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**Deloitte& Touche LLP**

CertifiedPublic Accountants

333Southeast 2nd Avenue

Suite3600

Miami,FL 33131

USA

 

Tel:+1 305 372 3100

Fax:+1 305 372 3160

www.deloitte.com 

 

 

**REPORTOF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM**

 

ToThose Charged with Governance of

3650REIT Loan Servicing, LLC:

 

Wehave examined management of 3650 REIT Loan Servicing, LLC’s assertion, includedin the accompanying Management’s Report on Assessment of Compliance with SECRegulation AB Servicing Criteria, that 3650 REIT Loan Servicing, LLC (the“Company”) complied with the servicing criteria set forth in Item 1122(d) ofthe Securities and Exchange Commission’s Regulation AB for the asset‐backedsecurities transactions for which the Company served as special servicerinvolving commercial mortgage loans in the Commercial MortgagePass‐Through Certificates, Series 2019‐C15 (“CSAIL2019‐C15”), the Commercial Mortgage Pass‐Through Certificates,Series 2019‐C17 (“CSAIL 2019‐C17”), the Commercial MortgagePass‐Through Certificates, Series 2020‐C19 (“CSAIL2020‐C19”), the Commercial Mortgage Pass‐Through Certificates,Series 2020‐TMIC (“CSMC 2020‐TMIC”), the Commercial MortgagePass‐ Through Certificates, Series 2021‐C20 (“CSAIL2021‐C20”), the Commercial Mortgage Pass‐Through Certificates,Series 2021‐ACEN (“ALEN 2021‐ACEN”), and the Commercial MortgagePass‐Through Certificates, Series 2021‐PF1 (“3650R 2021‐PF1”)and that were registered with the Securities and Exchange Commission pursuantto the Securities Act of 1933 (the “Platform”), excluding criteria in Items1122(d)(1)(iii), (2)(i), (2) (ii), (2)( iii), (2)(iv), (2)(v), (2)(vii),(3)(i)(C), (3)(i) (D), (3)(ii), (3)(iii), (3)(iv), (4)(ii), (4)(iii), (4)(iv),(4)(v), (4)(ix), (4)(x), (4)(xi), (4)(xii), (4)(xiii), (4)(xiv) and (4)(xv)(the “servicing criteria”), as of and for the year ended December 31, 2021,which management has determined are not applicable to the activities performedby the Company with respect to the Platform. Exhibit 1 to management’sassertion identifies the individual asset‐backed transactions defined bymanagement as constituting the Platform. Management is responsible for theCompany’s compliance with the servicing criteria and its assertion. Ourresponsibility is to express an opinion on management’s assertion about theCompany’s compliance with the servicing criteria based on our examination.

 

Ourexamination was conducted in accordance with the standards of the PublicCompany Accounting Oversight Board (United States) and in accordance withattestation standards established by the American Institute of Certified PublicAccountants. Those standards require that we plan and perform the examinationto obtain reasonable assurance about whether management’s assertion aboutcompliance with the servicing criteria is fairly stated, in all materialrespects, and, accordingly, included examining, on a test basis, evidence aboutthe Company’s compliance with the servicing criteria, including tests on asample basis of the servicing activities related to the Platform, determiningwhether the Company performed those selected activities in compliance with theservicing criteria during the specified period, and performing such otherprocedures as we considered necessary in the circumstances. Our procedures werelimited to selected servicing activities performed by the Company during theperiod covered by this report and, accordingly, such samples may not haveincluded servicing activities related to each asset‐backed transactionincluded in the Platform. Further, an examination is not designed to detectnoncompliance arising from errors that may have occurred prior to the periodspecified above that may have affected the balances or amounts calculated orreported by the Company during the period covered by this report. We believethat the evidence we obtained in our examination is sufficient and appropriateto provide a reasonable basis for our opinion.

 

Asdescribed in management’s assertion, for servicing criteria Items1122(d)(1)(ii) and d)(4)(i) the Company has engaged vendors to perform certainactivities required by this servicing criteria. The Company has determined thatthese vendors are not considered a “servicer” as defined in Item 1101(j) ofRegulation AB, and the Company has elected to take responsibility for assessingcompliance with the servicing criteria applicable to these vendors as permittedby the SEC’s Compliance and Disclosure Interpretation 200.06, Vendors Engagedby Servicers (“C&DI 200.06”). As permitted by C&DI 200.06, the Companyhas asserted that it has policies and procedures in place designed to providereasonable assurance that the vendors’ activities comply in all materialrespects with the servicing criteria applicable to this vendor. The Company issolely responsible for determining that it meets the SEC requirements to applyC&DI 200.06 for the vendors and related criteria as described in itsassertion, and we performed no procedures with respect to the Company’s determinationof its eligibility to apply C&DI 200.06.

 

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

 

Inour opinion, management’s assertion that the Company complied with theaforementioned servicing criteria as of and for the year ended December 31,2021, for the asset‐backed securities transactions for which the Companyserved as special servicer involving commercial mortgage loans in CSAIL2019‐C15, CSAIL 2019‐C17, CSAIL 2020‐C19, CSMC 2020‐TMIC,CSAIL 2021‐C20, ALEN 2021‐ACEN and 3650R 2021‐PF1 and thatwere registered with the Securities and Exchange Commission pursuant to theSecurities Act of1933, is fairly stated, in all material respects.

 

 

/s/Deloitte & Touche LLP

 

Miami,Florida 

February23, 2022