**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, 2021or**

**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: 333-228375-02**

**Central Index Key Number of the issuing entity:0001787490**

**BANK 2019-BNK21**

**(exact name of the issuing entity as specified in itscharter)**

** **

**Central Index Key Number of the depositor: 0001005007**

**Banc of America Merrill LynchCommercial Mortgage Inc.**

**(exact name of the depositor as specified in itscharter)**

** **

**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: 0000740906**

**Wells Fargo Bank, NationalAssociation**

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

** **

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

**the issuing entity)** | **38-4128706**

**38-4128707**

**38-7235580**

**(I.R.S. Employer**

**Identification Numbers)** |
|------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------|

**c/o 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:**

**(646) 855-3953**

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 and posted on its corporate Web site, if any, every InteractiveData File required to be submitted and posted pursuant to Rule 405 ofRegulation S-T (Section 232.405 of this chapter) during the preceding 12 months(or for such shorter period that the registrant was required to submit and postsuch files).

Not applicable.

Indicate by check mark if disclosure of delinquent filerspursuant to Item 405 of Regulation S-K (Section 229.405 of this chapter) is notcontained herein, and will not be contained, to the best of registrant’sknowledge, in definitive proxy or information statements incorporated byreference in Part III of this Form 10-K or any amendment to this Form10-K.   

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          ⌧  (Do not check ifa smaller reporting company)                          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

Indicate by check mark whether the registrant is a shell company(as defined in Rule 12b-2 of the Act).  oYes ⌧ 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 Park Tower at Transbay Mortgage Loan, the230 Park Avenue South Mortgage Loan, the Storage Post Portfolio Mortgage Loan,the 105 East 17th Street Mortgage Loan, the Tysons Tower Mortgage Loan, theNational Anchored Retail Portfolio Mortgage Loan and the Landing at FancherCreek Mortgage Loan, which constituted approximately 9.7%, 9.3%, 7.2%, 5.1%,4.2%, 4.2% and 1.7%, respectively, of the asset pool of the issuing entity asof its cut-off date, are each an asset of the issuing entity and are each partof a loan combination that includes (a) with respect to the Park Tower atTransbay Mortgage Loan, eight other *pari passu* loans, which are notassets of the issuing entity, (b) with respect to the 230 Park Avenue SouthMortgage Loan, five other *pari passu* loans, which are not assets of theissuing entity, (c) with respect to the Storage Post Portfolio Mortgage Loan,two other *pari passu* loans, which are not assets of the issuing entity,(d) with respect to the 105 East 17th Street Mortgage Loan, one other *paripassu* loan, which is not an asset of the issuing entity, (e) with respectto the Tysons Tower Mortgage Loan, six other *pari passu* loans, which arenot assets of the issuing entity, (f) with respect to the National AnchoredRetail Portfolio Mortgage Loan, two other *pari passu* loans, which arenot assets of the issuing entity and (g) with respect to the Landing at FancherCreek Mortgage Loan, one other *pari passu* loan, which is not an asset ofthe issuing entity. These loan combinations, including the Park Tower atTransbay Mortgage Loan, the 230 Park Avenue South Mortgage Loan, the StoragePost Portfolio Mortgage Loan, the 105 East 17th Street Mortgage Loan, theTysons Tower Mortgage Loan, the National Anchored Retail Portfolio MortgageLoan and the Landing at Fancher Creek Mortgage Loan, are being serviced andadministered pursuant to the Pooling and Servicing Agreement, which isincorporated by reference as Exhibit 4.1 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 3.4% 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-three 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 4.2 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 Tower at Burbank Mortgage Loan and the NKXMultifamily Portfolio Mortgage Loan, which constituted approximately 5.9% and2.6%, respectively, of the asset pool of the issuing entity as of its cut-offdate.  The Tower at Burbank Mortgage Loan and the NKX Multifamily PortfolioMortgage Loan are each an asset of the issuing entity and are each part of aloan combination that includes (a) with respect to The Tower at BurbankMortgage Loan, two other *pari passu* loans, which are not assets of theissuing entity or (b) with respect to the NKX Multifamily Portfolio MortgageLoan, one other *pari passu* loan, which is not an asset of the issuingentity. A *pari passu* portion of each loan combination was securitized inthe BANK 2019-BNK20 transaction, Commission File Number 333-227446-06 (the “BANK2019-BNK20 Transaction”). These loan combinations, including The Tower atBurbank Mortgage Loan and the NKX Multifamily Portfolio Mortgage Loan, arebeing serviced and administered pursuant to the pooling and servicing agreementfor the BANK 2019-BNK20 Transaction, which is incorporated by reference asExhibit 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 Global Data Center Mortgage Loan, whichconstituted approximately 1.0% of the asset pool of the issuing entity as ofits cut-off date.  The Global Data Center Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the Global DataCenter Mortgage Loan and one other *pari passu* loan, which is not anasset of the issuing entity. The other *pari passu* portion of the loancombination was securitized in the UBS Commercial Mortgage Trust 2019-C17transaction, Commission File Number 333-227784-04 (the “UBS 2019-C17Transaction”). This loan combination, including the Global Data CenterMortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the UBS 2019-C17 Transaction, which is incorporated byreference as Exhibit 4.4 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 administered pursuantto 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.

Wells Fargo Bank, NationalAssociation is the master servicer and certificate administrator of themortgage loans serviced under the Pooling and Servicing Agreement and the primaryservicer of The Tower at Burbank Mortgage Loan, the NKX Multifamily PortfolioMortgage Loan and the Global Data Center Mortgage Loan. As a result, WellsFargo Bank, 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 Wells Fargo Bank, National Association inthe capacities described above are listed in the Exhibit Index.

Wells Fargo Bank, National Association is the custodian ofthe mortgage loans serviced under the Pooling and Servicing Agreement, TheTower at Burbank Mortgage Loan, the Grand Canal Shoppes Mortgage Loan, the NKXMultifamily Portfolio Mortgage Loan and the Global Data Center MortgageLoan.  As a result, Wells Fargo Bank, National Association 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 Wells Fargo Bank,National Association in the capacities described above are listed in theExhibit Index.

Rialto Capital Advisors, LLC isthe special servicer of the mortgage loans serviced under the Pooling andServicing Agreement and the Global Data Center Mortgage Loan. As a result,Rialto Capital Advisors, LLC is a “servicer” as defined in Item 1108(a)(2)(iii)of Regulation 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 Rialto Capital Advisors, LLC in the capacities described above arelisted in the Exhibit Index.

Park Bridge Lender Services LLC is the operating advisor ofthe mortgage loans serviced under the Pooling and Servicing Agreement, TheTower at Burbank Mortgage Loan and the NKX Multifamily Portfolio 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.

Midland Loan Services, a Divisionof PNC Bank, National Association is the primary servicer of the Storage PostPortfolio Mortgage Loan, the Grand Canal Shoppes Mortgage Loan and the specialservicer of The Tower at Burbank Mortgage Loan prior to July 13, 2021 and theNKX Multifamily Portfolio Mortgage Loan prior to July 13, 2021. As a result,Midland Loan Services, a Division of PNC 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 Midland Loan Services, a Division of PNC Bank, National Association in thecapacities described above are listed in the Exhibit Index.

LNR Partners, LLC is the specialservicer of The Tower at Burbank Mortgage Loan and the NKX MultifamilyPortfolio Mortgage Loan, which constituted approximately 5.9% and 2.6%,respectively, of the asset pool of the issuing entity as of its cut-off date.In accordance with the Compliance and Disclosure Interpretations, Section200.03 (Rules 13a-18 and 15d-18, Servicer’s Assessment of Compliance), thispercentage must be reduced pro rata because it was only acting as specialservicer of The Tower at Burbank Mortgage Loan and the NKX MultifamilyPortfolio Mortgage Loan from July 13, 2021 to December 31, 2021. As a result,it falls below the de minimis requirements in Item 1122 of Regulation AB and nosuch assessment or attestation is required.

Wells Fargo Bank, NationalAssociation acts as trustee of the Grand Canal Shoppes Mortgage Loan.  Pursuantto the pooling and servicing agreement for the MSC 2019-H7 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 Grand Canal Shoppes MortgageLoan have delivered one or more assessments of compliance with respect to Item1122(d)(2)(iii) of Regulation AB.

Wilmington Trust, NationalAssociation acts as trustee of  the mortgage loans serviced under thePooling and Servicing Agreement, The Tower at Burbank Mortgage Loan, the NKXMultifamily Portfolio Mortgage Loan and the Global Data Center MortgageLoan.  Pursuant to the Pooling and Servicing Agreement, the pooling andservicing agreement for the BANK 2019-BNK20 Transaction and the pooling andservicing agreement for the UBS 2019-C17 Transaction, the trustee is requiredto provide an assessment of compliance with applicable servicing criteriasolely with respect to Item 1122(d)(2)(iii) of Regulation AB (regardingadvances 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 Tower at Burbank Mortgage Loan,the NKX Multifamily Portfolio Mortgage Loan and the Global Data Center MortgageLoan have delivered one or more assessments of compliance with respect to Item1122(d)(2)(iii) of Regulation 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 master servicer under the Pooling and ServicingAgreement (except with respect to those mortgageloans for which Midland Loan Services, a Division of PNC Bank, NationalAssociation is the primary servicer) and the primary servicer of TheTower at Burbank Mortgage Loan, the NKX Multifamily Portfolio Mortgage Loan andthe Global Data Center Mortgage Loan to remit tax payments received from theescrow accounts of borrowers to local taxing authorities, to report tax amountsdue, to verify tax parcel information, and to verify non-escrow tax payments.These servicing functions are included within the servicing criteria set forthin Items 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 “servicer” 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.  SeeCompliance 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 Grand Canal Shoppes Mortgage Loan, The Tower at BurbankMortgage Loan, the NKX Multifamily Portfolio Mortgage Loan and the Global DataCenter Mortgage Loan are omitted from this Annual Report on Form 10-K as thecertificate administrator pursuant to the related pooling and servicingagreement or trust and servicing agreement does not perform any activities thataddress servicing criteria with respect to the issuing entity and because theyare each not a “servicer” that meets the criteria in Item 1108(a)(2)(i) through(iii) of Regulation AB.

Withrespect to the *pari passu* loan combinations that include theGrand Canal Shoppes Mortgage Loan, the Global Data Center Mortgage Loan,The Tower at Burbank Mortgage Loan and the NKX Multifamily Portfolio MortgageLoan, (i) the reports on assessment ofcompliance with servicing criteria and attestation reports on assessment ofcompliance with servicing criteria of Situs Holdings, LLC as special servicerof the Grand Canal Shoppes Mortgage Loan and Pentalpha Surveillance LLC asoperating advisor of the Grand Canal Shoppes Mortgage Loan and the Global DataCenter Mortgage Loan, listed on the Exhibit Index are omitted from this AnnualReport on Form 10-K as they are not required to be included on this AnnualReport on Form 10-K per Instruction 3 to Item 1122 of Regulation AB because theyare parties performing activities that address servicing criteria relating to5% or less of the assets of the issuing entity, and the report on assessment ofcompliance with servicing criteria and attestation report on assessment ofcompliance with servicing criteria of LNR Partners, LLC as special servicer ofThe Tower at Burbank Mortgage Loan and the NKX Multifamily Portfolio MortgageLoan on and after July 13, 2021 listed on the Exhibit Index are omitted fromthis Annual Report on Form 10-K for the reasons set forth in the ExplanatoryNotes above; and (ii) the servicer compliance statements of Situs Holdings, LLCas special servicer of the Grand Canal Shoppes Mortgage Loan and LNR Partners,LLC as special servicer of The Tower at Burbank Mortgage Loan and the NKXMultifamily Portfolio Mortgage Loan on and after July 13, 2021, listed on theExhibit Index are omitted from this Annual Report on Form 10-K as they are notrequired by Item 1123 of Regulation AB to be included on this Annual Report onForm 10-K because they are each an unaffiliated party 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 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.  Selected Financial Data.**

Omitted.

**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.

**PART III**

**Item 10.  Directors, Executive Officers and CorporateGovernance.**

Omitted.

**Item 11.  Executive Compensation.**

Omitted.

**Item 12.  Security Ownership of Certain BeneficialOwners and Management and Related Stockholder Matters.**

Omitted.

**Item 13.  Certain Relationships and RelatedTransactions, and Director Independence.**

Omitted.

**Item 14.  Principal Accounting 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 DerivativesInstruments (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 material pending legal proceedinginvolving the trust or any party related to the trust, other than routinelitigation incidental to the duties of those respective parties, and thefollowing, with respect to Wells Fargo Bank, National Association, as trustee,as certificate administrator and as custodian.

 

In December 2014, Phoenix LightSF Limited and certain related entities and the National Credit UnionAdministration (NCUA) filed complaints in the United States District Court forthe Southern District of New York against Wells Fargo Bank, alleging claimsagainst Wells Fargo Bank in its capacity as trustee for a number of residentialmortgage-backed securities trusts. Complaints raising similar allegations havebeen filed by Commerzbank AG in the Southern District of New York and by IKBInternational and IKB Deutsche Industriebank in New York state court. In eachcase, the plaintiffs allege that Wells Fargo Bank, as trustee, caused losses toinvestors, and plaintiffs assert causes of action based upon, among otherthings, the trustee’s alleged failure to notify and enforce repurchaseobligations of mortgage loan sellers for purported breaches of representationsand warranties, notify investors of alleged events of default, and abide byappropriate standards of care following alleged events of default. Wells FargoBank previously settled two class action lawsuits with similar allegations thatwere filed in November 2014 and December 2016 by institutional investors in theSouthern District of New York and New York state court, respectively. In addition,Park Royal I LLC and Park Royal II LLC have filed complaints in New York statecourt alleging Wells Fargo Bank, N.A., as trustee, failed to take appropriateactions upon learning of defective mortgage loan documentation. In March 2021,the Company entered into an agreement to resolve the case filed by the NCUA.

 

In addition to the foregoingcases, in August 2014 and August 2015 Nomura Credit & Capital Inc. (“Nomura”)and Natixis Real Estate Holdings, LLC (“Natixis”) filed a total of seventhird-party complaints against Wells Fargo Bank in New York state court. In theunderlying first-party actions, Nomura and Natixis have been sued for allegedbreaches of representations and warranties made in connection with residentialmortgage-backed securities sponsored by them. In the third-party actions,Nomura and Natixis allege that Wells Fargo Bank, as master servicer, primaryservicer or securities administrator, failed to notify Nomura and Natixis oftheir own breaches, failed to properly oversee the primary servicers, andfailed to adhere to accepted servicing practices. Natixis additionally allegesthat Wells Fargo Bank failed to perform default oversight duties. Wells FargoBank has asserted counterclaims alleging that Nomura and Natixis failed toprovide Wells Fargo Bank notice of their representation and warranty breaches.

 

With respect to each of the foregoing litigations, WellsFargo Bank believes plaintiffs' claims are without merit and intends to contestthe claims vigorously, but there can be no assurances as to the outcome of thelitigations or the possible impact of the litigations on Wells Fargo Bank orthe related RMBS trusts.

**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 October 23, 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 Zto 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 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 4.2 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 servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to The Tower at Burbank Mortgage Loanand the NKX Multifamily Portfolio 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 4.3 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).

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 Global Data Center Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the UBS 2019-C17 Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit Z to the pooling andservicing agreement for the UBS 2019-C17 Transaction incorporated by referenceas Exhibit 4.4 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the UBS 2019-C17 Transactionresponsible for each applicable servicing criteria set forth in Item 1122(d).

**Item 1123 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, 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          Pooling and Servicing Agreement, dated as of October 1,2019, by and among Banc of America Merrill Lynch Commercial Mortgage Inc., asDepositor, Wells Fargo Bank, National Association, as Master Servicer, RialtoCapital Advisors, LLC, as Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator, Wilmington Trust, NationalAssociation, as Trustee, and Park Bridge Lender Services LLC, as OperatingAdvisor and Asset Representations Reviewer (filed as Exhibit 4.1 to theregistrant’s Current Report on Form 8-K filed on October 23, 2019 underCommission File No. 333-228375-02 and incorporated by reference herein).

4.2          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 4.3 tothe registrant’s Current Report on Form 8-K filed on October 23, 2019 underCommission File No. 333-228375-02 and incorporated by reference herein).

4.3          Pooling and Servicing Agreement, dated as of September 1,2019, by and among Morgan Stanley Capital I Inc., as Depositor, Wells FargoBank, National Association, as General Master Servicer, Midland Loan Services,a Division of 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 Asset Representations Reviewer (filed asExhibit 4.2 to the registrant’s Current Report on Form 8-K filed on October 23,2019 under Commission File No. 333-228375-02 and incorporated by referenceherein).

4.4          Pooling and Servicing Agreement, dated as of October 1,2019, by and among UBS Commercial Mortgage Securitization Corp., as Depositor,Wells Fargo Bank, National Association, as Master Servicer, Rialto CapitalAdvisors, LLC, as Special Servicer, Wells Fargo Bank, National Association, asCertificate Administrator, Wilmington Trust, National Association, as Trustee,and Pentalpha Surveillance LLC, as Operating Advisor and Asset RepresentationsReviewer (filed as Exhibit 4.4 to the registrant’s Current Report on Form 8-Kfiled on October 23, 2019 under Commission File No. 333-228375-02 andincorporated by reference herein).

4.5          Agreement Between Note Holders, dated as of September 16,2019, 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, and Bank of America, N.A.,as Initial Note A-3 Holder, and Bank of America, N.A., as Initial Note A-4Holder, and Bank of America, N.A., as Initial Note A-5 Holder, and Bank ofAmerica, N.A., as Initial Note A-6 Holder, and Bank of America, N.A., asInitial Note A-7 Holder, and Bank of America, N.A., as Initial Note A-8 Holder,and Bank of America, N.A., as Initial Note A-9 Holder, and Bank of America,N.A., as Initial Note A-10 Holder (filed as Exhibit 4.5 to the registrant’sCurrent Report on Form 8-K filed on October 23, 2019 under Commission File No.333-228375-02 and incorporated by reference herein).

4.6          Agreement Between Note Holders, dated as of October 23,2019, by and between Wells Fargo Bank, National Association, as Initial NoteA-1 Holder, Wells Fargo Bank, National Association, as Initial Note A-2 Holder,Wells Fargo Bank, National Association, as Initial Note A-3 Holder, Bank ofAmerica, National Association, as Initial Note A-4 Holder, Bank of America,National Association, as Initial Note A-5 Holder, Bank of America, NationalAssociation, as Initial Note A-6 Holder, and JPMorgan Chase Bank, NationalAssociation, as Initial Note A-7 Holder (filed as Exhibit 4.6 to theregistrant’s Current Report on Form 8-K filed on October 23, 2019 underCommission File No. 333-228375-02 and incorporated by reference herein).

4.7          Agreement Between Note Holders, dated as of October 23,2019, 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 4.7 to the registrant’s Current Reporton Form 8-K filed on October 23, 2019 under Commission File No. 333-228375-02and incorporated by reference herein).

4.8          Agreement Between Note Holders, dated as of September 26,2019, 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 4.8 to the registrant’s Current Report on Form 8-K filed on October23, 2019 under Commission File No. 333-228375-02 and incorporated by referenceherein).

4.9          Agreement Between Note Holders, dated as of August 22,2019, by and between Morgan Stanley Bank, N.A., as Initial Note A-1 Holder, DBRInvestments Co. Limited, as Initial Note A-2 Holder, and Morgan StanleyMortgage Capital Holdings LLC, as Initial Agent (filed as Exhibit 4.9 to theregistrant’s Current Report on Form 8-K filed on October 23, 2019 underCommission File No. 333-228375-02 and incorporated by reference herein).

4.10         Agreement Between Note Holders, dated as of October 23,2019, by and between Wells Fargo Bank, National Association, as Initial NoteA-1 Holder, Wells Fargo Bank, National Association, as Initial Note A-2 Holder,Wells Fargo Bank, National Association, as Initial Note A-3 Holder, JPMorganChase Bank, National Association, as Initial Note A-4 Holder, JPMorgan ChaseBank, National Association, as Initial Note A-5 Holder, JPMorgan Chase Bank,National Association, as Initial Note A-6 Holder, and JPMorgan Chase Bank,National Association, as Initial Note A-7 Holder (filed as Exhibit 4.10 to theregistrant’s Current Report on Form 8-K filed on October 23, 2019 underCommission File No. 333-228375-02 and incorporated by reference herein).

4.11         Agreement Between Note Holders, dated as of October 23,2019, 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 4.11 to the registrant’s Current Reporton Form 8-K filed on October 23, 2019 under Commission File No. 333-228375-02and incorporated by reference herein).

4.12         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 4.12to the registrant’s Current Report on Form 8-K filed on October 23, 2019 underCommission File No. 333-228375-02 and incorporated by reference herein).

4.13         Agreement Between Note Holders, dated as of September 26,2019, 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, and Morgan StanleyMortgage Capital Holdings LLC, as Initial Agent (filed as Exhibit 4.13 to theregistrant’s Current Report on Form 8-K filed on October 23, 2019 underCommission File No. 333-228375-02 and incorporated by reference herein).

4.14         Agreement Between Note Holders, dated as of October 15,2019, 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 4.14 to the registrant’s Current Report on Form 8-Kfiled on October 23, 2019 under Commission File No. 333-228375-02 andincorporated by reference herein).

4.15         Agreement Between Note Holders, dated as of October 15,2019, by and between Wells Fargo Bank, National Association, as Initial Note A-1Holder, and Wells Fargo Bank, National Association, as Initial Note A-2 Holder(filed as Exhibit 4.15 to the registrant’s Current Report on Form 8-K filed onOctober 23, 2019 under Commission File No. 333-228375-02 and incorporated byreference 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 MasterServicer

33.2        Rialto Capital Advisors, LLC, as Special Servicer

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

33.4        Wells Fargo Bank, National Association, asCertificate Administrator

33.5        Wells Fargo Bank, National Association, asCustodian

33.6        Park Bridge Lender Services LLC, as OperatingAdvisor

33.7        CoreLogic Solutions, LLC, as Servicing FunctionParticipant

33.8        Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator on andafter November 1, 2021

33.9        Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021

33.10      Wells Fargo Bank, National Association, as PrimaryServicer of the Park Tower at Transbay Mortgage Loan (see Exhibit 33.1)

33.11      Rialto Capital Advisors, LLC, as Special Servicerof the Park Tower at Transbay Mortgage Loan (see Exhibit 33.2)

33.12      Wilmington Trust, National Association, as Trustee of the Park Tower atTransbay Mortgage Loan (Omitted. See Explanatory Notes.)

33.13      Wells Fargo Bank, National Association, asCustodian of the Park Tower at Transbay Mortgage Loan (see Exhibit 33.5)

33.14      Park Bridge Lender Services LLC, as Operating Advisorof the Park Tower at Transbay Mortgage Loan (see Exhibit 33.6)

33.15      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Park Tower at Transbay Mortgage Loan (see Exhibit 33.7)

33.16      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.17      Wells Fargo Bank, National Association, as PrimaryServicer of the 230 Park Avenue South Mortgage Loan (see Exhibit 33.1)

33.18      Rialto Capital Advisors, LLC, as Special Servicerof the 230 Park Avenue South Mortgage Loan (see Exhibit 33.2)

33.19      Wilmington Trust, National Association, as Trustee of the 230 Park Avenue SouthMortgage Loan (Omitted. See Explanatory Notes.)

33.20      Wells Fargo Bank, National Association, asCustodian of the 230 Park Avenue South Mortgage Loan (see Exhibit 33.5)

33.21      Park Bridge Lender Services LLC, as OperatingAdvisor of the 230 Park Avenue South Mortgage Loan (see Exhibit 33.6)

33.22      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 230 Park Avenue South Mortgage Loan (see Exhibit 33.7)

33.23      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.24      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Storage Post PortfolioMortgage Loan

33.25      Rialto Capital Advisors, LLC, as Special Servicerof the Storage Post Portfolio Mortgage Loan (see Exhibit 33.2)

33.26      Wilmington Trust, National Association, as Trustee of the Storage PostPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.27      Wells Fargo Bank, National Association, asCustodian of the Storage Post Portfolio Mortgage Loan (see Exhibit 33.5)

33.28      Park Bridge Lender Services LLC, as OperatingAdvisor of the Storage Post Portfolio Mortgage Loan (see Exhibit 33.6)

33.29      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Storage Post Portfolio Mortgage Loan (see Exhibit 33.7)

33.30      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.31      Wells Fargo Bank, National Association, as PrimaryServicer of the 105 East 17th Street Mortgage Loan (see Exhibit 33.1)

33.32      Rialto Capital Advisors, LLC, as Special Servicerof the 105 East 17th Street Mortgage Loan (see Exhibit 33.2)

33.33      Wilmington Trust, National Association, as Trustee of the 105 East 17th StreetMortgage Loan (Omitted. See Explanatory Notes.)

33.34      Wells Fargo Bank, National Association, asCustodian of the 105 East 17th Street Mortgage Loan (see Exhibit 33.5)

33.35      Park Bridge Lender Services LLC, as OperatingAdvisor of the 105 East 17th Street Mortgage Loan (see Exhibit 33.6)

33.36      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 105 East 17th Street Mortgage Loan (see Exhibit 33.7)

33.37      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.38      Wells Fargo Bank, National Association, as PrimaryServicer of the Tysons Tower Mortgage Loan (see Exhibit 33.1)

33.39      Rialto Capital Advisors, LLC, as Special Servicerof the Tysons Tower Mortgage Loan (see Exhibit 33.2)

33.40      Wilmington Trust, National Association, as Trustee of the Tysons Tower MortgageLoan (Omitted. See Explanatory Notes.)

33.41      Wells Fargo Bank, National Association, asCustodian of the Tysons Tower Mortgage Loan (see Exhibit 33.5)

33.42      Park Bridge Lender Services LLC, as OperatingAdvisor of the Tysons Tower Mortgage Loan (see Exhibit 33.6)

33.43      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Tysons Tower Mortgage Loan (see Exhibit 33.7)

33.44      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.45      Wells Fargo Bank, National Association, as PrimaryServicer of the National Anchored Retail Portfolio Mortgage Loan (see Exhibit33.1)

33.46      Rialto Capital Advisors, LLC, as Special Servicerof the National Anchored Retail Portfolio Mortgage Loan (see Exhibit 33.2)

33.47      Wilmington Trust, National Association, as Trustee of the National AnchoredRetail Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.48      Wells Fargo Bank, National Association, asCustodian of the National Anchored Retail Portfolio Mortgage Loan (see Exhibit33.5)

33.49      Park Bridge Lender Services LLC, as Operating Advisorof the National Anchored Retail Portfolio Mortgage Loan (see Exhibit 33.6)

33.50      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the National Anchored Retail Portfolio Mortgage Loan (see Exhibit33.7)

33.51      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.52      Wells Fargo Bank, National Association, as PrimaryServicer of the Landing at Fancher Creek Mortgage Loan (see Exhibit 33.1)

33.53      Rialto Capital Advisors, LLC, as Special Servicerof the Landing at Fancher Creek Mortgage Loan (see Exhibit 33.2)

33.54      Wilmington Trust, National Association, as Trustee of the Landing at FancherCreek Mortgage Loan (Omitted. See Explanatory Notes.)

33.55      Wells Fargo Bank, National Association, asCustodian of the Landing at Fancher Creek Mortgage Loan (see Exhibit 33.5)

33.56      Park Bridge Lender Services LLC, as OperatingAdvisor of the Landing at Fancher Creek Mortgage Loan (see Exhibit 33.6)

33.57      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Landing at Fancher Creek Mortgage Loan (see Exhibit 33.7)

33.58      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.59      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Grand Canal Shoppes MortgageLoan (see Exhibit 33.24)

33.60      Situs Holdings, LLC, as Special Servicer of the Grand Canal Shoppes MortgageLoan (Omitted. See Explanatory Notes.)

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

33.62      Wells Fargo Bank, National Association, asCustodian of the Grand Canal Shoppes Mortgage Loan (see Exhibit 33.5)

33.63      Pentalpha Surveillance LLC, as Operating Advisor of the Grand Canal ShoppesMortgage Loan (Omitted. See Explanatory Notes.)

33.64      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.65      Wells Fargo Bank, National Association, as PrimaryServicer of The Tower at Burbank Mortgage Loan (see Exhibit 33.1)

33.66      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of The Tower at Burbank Mortgage Loanprior to July 13, 2021 (see Exhibit 33.24)

33.67      LNR Partners, LLC, as Special Servicer of The Tower at Burbank Mortgage Loan onand after July 13, 2021 (Omitted. See Explanatory Notes.)

33.68      Wilmington Trust, National Association, as Trustee of The Tower at BurbankMortgage Loan (Omitted. See Explanatory Notes.)

33.69      Wells Fargo Bank, National Association, asCustodian of The Tower at Burbank Mortgage Loan (see Exhibit 33.5)

33.70      Park Bridge Lender Services LLC, as OperatingAdvisor of The Tower at Burbank Mortgage Loan (see Exhibit 33.6)

33.71      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of The Tower at Burbank Mortgage Loan (see Exhibit 33.7)

33.72      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.73      Wells Fargo Bank, National Association, as PrimaryServicer of the NKX Multifamily Portfolio Mortgage Loan (see Exhibit 33.1)

33.74      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the NKX Multifamily PortfolioMortgage Loan prior to July 13, 2021 (see Exhibit 33.24)

33.75      LNR Partners, LLC, as Special Servicer of the NKX Multifamily PortfolioMortgage Loan on and after July 13, 2021 (Omitted. See Explanatory Notes.)

33.76      Wilmington Trust, National Association, as Trustee of the NKX MultifamilyPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.77      Wells Fargo Bank, National Association, asCustodian of the NKX Multifamily Portfolio Mortgage Loan (see Exhibit 33.5)

33.78      Park Bridge Lender Services LLC, as OperatingAdvisor of the NKX Multifamily Portfolio Mortgage Loan (see Exhibit 33.6)

33.79      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the NKX Multifamily Portfolio Mortgage Loan (see Exhibit 33.7)

33.80      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.81      Wells Fargo Bank, National Association, as PrimaryServicer of the Global Data Center Mortgage Loan (see Exhibit 33.1)

33.82      Rialto Capital Advisors, LLC, as Special Servicerof the Global Data Center Mortgage Loan (see Exhibit 33.2)

33.83      Wilmington Trust, National Association, as Trustee of the Global Data CenterMortgage Loan (Omitted. See Explanatory Notes.)

33.84      Wells Fargo Bank, National Association, asCustodian of the Global Data Center Mortgage Loan (see Exhibit 33.5)

33.85      Pentalpha Surveillance LLC, as Operating Advisor of the Global Data CenterMortgage Loan (Omitted. See Explanatory Notes.)

33.86      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Global Data Center Mortgage Loan (see Exhibit 33.7)

33.87      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

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

34.1        Wells Fargo Bank, National Association, as MasterServicer

34.2        Rialto Capital Advisors, LLC, as Special Servicer

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

34.4        Wells Fargo Bank, National Association, asCertificate Administrator

34.5        Wells Fargo Bank, National Association, asCustodian

34.6        Park Bridge Lender Services LLC, as OperatingAdvisor

34.7        CoreLogic Solutions, LLC, as Servicing FunctionParticipant

34.8        Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator on andafter November 1, 2021

34.9        Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1, 2021

34.10      Wells Fargo Bank, National Association, as PrimaryServicer of the Park Tower at Transbay Mortgage Loan (see Exhibit 34.1)

34.11      Rialto Capital Advisors, LLC, as Special Servicerof the Park Tower at Transbay Mortgage Loan (see Exhibit 34.2)

34.12      Wilmington Trust, National Association, as Trustee of the Park Tower atTransbay Mortgage Loan (Omitted. See Explanatory Notes.)

34.13      Wells Fargo Bank, National Association, asCustodian of the Park Tower at Transbay Mortgage Loan (see Exhibit 34.5)

34.14      Park Bridge Lender Services LLC, as Operating Advisorof the Park Tower at Transbay Mortgage Loan (see Exhibit 34.6)

34.15      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Park Tower at Transbay Mortgage Loan (see Exhibit 34.7)

34.16      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

34.17      Wells Fargo Bank, National Association, as PrimaryServicer of the 230 Park Avenue South Mortgage Loan (see Exhibit 34.1)

34.18      Rialto Capital Advisors, LLC, as Special Servicerof the 230 Park Avenue South Mortgage Loan (see Exhibit 34.2)

34.19      Wilmington Trust, National Association, as Trustee of the 230 Park Avenue SouthMortgage Loan (Omitted. See Explanatory Notes.)

34.20      Wells Fargo Bank, National Association, asCustodian of the 230 Park Avenue South Mortgage Loan (see Exhibit 34.5)

34.21      Park Bridge Lender Services LLC, as OperatingAdvisor of the 230 Park Avenue South Mortgage Loan (see Exhibit 34.6)

34.22      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 230 Park Avenue South Mortgage Loan (see Exhibit 34.7)

34.23      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

34.24      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Storage Post PortfolioMortgage Loan

34.25      Rialto Capital Advisors, LLC, as Special Servicerof the Storage Post Portfolio Mortgage Loan (see Exhibit 34.2)

34.26      Wilmington Trust, National Association, as Trustee of the Storage PostPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.27      Wells Fargo Bank, National Association, asCustodian of the Storage Post Portfolio Mortgage Loan (see Exhibit 34.5)

34.28      Park Bridge Lender Services LLC, as OperatingAdvisor of the Storage Post Portfolio Mortgage Loan (see Exhibit 34.6)

34.29      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Storage Post Portfolio Mortgage Loan (see Exhibit 34.7)

34.30      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

34.31      Wells Fargo Bank, National Association, as PrimaryServicer of the 105 East 17th Street Mortgage Loan (see Exhibit 34.1)

34.32      Rialto Capital Advisors, LLC, as Special Servicerof the 105 East 17th Street Mortgage Loan (see Exhibit 34.2)

34.33      Wilmington Trust, National Association, as Trustee of the 105 East 17th StreetMortgage Loan (Omitted. See Explanatory Notes.)

34.34      Wells Fargo Bank, National Association, asCustodian of the 105 East 17th Street Mortgage Loan (see Exhibit 34.5)

34.35      Park Bridge Lender Services LLC, as OperatingAdvisor of the 105 East 17th Street Mortgage Loan (see Exhibit 34.6)

34.36      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 105 East 17th Street Mortgage Loan (see Exhibit 34.7)

34.37      Computershare Trust Company, National Association, asServicing Function Participant for the Custodian on and after November 1, 2021(see Exhibit 34.9)

34.38      Wells Fargo Bank, National Association, as PrimaryServicer of the Tysons Tower Mortgage Loan (see Exhibit 34.1)

34.39      Rialto Capital Advisors, LLC, as Special Servicerof the Tysons Tower Mortgage Loan (see Exhibit 34.2)

34.40      Wilmington Trust, National Association, as Trustee of the Tysons Tower MortgageLoan (Omitted. See Explanatory Notes.)

34.41      Wells Fargo Bank, National Association, asCustodian of the Tysons Tower Mortgage Loan (see Exhibit 34.5)

34.42      Park Bridge Lender Services LLC, as OperatingAdvisor of the Tysons Tower Mortgage Loan (see Exhibit 34.6)

34.43      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Tysons Tower Mortgage Loan (see Exhibit 34.7)

34.44      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

34.45      Wells Fargo Bank, National Association, as PrimaryServicer of the National Anchored Retail Portfolio Mortgage Loan (see Exhibit34.1)

34.46      Rialto Capital Advisors, LLC, as Special Servicerof the National Anchored Retail Portfolio Mortgage Loan (see Exhibit 34.2)

34.47      Wilmington Trust, National Association, as Trustee of the National AnchoredRetail Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.48      Wells Fargo Bank, National Association, asCustodian of the National Anchored Retail Portfolio Mortgage Loan (see Exhibit34.5)

34.49      Park Bridge Lender Services LLC, as OperatingAdvisor of the National Anchored Retail Portfolio Mortgage Loan (see Exhibit34.6)

34.50      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the National Anchored Retail Portfolio Mortgage Loan (seeExhibit 34.7)

34.51      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

34.52      Wells Fargo Bank, National Association, as PrimaryServicer of the Landing at Fancher Creek Mortgage Loan (see Exhibit 34.1)

34.53      Rialto Capital Advisors, LLC, as Special Servicerof the Landing at Fancher Creek Mortgage Loan (see Exhibit 34.2)

34.54      Wilmington Trust, National Association, as Trustee of the Landing at FancherCreek Mortgage Loan (Omitted. See Explanatory Notes.)

34.55      Wells Fargo Bank, National Association, asCustodian of the Landing at Fancher Creek Mortgage Loan (see Exhibit 34.5)

34.56      Park Bridge Lender Services LLC, as OperatingAdvisor of the Landing at Fancher Creek Mortgage Loan (see Exhibit 34.6)

34.57      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Landing at Fancher Creek Mortgage Loan (see Exhibit 34.7)

34.58      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1, 2021(see Exhibit 34.9)

34.59      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Grand Canal Shoppes MortgageLoan (see Exhibit 34.24)

34.60      Situs Holdings, LLC, as Special Servicer of the Grand Canal Shoppes MortgageLoan (Omitted. See Explanatory Notes.)

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

34.62      Wells Fargo Bank, National Association, asCustodian of the Grand Canal Shoppes Mortgage Loan (see Exhibit 34.5)

34.63      Pentalpha Surveillance LLC, as Operating Advisor of the Grand Canal ShoppesMortgage Loan (Omitted. See Explanatory Notes.)

34.64      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

34.65      Wells Fargo Bank, National Association, as PrimaryServicer of The Tower at Burbank Mortgage Loan (see Exhibit 34.1)

34.66      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of The Tower at Burbank Mortgage Loanprior to July 13, 2021 (see Exhibit 34.24)

34.67      LNR Partners, LLC, as Special Servicer of The Tower at Burbank Mortgage Loan onand after July 13, 2021 (Omitted. See Explanatory Notes.)

34.68      Wilmington Trust, National Association, as Trustee of The Tower at BurbankMortgage Loan (Omitted. See Explanatory Notes.)

34.69      Wells Fargo Bank, National Association, asCustodian of The Tower at Burbank Mortgage Loan (see Exhibit 34.5)

34.70      Park Bridge Lender Services LLC, as OperatingAdvisor of The Tower at Burbank Mortgage Loan (see Exhibit 34.6)

34.71      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of The Tower at Burbank Mortgage Loan (see Exhibit 34.7)

34.72      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

34.73      Wells Fargo Bank, National Association, as PrimaryServicer of the NKX Multifamily Portfolio Mortgage Loan (see Exhibit 34.1)

34.74      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the NKX Multifamily PortfolioMortgage Loan prior to July 13, 2021 (see Exhibit 34.24)

34.75      LNR Partners, LLC, as Special Servicer of the NKX Multifamily PortfolioMortgage Loan on and after July 13, 2021 (Omitted. See Explanatory Notes.)

34.76      Wilmington Trust, National Association, as Trustee of the NKX MultifamilyPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.77      Wells Fargo Bank, National Association, asCustodian of the NKX Multifamily Portfolio Mortgage Loan (see Exhibit 34.5)

34.78      Park Bridge Lender Services LLC, as OperatingAdvisor of the NKX Multifamily Portfolio Mortgage Loan (see Exhibit 34.6)

34.79      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the NKX Multifamily Portfolio Mortgage Loan (see Exhibit 34.7)

34.80      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

34.81      Wells Fargo Bank, National Association, as PrimaryServicer of the Global Data Center Mortgage Loan (see Exhibit 34.1)

34.82      Rialto Capital Advisors, LLC, as Special Servicerof the Global Data Center Mortgage Loan (see Exhibit 34.2)

34.83      Wilmington Trust, National Association, as Trustee of the Global Data CenterMortgage Loan (Omitted. See Explanatory Notes.)

34.84      Wells Fargo Bank, National Association, asCustodian of the Global Data Center Mortgage Loan (see Exhibit 34.5)

34.85      Pentalpha Surveillance LLC, as Operating Advisor of the Global Data CenterMortgage Loan (Omitted. See Explanatory Notes.)

34.86      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Global Data Center Mortgage Loan (see Exhibit 34.7)

34.87      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1, 2021(see Exhibit 34.9)

35           Servicer compliance statements.

35.1        Wells Fargo Bank, National Association, as MasterServicer

35.2        Rialto Capital Advisors, LLC, as Special Servicer

35.3        Wells Fargo Bank, National Association, asCertificate Administrator

35.4        Computershare Trust Company, National Association, asServicing Function Participant for the Certificate Administrator on and afterNovember 1, 2021

35.5        Wells Fargo Bank, National Association, as PrimaryServicer of the Park Tower at Transbay Mortgage Loan (see Exhibit 35.1)

35.6        Rialto Capital Advisors, LLC, as Special Servicerof the Park Tower at Transbay Mortgage Loan (see Exhibit 35.2)

35.7        Wells Fargo Bank, National Association, as PrimaryServicer of the 230 Park Avenue South Mortgage Loan (see Exhibit 35.1)

35.8        Rialto Capital Advisors, LLC, as Special Servicerof the 230 Park Avenue South Mortgage Loan (see Exhibit 35.2)

35.9        Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Storage Post PortfolioMortgage Loan

35.10      Rialto Capital Advisors, LLC, as Special Servicerof the Storage Post Portfolio Mortgage Loan (see Exhibit 35.2)

35.11      Wells Fargo Bank, National Association, as PrimaryServicer of the 105 East 17th Street Mortgage Loan (see Exhibit 35.1)

35.12      Rialto Capital Advisors, LLC, as Special Servicerof the 105 East 17th Street Mortgage Loan (see Exhibit 35.2)

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

35.14      Rialto Capital Advisors, LLC, as Special Servicerof the Tysons Tower Mortgage Loan (see Exhibit 35.2)

35.15      Wells Fargo Bank, National Association, as PrimaryServicer of the National Anchored Retail Portfolio Mortgage Loan (see Exhibit35.1)

35.16      Rialto Capital Advisors, LLC, as Special Servicerof the National Anchored Retail Portfolio Mortgage Loan (see Exhibit 35.2)

35.17      Wells Fargo Bank, National Association, as PrimaryServicer of the Landing at Fancher Creek Mortgage Loan (see Exhibit 35.1)

35.18      Rialto Capital Advisors, LLC, as Special Servicerof the Landing at Fancher Creek Mortgage Loan (see Exhibit 35.2)

35.19      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Grand Canal Shoppes MortgageLoan (see Exhibit 35.9)

35.20      Situs Holdings, LLC, as Special Servicer of the Grand Canal Shoppes MortgageLoan (Omitted. See Explanatory Notes.)

35.21      Wells Fargo Bank, National Association, as PrimaryServicer of The Tower at Burbank Mortgage Loan (see Exhibit 35.1)

35.22      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of The Tower at Burbank Mortgage Loanprior to July 13, 2021 (see Exhibit 35.9)

35.23      LNR Partners, LLC, as Special Servicer of The Tower at Burbank Mortgage Loan onand after July 13, 2021 (Omitted. See Explanatory Notes.)

35.24      Wells Fargo Bank, National Association, as PrimaryServicer of the NKX Multifamily Portfolio Mortgage Loan (see Exhibit 35.1)

35.25      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the NKX Multifamily PortfolioMortgage Loan prior to July 13, 2021 (see Exhibit 35.9)

35.26      LNR Partners, LLC, as Special Servicer of the NKX Multifamily PortfolioMortgage Loan on and after July 13, 2021 (Omitted. See Explanatory Notes.)

35.27      Wells Fargo Bank, National Association, as PrimaryServicer of the Global Data Center Mortgage Loan (see Exhibit 35.1)

35.28      Rialto Capital Advisors, LLC, as Special Servicerof the Global Data Center Mortgage Loan (see Exhibit 35.2)

99.1        Mortgage Loan Purchase Agreement, dated as of September27, 2019, between Banc of America Merrill Lynch Commercial Mortgage Inc. andBank of America, National Association (filed as Exhibit 99.2 to theregistrant’s Current Report on Form 8-K filed on October 23, 2019 underCommission File No. 333-228375-02 and incorporated by reference herein)

99.2        Mortgage Loan Purchase Agreement, dated as of September27, 2019, between Banc of America Merrill Lynch Commercial Mortgage Inc. andMorgan Stanley Mortgage Capital Holdings LLC (filed as Exhibit 99.1 to theregistrant’s Current Report on Form 8-K filed on October 23, 2019 underCommission File No. 333-228375-02 and incorporated by reference herein)

99.3        Mortgage Loan Purchase Agreement, dated as of September27, 2019, between Banc of America Merrill Lynch Commercial Mortgage Inc. andWells Fargo Bank, National Association (filed as Exhibit 99.3 to theregistrant’s Current Report on Form 8-K filed on October 23, 2019 underCommission File No. 333-228375-02 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.

Banc of America Merrill LynchCommercial Mortgage Inc.(Depositor)

/s/ LelandF. Bunch, III

Leland F.Bunch, III, President and Chief Executive Officer

(senior officer in charge ofsecuritization of the depositor)

Date: March 15, 2022