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Reportof Independent Registered Public Accounting Firm

 

To theBoard of Directors

PrincipalGlobal Investors, LLC and Principal Real Estate Investors, LLC

 

Wehave examined management’s assertion, included in the accompanying Management’sAssessment on Compliance With Regulation AB Criteria, that Principal GlobalInvestors, LLC and Principal Real Estate Investors, LLC, (the “Companies”)complied with the servicing criteria set forth in Item 1122 (d) of theSecurities and Exchange Commission’s Regulation AB for the commercial mortgagebacked securities platform as of and for the year ended December 31, 2019,except for 1122 (d)(1)(ii)-(iii), 1122 (d)(3)(i)-(iv),1122(d)(4)(ix), and1122(d)(4)(xv), which the Companies have determined are not applicable to theactivities performed by them with respect to the servicing platform covered bythis report. See Attachment A of Management’s Assessment on Compliance withRegulation AB Criteria for the asset backed transactions covered by thisplatform. Management is responsible for the Companies’ compliance with thoseservicing criteria. Our responsibility is to express an opinion on management’sassertion about the Companies’ compliance with the servicing criteria based onour examination.

 

Ourexamination was conducted in accordance with attestation standards establishedby the American Institute of Certified Public Accountants and the PublicCompany Accounting Oversight Board (United States) and, accordingly, includedexamining, on a test basis, evidence about the Companies’ compliance with theapplicable servicing criteria and performing such other procedures as weconsidered necessary in the circumstances. Our examination included testing ofless than all of the individual asset backed transactions and securities thatcomprise the platform, testing of less than all of the servicing activitiesrelated to the Platform and determining whether the Companies processed thoseselected transactions and performed those selected activities in compliancewith the servicing criteria and as permitted by Regulation AB Compliance andDisclosure Interpretations of the Division of Corporation Finance, Section200.06, “Vendors Engaged by Servicers” (C&DI 200.06). Furthermore, ourprocedures were limited to the selected transactions and servicing activitiesperformed by the Companies during the period covered by this report. Ourprocedures were not designed to determine whether errors may have occurredeither prior to or subsequent to our tests that may have affected the balancesor amounts calculated or reported by the Companies during the period covered bythis report for the selected transactions or any other transactions. We believethat the evidence we obtained is sufficient and appropriate to provide areasonable basis for our opinion.

 

Ourexamination does not provide a legal determination on the Companies’ compliancewith the servicing criteria.

 

Asdescribed in management’s assertion, for servicing criteria 1122 (d)(1)(i) and1122 (d)(4)(i), the Companies have engaged various vendors to perform theactivities required by these servicing criteria. The Companies have determinedthat these vendors are not considered a “servicer” as defined in Item 1101(j)of Regulation AB, and the Companies have elected to take responsibility forassessing compliance with the applicable servicing criteria applicable to eachvendor as permitted by C&DI 200.06. As permitted by C&DI 200.06, theCompanies have asserted that they have policies and procedures in placedesigned to provide reasonable assurance that the vendors’ activities comply inall material respects with servicing criteria applicable to each vendor. TheCompanies are solely responsible for determining that they meet the SECrequirements to apply C&DI 200.06 for the vendors and related criteria asdescribed in their assertion, and we performed no procedures with respect tothe Companies’ eligibility to apply C&DI 200.06.

 

Inour opinion, management’s assertion that the Companies complied with theaforementioned servicing criteria, including servicing criteria 1122 (d)(1)(i)and 1122 (d)(4)(i) for which compliance is determined based on C&DI200.06 as described above, as of andfor the year endedDecember 31, 2019, for the commercial mortgage backed securities platform isfairly stated, in all material respects.

 

 

/s/Ernst&Young LLP

 

 

February17, 2020