MANAGEMENT’S ASSESSMENT OF

COMPLIANCE WITH REGULATION AB CRITERIA

 

 

PrincipalReal Estate Investors, LLC and Principal Global Investors, LLC, (the “AssessingParties”) are responsible for assessing compliance for the transactions listedon Attachment A for the period January 1, 2022 through December 31, 2022, (the“Reporting Period”) with the servicing criteria set forth in Title 17, Section229.1122(d) of the Code of Federal Regulations (the “CFR”), except for thecriteria set forth in Sections 229.1122(d)(1)(ii)-(iii), 229.1122(d)(3)(i) –(iv), 229.1122(d)(4)(ix), and 229.1122(d)(4)(xv), in the CFR, which theAssessing Parties have concluded are not applicable to the servicing of thetransactions listed on Attachment A, backed by commercial mortgage loans andprimarily serviced by the Assessing Parties (the “Applicable ServicingCriteria”).

 

TheAssessing Parties have assessed compliance with the Applicable Servicing Criteriafor the Reporting Period and have concluded that the Assessing Parties havecomplied, in all material respects, with the Applicable Servicing Criteria forthe transactions listed on Attachment A backed by commercial mortgagesprimarily serviced by the Assessing Parties.

 

Withrespect to servicing criteria 1122(d)(1)(i) and 1122(d)(4)(i) (the “Criteria”),the Assessing Parties have engaged various vendors to perform certainactivities required by this Criteria. The Assessing Parties have determined thatnone of these vendors are considered a “servicer” as defined in Item 1101(j) ofRegulation AB, and the Assessing Parties have elected to take responsibilityfor assessing compliance with the servicing criteria applicable to each vendoras permitted by Regulation AB Compliance and Disclosure Interpretations of theDivision of Corporation Finance, Section 200.06, “Vendors Engaged by Servicers”(C&DI 200.06). The Assessing Parties have assessed that it has policies andprocedures in place designed to provide reasonable assurance that the vendors’activities comply in all material respects with the servicing criteriaapplicable to each vendor. The Assessing Parties are solely responsible fordetermining that it meets the SEC requirements to apply C&DI 200.06 for thevendors and related criterion as described herein.

 

Ernst & Young LLP, anindependent registered public accounting firm, has issued an attestation reporton the assessment of compliance with the Applicable Servicing Criteria for theReporting Period as set forth in this assessment.

 

 

By: /s/ Steven Johnson

Steven Johnson

Managing Director

Principal Real EstateInvestors, LLC

Principal Global Investors,LLC

 

 

Date: February 20, 2023

 

 

Attachment A

Commercial MortgagePass-Through Certificates

 

| Wells Fargo Bank, National  Association, as Master Servicer |
|-------------------------------------------------------------|
| Series 2005 PWR10 dated  December 1, 2005                   | Series 2007 Top25 dated  January 30, 2007 | Series 2006-Top24 dated  October 1, 2006 |
| Series 2007 Top26 dated  April 18, 2007                     | Series 2012 C10 dated December  1, 2012 | Series 2007 PWR15 dated  March 29, 2007 |
| Series 2012 C-9 dated  October 1, 2012                      | Series 2013 C17 dated  November 1, 2013 | Series 2012 C-8 dated August  1, 2012 |
| Series 2013 C13 dated May 1,  2013                          | Series 2015 – C27 dated  March 1, 2015 | Series 2013 C11 dated  February 1, 2013 |
| Series 2014 – LC14 dated  February 1, 2014            | Series 2017 – P7 dated April  1, 2017 | Series 2014 – C19 dated  March 1, 2014 |
| Series 2014 – C21 dated  August 1, 2014               | Series 2016 – P3 dated April  1, 2016 | Series 2015 – P1 dated August  1, 2015 |
| Series 2015 – P2 dated  December 1, 2015              | Series 2016 – P4 dated July  1, 2016 | Series 2017 – P8 dated  September 1, 2017 |
| Series 2017 – CD6 dated  November 1, 2017             |   |   |

 

| Berkadia Commercial Mortgage  LLC, as Master Servicer |
|-------------------------------------------------------|
| Series 2007 IQ-15 dated  8/23/2007                    |   |   |

 

| Midland Loan Services, a  Division of PNC Bank, National Association, as Master Servicer |
|------------------------------------------------------------------------------------------|
| Series 2016 – P5 dated  October 1, 2016                                            | Series 2016 – P6 dated  December 1, 2016 | Series 2019 – CD8 dated  August 1, 2019 |
| CSAIL 2021 C20 dated March  1, 2021                                                      |   |   |