buildings 3 & 4 Mortgage Loan, the 30 HudsonYards Mortgage Loan, the Grand Canal Shoppes Mortgage Loan, the ElevenSeventeen Perimeter Mortgage Loan and the Polo Towne Crossing SC Mortgage Loanare omitted from this Annual Report on Form 10-K as the certificateadministrator pursuant to the related pooling and servicing agreement or trustand servicing agreement does not perform any activities that address servicingcriteria with respect to the issuing entity and because they are each not a“servicer” that meets the criteria in Item 1108(a)(2)(i) through (iii) ofRegulation AB.

With respect to the *pari passu*loan combinations that include the Nova Place Mortgage Loan and the 450-460Park Avenue South Mortgage Loan, the servicer compliance statements ofGreystone Servicing Company LLC (as successor to C-III Asset Management LLC) asspecial servicer of the Nova Place Mortgage Loan and the 450-460 Park AvenueSouth Mortgage Loan, listed on the Exhibit Index are omitted from this AnnualReport on Form 10-K as they are not required by Item 1123 of Regulation AB tobe included on this Annual Report on Form 10-K because it is an unaffiliatedparty that 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 Beneficial Ownersand 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 Derivatives Instruments(Financial Information).**

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

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

The registrant knows of no materialpending legal proceeding involving the trust or any party related to the trust,other than routine litigation incidental to the duties of those respectiveparties, and the following, with respect to Wells Fargo Bank, NationalAssociation, as certificate administrator, as trustee and as custodian.

In December 2014, Phoenix Light SF Limited (Phoenix Light)and certain related entities filed a complaint in the United States DistrictCourt for the Southern District of New York alleging claims against Wells FargoBank, N.A., in its capacity as trustee for a number of residentialmortgage-backed securities (RMBS) trusts. Complaints raising similarallegations have been filed by Commerzbank AG in the Southern District of NewYork, IKB International and IKB Deutsche Industriebank (together, IKB) in NewYork state court, and Park Royal I LLC and Park Royal II LLC in New York statecourt. In each case, the plaintiffs allege that Wells Fargo Bank, N.A., astrustee, 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 August 8, 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 Waterford Lakes Town CenterMortgage Loan, which is being serviced and administered pursuant to the poolingand servicing agreement for the GSMS 2019-GC39 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 GSMS 2019-GC39 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 GSMS2019-GC39 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 350 Bush Street Mortgage Loan,The Alhambra Mortgage Loan and the Ford Factory Mortgage Loan, which are beingserviced and administered pursuant to the pooling and servicing agreement forthe BANK 2019-BNK18 Transaction, are attached hereto under Item 15 to thisAnnual Report on Form 10-K. Attached as Exhibit Z to the pooling and servicingagreement for the BANK 2019-BNK18 Transaction incorporated by reference asExhibit 4.3 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the BANK 2019-BNK18Transaction 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 Nova Place Mortgage Loan and the450-460 Park Avenue South Mortgage Loan, which are being serviced andadministered pursuant to the pooling and servicing agreement for the WFCM2019-C51 Transaction, are attached hereto under Item 15 to this Annual Reporton Form 10-K. Attached as Exhibit AA to the pooling and servicing agreement forthe WFCM 2019-C51 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 WFCM 2019-C51 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 Moffett Towers - Buildings 3& 4 Mortgage Loan, which is being serviced and administered pursuant to thetrust and servicing agreement for the MFTII 2019-B3B4 Transaction, are attachedhereto under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit Lto the trust and servicing agreement for the MFTII 2019-B3B4 Transactionincorporated by reference as Exhibit 4.5 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theMFTII 2019-B3B4 Transaction responsible for each applicable servicing criteriaset 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 30 Hudson Yards Mortgage Loan,which is being serviced and administered pursuant to the trust and servicingagreement for the Hudson Yards 2019-30HY Transaction, are attached hereto underItem 15 to this Annual Report on Form 10-K. Attached as Schedule I to the trustand servicing agreement for the Hudson Yards 2019-30HY 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 HudsonYards 2019-30HY Transaction responsible for each applicable servicing criteriaset 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 Grand Canal Shoppes MortgageLoan, which is being serviced and administered pursuant to the pooling andservicing agreement for the MSC 2019-H7 Transaction, are attached hereto underItem 15 to this Annual Report on Form 10-K. Attached as Exhibit AA to thepooling and servicing agreement for the MSC 2019-H7 Transaction incorporated byreference as Exhibit 4.7 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the MSC2019-H7 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicing criteriafor asset-backed securities and related attestation reports on such assessmentsof compliance with respect to the Eleven Seventeen Perimeter Mortgage Loan andthe Polo Towne Crossing SC Mortgage Loan, which are being serviced andadministered pursuant to the pooling and servicing agreement for the BANK2019-BNK20 Transaction, are attached hereto under Item 15 to this Annual Reporton Form 10-K. Attached as Exhibit Z to the pooling and servicing agreement forthe BANK 2019-BNK20 Transaction incorporated by reference as Exhibit 4.8 tothis Annual Report on Form 10-K is a chart identifying the entitiesparticipating in a servicing function for the BANK 2019-BNK20 Transactionresponsible for each applicable servicing criteria set forth in Item 1122(d).

**Item1123 of Regulation AB, Servicer Compliance Statement.**

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

**PART IV**

**Item 15. Exhibits 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 August 1, 2019, among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as General Master Servicer, LNR Partners, LLC, as General SpecialServicer, National Cooperative Bank, N.A., as NCB Master Servicer and as NCBSpecial Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator, Wilmington Trust, National Association, as Trustee, and ParkBridge Lender Services LLC, as Operating Advisor and as Asset RepresentationsReviewer (filed as Exhibit 4.1 to the registrant’s Current Report on Form 8-K/Afiled on August 20, 2019 under Commission File No. 333-226486-07 andincorporated by reference herein).

4.2          Pooling and Servicing Agreement, dated as of May 1, 2019,by and among GS Mortgage Securities Corporation II, as Depositor, Midland LoanServices, a Division of PNC Bank, National Association, as Master Servicer,KeyBank National Association, as Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator and Trustee, and Park Bridge LenderServices LLC, as Operating Advisor and Asset Representations Reviewer (filed asExhibit 4.3 to the registrant’s Current Report on Form 8-K filed on August 8,2019 under Commission File No. 333-226486-07 and incorporated by referenceherein).

4.3          Pooling and Servicing Agreement, dated as of May 1, 2019,by and among Banc of America Merrill Lynch Commercial Mortgage Inc., asDepositor, Wells Fargo Bank, National Association, as General Master Servicer,Rialto Capital Advisors, LLC, as General Special Servicer, National CooperativeBank, N.A., as NCB Master Servicer and NCB Special Servicer, Wells Fargo Bank,National Association, as Certificate Administrator, Wilmington Trust, NationalAssociation, as Trustee, and Pentalpha Surveillance LLC, as Operating Advisorand Asset Representations Reviewer (filed as Exhibit 4.4 to the registrant’sCurrent Report on Form 8-K filed on August 8, 2019 under Commission File No.333-226486-07 and incorporated by reference herein).

4.4          Pooling and Servicing Agreement, dated as of July 1,2019, by and among Wells Fargo Commercial Mortgage Securities, Inc., asDepositor, Wells Fargo Bank, National Association, as Master Servicer, C-IIIAsset Management LLC, as Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator, Wilmington Trust, NationalAssociation, as Trustee, and Pentalpha Surveillance LLC, as Operating Advisorand Asset Representations Reviewer (filed as Exhibit 4.6 to the registrant’sCurrent Report on Form 8-K filed on August 8, 2019 under Commission File No.333-226486-07 and incorporated by reference herein).

4.5          Trust and Servicing Agreement, dated as of July 11, 2019,by and among Barclays Commercial Mortgage Securities LLC, as Depositor, KeyBankNational Association, as Servicer, Situs Holdings, LLC, as Special Servicer,Wells Fargo Bank, National Association, as Certificate Administrator andTrustee (filed as Exhibit 4.7 to the registrant’s Current Report on Form 8-Kfiled on August 8. 2019 under Commission File No. 333-226486-07 andincorporated by reference herein).

4.6          Trustand Servicing Agreement, dated as of July 6, 2019, by and among DeutscheMortgage & Asset Receiving Corporation, as Depositor, Wells Fargo Bank,National Association, as Master Servicer, Situs Holdings, LLC, as SpecialServicer, Wilmington Trust, National Association, as Trustee, Wells Fargo Bank,National Association, as Certificate Administrator, Paying Agent and Custodian(filed as Exhibit 4.5 to the registrant’s Current Report on Form 8-K filed onAugust 8, 2019 under Commission File No. 333-226486-07 and incorporated byreference herein).

4.7          Pooling and Servicing Agreement, dated as of July 1,2019, by and among Morgan Stanley Capital I Inc., as Depositor, Midland LoanServices, a Division of PNC Bank, National Association, as Master Servicer, LNRPartners, LLC, as Special Servicer, Wells Fargo Bank, National Association, asCertificate Administrator and Trustee, and Pentalpha Surveillance LLC, asOperating Advisor and Asset Representations Reviewer (filed as Exhibit 4.2 tothe registrant’s Current Report on Form 8-K filed on August 8, 2019 underCommission File No. 333-226486-07 and incorporated by reference herein).

4.8          Pooling and Servicing Agreement, dated as of September 1,2019, between Morgan Stanley Capital I Inc., as Depositor, Wells Fargo Bank,National Association, as General Master Servicer, Midland Loan Services, a Divisionof PNC Bank, National Association, as General Special Servicer, NationalCooperative Bank, N.A., as NCB Master Servicer and as NCB Special Servicer,Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Park Bridge LenderServices LLC, as Operating Advisor and as Asset Representations Reviewer (filedas Exhibit 4.1 to the registrant’s Current Report on Form 8-K filed on October1, 2019 under Commission File No. 333-226486-07 and incorporated by referenceherein).

4.9          Agreement Between Noteholders, dated as of July 3, 2019,between Morgan Stanley Bank, N.A., as Note A-1 Holder, Wells Fargo Bank,National Association, as Note A-2 Holder, JPMorgan Chase Bank, NationalAssociation, as Note A-3 Holder, Goldman Sachs Bank USA, as Note A-4 Holder,and CPPIB Credit Investments II Inc., as Note B Holder (filed as Exhibit 4.8 tothe registrant’s Current Report on Form 8-K filed on August 8, 2019 underCommission File No. 333-226486-07 and incorporated by reference herein).

4.10        Agreement Between Noteholders, dated as of May 23, 2019,by and among Goldman Sachs Bank USA, as Initial Note A-1-A Holder and InitialNote A-1-B Holder, and Bank of America, N.A., as Initial Note A-2-A Holder andInitial Note A-2-B Holder (filed as Exhibit 4.9 to the registrant’s CurrentReport on Form 8-K filed on August 8, 2019 under Commission File No.333-226486-07 and incorporated by reference herein).

4.11        Agreement Between Note Holders, dated as of May 31, 2019,by and between Wells Fargo Bank, National Association, as Initial Note A-1Holder, Wells Fargo Bank, National Association, as Initial Note A-2 Holder, andWells Fargo Bank, National Association, as Initial Note A-3 Holder (filed asExhibit 4.10 to the registrant’s Current Report on Form 8-K filed on August 8,2019 under Commission File No. 333-226486-07 and incorporated by referenceherein).

4.12        Co-Lender Agreement, dated as of July 6, 2019, by andbetween Deutsche Bank AG, New York Branch, as an Initial Note A Holder, WellsFargo Bank, National Association, as an Initial Note A Holder, Goldman SachsBank USA, as an Initial Note A Holder, Deutsche Bank AG, New York Branch, asInitial Note B-1 Holder, Goldman Sachs Bank USA, as Initial Note B-2 Holder,and Wells Fargo Bank, National Association, as Initial Note B-3 Holder (filedas Exhibit 4.11 to the registrant’s Current Report on Form 8-K filed on August8, 2019 under Commission File No. 333-226486-07 and incorporated by referenceherein).

4.13        Agreement Between Note Holders, dated as of July 11,2019, by and between Wells Fargo Bank, National Association, as Initial NoteA-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 (filedas Exhibit 4.12 to the registrant’s Current Report on Form 8-K filed on August8, 2019 under Commission File No. 333-226486-07 and incorporated by referenceherein).

4.14        Co-Lender Agreement, dated as of July 11, 2019, by andbetween Barclays Bank PLC, as Note A-1-A and Note B-1 Holder, Barclays CapitalReal Estate Inc., as Initial Note A-1-B Holder, Initial Note A-1-D Holder andInitial Note A-1-E Holder, Bank of America, N.A., as Note A-1-C Holder,Deutsche Bank AG, New York Branch, as Initial Note A-2-A Holder, Initial NoteA-2-B Holder, Initial Note A-2-C Holder and Initial Note B-2 Holder, and GoldmanSachs Bank USA, as Initial Note A-3-A Holder, Initial Note A-3-B Holder,Initial Note A-3-C Holder and Initial Note B-3 Holder (filed as Exhibit 4.13 tothe registrant’s Current Report on Form 8-K filed on August 8, 2019 underCommission File No. 333-226486-07 and incorporated by reference herein).

4.15        AgreementBetween Note Holders, dated as of May 31, 2019, by and between Wells FargoBank, National Association, as Initial Note A-1 Holder, Wells Fargo Bank,National Association, as Initial Note A-2 Holder, and Wells Fargo Bank,National Association, as Initial Note A-3 Holder (filed as Exhibit 4.14 to theregistrant’s Current Report on Form 8-K filed on August 8, 2019 underCommission File No. 333-226486-07 and incorporated by reference herein).

4.16        Agreement Between Note Holders, dated as of March 29,2019, by and between Bank of America, N.A., as Initial Note A-1 Holder, andBank of America, N.A., as Initial Note A-2 Holder (filed as Exhibit 4.15 to theregistrant’s Current Report on Form 8-K filed on August 8, 2019 underCommission File No. 333-226486-07 and incorporated by reference herein).

4.17        Agreement Between Note Holders, dated as of July 11,2019, by and between Wells Fargo Bank, National Association, as Initial NoteA-1 Holder, and Wells Fargo Bank, National Association, as Initial Note A-2Holder (filed as Exhibit 4.16 to the registrant’s Current Report on Form 8-Kfiled on August 8, 2019 under Commission File No. 333-226486-07 andincorporated by reference herein).

4.18        Agreement Between Note Holders, dated as of July 25, 2019,by and between Morgan Stanley Bank, N.A., as Initial Note A-1 Holder, MorganStanley Bank, N.A., as Initial Note A-2 Holder, Morgan Stanley Bank, N.A., asInitial Note A-3 Holder, Morgan Stanley Bank, N.A., as Initial Note A-4 Holder,and Morgan Stanley Mortgage Capital Holdings LLC, as Initial Agent (filed asExhibit 4.17 to the registrant’s Current Report on Form 8-K filed on August 8,2019 under Commission File No. 333-226486-07 and incorporated by referenceherein).

4.19        Agreement Between Note Holders, dated as of August 8,2019, by and between Morgan Stanley Bank, N.A., as Initial Note A-1 Holder,Morgan Stanley Bank, N.A., as Initial Note A-2 Holder, Morgan Stanley Bank,N.A., as Initial Note A-3 Holder, and Morgan Stanley Mortgage Capital HoldingsLLC, as Initial Agent (filed as Exhibit 4.18 to the registrant’s Current Reporton Form 8-K filed on August 8, 2019 under Commission File No. 333-226486-07 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 GeneralMaster Servicer

33.2        National Cooperative Bank, N.A., as NCB MasterServicer

33.3        LNR Partners, LLC, as General Special Servicer

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

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

33.6        Wells Fargo Bank, National Association, asCertificate Administrator

33.7        Wells Fargo Bank, National Association, asCustodian

33.8        Park Bridge Lender Services LLC, as OperatingAdvisor

33.9        CoreLogic Solutions, LLC, as Servicing FunctionParticipant

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

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

33.12      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Waterford Lakes Town CenterMortgage Loan

33.13      KeyBank National Association, as Special Servicerof the Waterford Lakes Town Center Mortgage Loan

33.14      Wells Fargo Bank, National Association, as Trustee of the Waterford Lakes TownCenter Mortgage Loan (Omitted. See Explanatory Notes.)

33.15      Wells Fargo Bank, National Association, asCustodian of the Waterford Lakes Town Center Mortgage Loan (see Exhibit 33.7)

33.16      Park Bridge Lender Services LLC, as OperatingAdvisor of the Waterford Lakes Town Center Mortgage Loan (see Exhibit 33.8)

33.17       Computershare Trust Company, National Association, asServicing Function Participant for the Custodian (see Exhibit 33.11)

33.18      Wells Fargo Bank, National Association, as PrimaryServicer of the 350 Bush Street Mortgage Loan (see Exhibit 33.1)

33.19      Rialto Capital Advisors, LLC, as Special Servicerof the 350 Bush Street Mortgage Loan

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

33.21      Wells Fargo Bank, National Association, asCustodian of the 350 Bush Street Mortgage Loan (see Exhibit 33.7)

33.22      Pentalpha Surveillance LLC, as Operating Advisorof the 350 Bush Street Mortgage Loan

33.23      CoreLogic Solutions, LLC, as Servicing Function Participantof the 350 Bush Street Mortgage Loan (see Exhibit 33.9)

33.24      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

33.25      Wells Fargo Bank, National Association, as PrimaryServicer of The Alhambra Mortgage Loan (see Exhibit 33.1)

33.26      Rialto Capital Advisors, LLC, as Special Servicerof The Alhambra Mortgage Loan (see Exhibit 33.19)

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

33.28      Wells Fargo Bank, National Association, asCustodian of The Alhambra Mortgage Loan (see Exhibit 33.7)

33.29      Pentalpha Surveillance LLC, as Operating Advisorof The Alhambra Mortgage Loan (see Exhibit 33.22)

33.30      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of The Alhambra Mortgage Loan (see Exhibit 33.9)

33.31      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

33.32      Wells Fargo Bank, National Association, as PrimaryServicer of the Ford Factory Mortgage Loan (see Exhibit 33.1)

33.33      Rialto Capital Advisors, LLC, as Special Servicerof the Ford Factory Mortgage Loan (see Exhibit 33.19)

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

33.35      Wells Fargo Bank, National Association, asCustodian of the Ford Factory Mortgage Loan (see Exhibit 33.7)

33.36      Pentalpha Surveillance LLC, as Operating Advisorof the Ford Factory Mortgage Loan (see Exhibit 33.22)

33.37      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Ford Factory Mortgage Loan (see Exhibit 33.9)

33.38      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

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

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

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

33.42      Wells Fargo Bank, National Association, asCustodian of the Nova Place Mortgage Loan (see Exhibit 33.7)

33.43      Pentalpha Surveillance LLC, as Operating Advisorof the Nova Place Mortgage Loan (see Exhibit 33.22)

33.44      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Nova Place Mortgage Loan (see Exhibit 33.9)

33.45      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

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

33.47      Greystone Servicing Company LLC (as successor toC-III Asset Management LLC), as Special Servicer of the 450-460 Park AvenueSouth Mortgage Loan (see Exhibit 33.40)

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

33.49      Wells Fargo Bank, National Association, asCustodian of the 450-460 Park Avenue South Mortgage Loan (see Exhibit 33.7)

33.50      Pentalpha Surveillance LLC, as Operating Advisorof the 450-460 Park Avenue South Mortgage Loan (see Exhibit 33.22)

33.51      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 450-460 Park Avenue South Mortgage Loan (see Exhibit 33.9)

33.52      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

33.53      KeyBank National Association, as Primary Servicerof the Moffett Towers - Buildings 3 & 4 Mortgage Loan (see Exhibit 33.13)

33.54      Situs Holdings, LLC, as Special Servicer of theMoffett Towers - Buildings 3 & 4 Mortgage Loan

33.55      Wells Fargo Bank, National Association, as Trustee of the Moffett Towers -Buildings 3 & 4 Mortgage Loan (Omitted. See Explanatory Notes.)

33.56      Wells Fargo Bank, National Association, asCustodian of the Moffett Towers - Buildings 3 & 4 Mortgage Loan (seeExhibit 33.7)

33.57      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

33.58      Wells Fargo Bank, National Association, as PrimaryServicer of the 30 Hudson Yards Mortgage Loan (see Exhibit 33.1)

33.59      Situs Holdings, LLC, as Special Servicer of the 30Hudson Yards Mortgage Loan (see Exhibit 33.54)

33.60      Wilmington Trust, National Association, as Trustee of the 30 Hudson YardsMortgage Loan (Omitted. See Explanatory Notes.)

33.61      Wells Fargo Bank, National Association, asCustodian of the 30 Hudson Yards Mortgage Loan (see Exhibit 33.7)

33.62      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 30 Hudson Yards Mortgage Loan (see Exhibit 33.9)

33.63      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

33.64      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Grand Canal Shoppes MortgageLoan (see Exhibit 33.12)

33.65      Situs Holdings, LLC, as Special Servicer of theGrand Canal Shoppes Mortgage Loan (see Exhibit 33.54)

33.66      Wells Fargo Bank, National Association, as Trustee of the Grand Canal ShoppesMortgage Loan (Omitted. See Explanatory Notes.)

33.67      Wells Fargo Bank, National Association, asCustodian of the Grand Canal Shoppes Mortgage Loan (see Exhibit 33.7)

33.68      Pentalpha Surveillance LLC, as Operating Advisorof the Grand Canal Shoppes Mortgage Loan (see Exhibit 33.22)

33.69      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

33.70      Wells Fargo Bank, National Association, as PrimaryServicer of the Eleven Seventeen Perimeter Mortgage Loan (see Exhibit 33.1)

33.71      LNR Partners, LLC, as Special Servicer of theEleven Seventeen Perimeter Mortgage Loan (see Exhibit 33.3)

33.72      Wilmington Trust, National Association, as Trustee of the Eleven SeventeenPerimeter Mortgage Loan (Omitted. See Explanatory Notes.)

33.73      Wells Fargo Bank, National Association, asCustodian of the Eleven Seventeen Perimeter Mortgage Loan (see Exhibit 33.7)

33.74      Park Bridge Lender Services LLC, as OperatingAdvisor of the Eleven Seventeen Perimeter Mortgage Loan (see Exhibit 33.8)

33.75      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Eleven Seventeen Perimeter Mortgage Loan (see Exhibit 33.9)

33.76      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

33.77      Wells Fargo Bank, National Association, as PrimaryServicer of the Polo Towne Crossing SC Mortgage Loan (see Exhibit 33.1)

33.78      LNR Partners, LLC, as Special Servicer of the PoloTowne Crossing SC Mortgage Loan (see Exhibit 33.3)

33.79      Wilmington Trust, National Association, as Trustee of the Polo Towne CrossingSC Mortgage Loan (Omitted. See Explanatory Notes.)

33.80      Wells Fargo Bank, National Association, asCustodian of the Polo Towne Crossing SC Mortgage Loan (see Exhibit 33.7)

33.81      Park Bridge Lender Services LLC, as OperatingAdvisor of the Polo Towne Crossing SC Mortgage Loan (see Exhibit 33.8)

33.82      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Polo Towne Crossing SC Mortgage Loan (see Exhibit 33.9)

33.83      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

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

34.1        Wells Fargo Bank, National Association, as GeneralMaster Servicer

34.2        National Cooperative Bank, N.A., as NCB MasterServicer

34.3        LNR Partners, LLC, as General Special Servicer

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

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

34.6        Wells Fargo Bank, National Association, asCertificate Administrator

34.7        Wells Fargo Bank, National Association, asCustodian

34.8        Park Bridge Lender Services LLC, as OperatingAdvisor

34.9        CoreLogic Solutions, LLC, as Servicing FunctionParticipant

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

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

34.12      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Waterford Lakes Town CenterMortgage Loan

34.13      KeyBank National Association, as Special Servicerof the Waterford Lakes Town Center Mortgage Loan

34.14      Wells Fargo Bank, National Association, as Trustee of the Waterford Lakes TownCenter Mortgage Loan (Omitted. See Explanatory Notes.)

34.15      Wells Fargo Bank, National Association, asCustodian of the Waterford Lakes Town Center Mortgage Loan (see Exhibit 34.7)

34.16      Park Bridge Lender Services LLC, as OperatingAdvisor of the Waterford Lakes Town Center Mortgage Loan (see Exhibit 34.8)

34.17      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

34.18      Wells Fargo Bank, National Association, as PrimaryServicer of the 350 Bush Street Mortgage Loan (see Exhibit 34.1)

34.19      Rialto Capital Advisors, LLC, as Special Servicerof the 350 Bush Street Mortgage Loan

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

34.21      Wells Fargo Bank, National Association, asCustodian of the 350 Bush Street Mortgage Loan (see Exhibit 34.7)

34.22      Pentalpha Surveillance LLC, as Operating Advisorof the 350 Bush Street Mortgage Loan

34.23      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 350 Bush Street Mortgage Loan (see Exhibit 34.9)

34.24      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

34.25      Wells Fargo Bank, National Association, as PrimaryServicer of The Alhambra Mortgage Loan (see Exhibit 34.1)

34.26      Rialto Capital Advisors, LLC, as Special Servicerof The Alhambra Mortgage Loan (see Exhibit 34.19)

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

34.28      Wells Fargo Bank, National Association, asCustodian of The Alhambra Mortgage Loan (see Exhibit 34.7)

34.29      Pentalpha Surveillance LLC, as Operating Advisorof The Alhambra Mortgage Loan (see Exhibit 34.22)

34.30      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of The Alhambra Mortgage Loan (see Exhibit 34.9)

34.31      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

34.32      Wells Fargo Bank, National Association, as PrimaryServicer of the Ford Factory Mortgage Loan (see Exhibit 34.1)

34.33      Rialto Capital Advisors, LLC, as Special Servicerof the Ford Factory Mortgage Loan (see Exhibit 34.19)

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

34.35      Wells Fargo Bank, National Association, asCustodian of the Ford Factory Mortgage Loan (see Exhibit 34.7)

34.36      Pentalpha Surveillance LLC, as Operating Advisorof the Ford Factory Mortgage Loan (see Exhibit 34.22)

34.37      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Ford Factory Mortgage Loan (see Exhibit 34.9)

34.38      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

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

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

34.41      Wilmington Trust, National Association, as Trustee of the Nova Place Mortgage Loan(Omitted. See Explanatory Notes.)

34.42      Wells Fargo Bank, National Association, asCustodian of the Nova Place Mortgage Loan (see Exhibit 34.7)

34.43      Pentalpha Surveillance LLC, as Operating Advisorof the Nova Place Mortgage Loan (see Exhibit 34.22)

34.44      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Nova Place Mortgage Loan (see Exhibit 34.9)

34.45      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

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

34.47      Greystone Servicing Company LLC (as successor toC-III Asset Management LLC), as Special Servicer of the 450-460 Park AvenueSouth Mortgage Loan (see Exhibit 34.40)

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

34.49      Wells Fargo Bank, National Association, asCustodian of the 450-460 Park Avenue South Mortgage Loan (see Exhibit 34.7)

34.50      Pentalpha Surveillance LLC, as Operating Advisorof the 450-460 Park Avenue South Mortgage Loan (see Exhibit 34.22)

34.51      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 450-460 Park Avenue South Mortgage Loan (see Exhibit 34.9)

34.52      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

34.53      KeyBank National Association, as Primary Servicerof the Moffett Towers - Buildings 3 & 4 Mortgage Loan (see Exhibit 34.13)

34.54      Situs Holdings, LLC, as Special Servicer of theMoffett Towers - Buildings 3 & 4 Mortgage Loan

34.55      Wells Fargo Bank, National Association, as Trustee of the Moffett Towers -Buildings 3 & 4 Mortgage Loan (Omitted. See Explanatory Notes.)

34.56      Wells Fargo Bank, National Association, asCustodian of the Moffett Towers - Buildings 3 & 4 Mortgage Loan (seeExhibit 34.7)

34.57      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

34.58      Wells Fargo Bank, National Association, as PrimaryServicer of the 30 Hudson Yards Mortgage Loan (see Exhibit 34.1)

34.59      Situs Holdings, LLC, as Special Servicer of the 30Hudson Yards Mortgage Loan (see Exhibit 34.54)

34.60      Wilmington Trust, National Association, as Trustee of the 30 Hudson YardsMortgage Loan (Omitted. See Explanatory Notes.)

34.61      Wells Fargo Bank, National Association, asCustodian of the 30 Hudson Yards Mortgage Loan (see Exhibit 34.7)

34.62      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 30 Hudson Yards Mortgage Loan (see Exhibit 34.9)

34.63      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

34.64      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Grand Canal Shoppes MortgageLoan (see Exhibit 34.12)

34.65      Situs Holdings, LLC, as Special Servicer of theGrand Canal Shoppes Mortgage Loan (see Exhibit 34.54)

34.66      Wells Fargo Bank, National Association, as Trustee of the Grand Canal ShoppesMortgage Loan (Omitted. See Explanatory Notes.)

34.67      Wells Fargo Bank, National Association, asCustodian of the Grand Canal Shoppes Mortgage Loan (see Exhibit 34.7)

34.68      Pentalpha Surveillance LLC, as Operating Advisorof the Grand Canal Shoppes Mortgage Loan (see Exhibit 34.22)

34.69      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

34.70      Wells Fargo Bank, National Association, as PrimaryServicer of the Eleven Seventeen Perimeter Mortgage Loan (see Exhibit 34.1)

34.71      LNR Partners, LLC, as Special Servicer of theEleven Seventeen Perimeter Mortgage Loan (see Exhibit 34.3)

34.72      Wilmington Trust, National Association, as Trustee of the Eleven SeventeenPerimeter Mortgage Loan (Omitted. See Explanatory Notes.)

34.73      Wells Fargo Bank, National Association, asCustodian of the Eleven Seventeen Perimeter Mortgage Loan (see Exhibit 34.7)

34.74      Park Bridge Lender Services LLC, as OperatingAdvisor of the Eleven Seventeen Perimeter Mortgage Loan (see Exhibit 34.8)

34.75      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Eleven Seventeen Perimeter Mortgage Loan (see Exhibit 34.9)

34.76      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

34.77      Wells Fargo Bank, National Association, as PrimaryServicer of the Polo Towne Crossing SC Mortgage Loan (see Exhibit 34.1)

34.78      LNR Partners, LLC, as Special Servicer of the PoloTowne Crossing SC Mortgage Loan (see Exhibit 34.3)

34.79      Wilmington Trust, National Association, as Trustee of the Polo Towne CrossingSC Mortgage Loan (Omitted. See Explanatory Notes.)

34.80      Wells Fargo Bank, National Association, asCustodian of the Polo Towne Crossing SC Mortgage Loan (see Exhibit 34.7)

34.81      Park Bridge Lender Services LLC, as OperatingAdvisor of the Polo Towne Crossing SC Mortgage Loan (see Exhibit 34.8)

34.82      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Polo Towne Crossing SC Mortgage Loan (see Exhibit 34.9)

34.83      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

35           Servicer compliance statements.

35.1        Wells Fargo Bank, National Association, as GeneralMaster Servicer

35.2        National Cooperative Bank, N.A., as NCB MasterServicer

35.3        LNR Partners, LLC, as General Special Servicer

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

35.5        Wells Fargo Bank, National Association, asCertificate Administrator

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

35.7        Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Waterford Lakes Town CenterMortgage Loan

35.8        KeyBank National Association, as Special Servicerof the Waterford Lakes Town Center Mortgage Loan

35.9        Wells Fargo Bank, National Association, as PrimaryServicer of the 350 Bush Street Mortgage Loan (see Exhibit 35.1)

35.10      Rialto Capital Advisors, LLC, as Special Servicerof the 350 Bush Street Mortgage Loan

35.11      Wells Fargo Bank, National Association, as PrimaryServicer of The Alhambra Mortgage Loan (see Exhibit 35.1)

35.12      Rialto Capital Advisors, LLC, as Special Servicerof The Alhambra Mortgage Loan (see Exhibit 35.10)

35.13      Wells Fargo Bank, National Association, as PrimaryServicer of the Ford Factory Mortgage Loan (see Exhibit 35.1)

35.14      Rialto Capital Advisors, LLC, as Special Servicerof the Ford Factory Mortgage Loan (see Exhibit 35.10)

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

35.16      Greystone Servicing Company LLC (as successor to C-III Asset Management LLC),as Special Servicer of the Nova Place Mortgage Loan (Omitted. See ExplanatoryNotes.)

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

35.18      Greystone Servicing Company LLC (as successor to C-III Asset Management LLC),as Special Servicer of the 450-460 Park Avenue South Mortgage Loan (Omitted.See Explanatory Notes.)

35.19      KeyBank National Association, as Primary Servicerof the Moffett Towers - Buildings 3 & 4 Mortgage Loan (see Exhibit 35.8)

35.20      Situs Holdings, LLC, as Special Servicer of theMoffett Towers - Buildings 3 & 4 Mortgage Loan

35.21      Wells Fargo Bank, National Association, as PrimaryServicer of the 30 Hudson Yards Mortgage Loan (see Exhibit 35.1)

35.22      Situs Holdings, LLC, as Special Servicer of the 30Hudson Yards Mortgage Loan (see Exhibit 35.20)

35.23      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Grand Canal Shoppes MortgageLoan (see Exhibit 35.7)

35.24      Situs Holdings, LLC, as Special Servicer of theGrand Canal Shoppes Mortgage Loan (see Exhibit 35.20)

35.25      Wells Fargo Bank, National Association, as PrimaryServicer of the Eleven Seventeen Perimeter Mortgage Loan (see Exhibit 35.1)

35.26      LNR Partners, LLC, as Special Servicer of theEleven Seventeen Perimeter Mortgage Loan (see Exhibit 35.3)

35.27      Wells Fargo Bank, National Association, as PrimaryServicer of the Polo Towne Crossing SC Mortgage Loan (see Exhibit 35.1)

35.28      LNR Partners, LLC, as Special Servicer of the PoloTowne Crossing SC Mortgage Loan (see Exhibit 35.3)

99.1        Mortgage Loan Purchase Agreement, dated as of July 23,2019, between Wells Fargo Commercial Mortgage Securities, Inc. and Wells FargoBank, National Association (filed as Exhibit 99.1 to the registrant’s CurrentReport on Form 8-K filed on August 8, 2019 under Commission File No.333-226486-07 and incorporated by reference herein)

99.2        Mortgage Loan Purchase Agreement, dated as of July 23,2019, between Wells Fargo Commercial Mortgage Securities, Inc. and Bank ofAmerica, National Association (filed as Exhibit 99.3 to the registrant’sCurrent Report on Form 8-K filed on August 8, 2019 under Commission File No.333-226486-07 and incorporated by reference herein)

99.3        Mortgage Loan Purchase Agreement, dated as of July 23,2019, between Wells Fargo Commercial Mortgage Securities, Inc. and MorganStanley Mortgage Capital Holdings LLC (filed as Exhibit 99.2 to theregistrant’s Current Report on Form 8-K/A filed on August 20, 2019 underCommission File No. 333-226486-07 and incorporated by reference herein)

99.4        Mortgage Loan Purchase Agreement, dated as of July 23,2019, between Wells Fargo Commercial Mortgage Securities, Inc. and NationalCooperative Bank, N.A. (filed as Exhibit 99.4 to the registrant’s CurrentReport on Form 8-K filed on August 8, 2019 under Commission File No.333-226486-07 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/ Anthony Sfarra

AnthonySfarra, President

(senior officer in charge ofsecuritization of the depositor)

Date: March 15,2024