**UNITED STATESSECURITIES AND EXCHANGE COMMISSION**

**Washington, D.C. 20549**

**FORM 10-K**

(Mark One)

**x****   ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THESECURITIES EXCHANGE ACT OF 1934**

**For the fiscal year ended December 31, 2022or**

**o****    TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OFTHE SECURITIES EXCHANGE ACT OF 1934**

**For the transition period from _____ to _____Commission file number of the issuing entity: 333-226486-10**

**Central Index Key Number of the issuing entity:0001789307**

**BANK 2019-BNK22**

**(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)** | **38-4128790**

**38-4128791**

**38-7235611**

**(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 principal executive offices of the issuingentity)**

**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 o No

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          ⌧  (Do not check if asmaller reporting company)                          Smaller reporting company                    o

                                                                                                                                                       Emerging growth company                    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 o No

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 documents shouldbe 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 Park Tower at Transbay Mortgage Loan, the230 Park Avenue South Mortgage Loan, the Storage Post Portfolio Mortgage Loan,the Tysons Tower Mortgage Loan and the National Anchored Retail Portfolio MortgageLoan, which constituted approximately 9.6%, 9.2%, 5.4%, 3.7% and 2.5%,respectively, of the asset pool of the issuing entity as of its cut-offdate.  The Park Tower at Transbay Mortgage Loan, the 230 Park Avenue SouthMortgage Loan, the Storage Post Portfolio Mortgage Loan, the Tysons TowerMortgage Loan and the National Anchored Retail Portfolio Mortgage Loan are eachan asset of the issuing entity and are each part of a loan combination thatincludes (a) with respect to the Park Tower at Transbay Mortgage Loan, sevenother *pari passu* loans, which are not assets of the issuing entity, (b)with respect to the 230 Park Avenue South Mortgage Loan, three other *paripassu* loans, which are not assets of the issuing entity, (c) with respectto the Storage Post Portfolio Mortgage Loan, one other *pari passu* loan,which is not an asset of the issuing entity, (d) with respect to the TysonsTower Mortgage Loan, five other *pari passu* loans, which are not assetsof the issuing entity or (e) with respect to the National Anchored RetailPortfolio Mortgage Loan, two other *pari passu* loans, which are notassets of the issuing entity. A *pari passu* portion of each loancombination was securitized in the BANK 2019-BNK21 transaction, Commission FileNumber 333-228375-02 (the “BANK 2019-BNK21 Transaction”). These loancombinations, including the Park Tower at Transbay Mortgage Loan, the 230 ParkAvenue South Mortgage Loan, the Storage Post Portfolio Mortgage Loan, theTysons Tower Mortgage Loan and the National Anchored Retail Portfolio MortgageLoan, are being serviced and administered pursuant to the pooling and servicingagreement for the BANK 2019-BNK21 Transaction, which is incorporated byreference 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 Midtown Center Mortgage Loan, whichconstituted approximately 7.4% of the asset pool of the issuing entity as ofits cut-off date.  The Midtown Center Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the MidtownCenter Mortgage Loan, five other *pari passu* loans and three subordinatecompanion loans, which are not assets of the issuing entity. A *pari passu*portion of the loan combination was securitized in the DC Office Trust 2019-MTCtransaction (the “DCOT 2019-MTC Transaction”). This loan combination,including the Midtown Center Mortgage Loan, is being serviced and administeredpursuant to the trust and servicing agreement for the DCOT 2019-MTCTransaction, which is incorporated by reference as Exhibit 4.3 to this AnnualReport on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the 360 North Crescent Drive Mortgage Loan,which constituted approximately 4.6% of the asset pool of the issuing entity asof its cut-off date.  The 360 North Crescent Drive Mortgage Loan is anasset of the issuing entity and is part of a loan combination that includes the360 North Crescent Drive Mortgage Loan and one other *pari passu* loan,which is not an asset of the issuing entity. This loan combination, includingthe 360 North Crescent Drive Mortgage Loan, was serviced under the Pooling andServicing Agreement for the issuing entity prior to the closing of thesecuritization of the other *pari passu* portion of the 360 North CrescentDrive loan combination in the BANK 2019-BNK23 transaction, Commission FileNumber 333-227446-08 (the “BANK 2019-BNK23 Transaction”).  Afterthe closing of the BANK 2019-BNK23 Transaction on December 10, 2019, this loancombination, including the 360 North Crescent Drive Mortgage Loan was, and willcontinue to be, serviced and administered pursuant to the pooling and servicingagreement with respect to the BANK 2019-BNK23 Transaction, which isincorporated by reference 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 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.

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 Park Tower at Transbay Mortgage Loan, the 230 ParkAvenue South Mortgage Loan, the Midtown Center Mortgage Loan, the 360 NorthCrescent Drive Mortgage Loan, the Tysons Tower Mortgage Loan and the NationalAnchored Retail Portfolio Mortgage Loan. As a result, Wells Fargo Bank,National Association 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 Wells Fargo Bank, National Association in the capacities describedabove are listed in the Exhibit Index.

Wells Fargo Bank, NationalAssociation is the custodian of the mortgage loans serviced under the Poolingand Servicing Agreement, the Park Tower at Transbay Mortgage Loan, the 230 ParkAvenue South Mortgage Loan, the Midtown Center Mortgage Loan, the Storage PostPortfolio Mortgage Loan, the 360 North Crescent Drive Mortgage Loan, the TysonsTower Mortgage Loan and the National Anchored Retail Portfolio 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, NationalAssociation in the capacities described above are listed in the Exhibit Index.

KeyBank National Association isthe special servicer of the mortgage loans serviced under the Pooling andServicing Agreement and the 360 North Crescent Drive Mortgage Loan. As aresult, 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.

Rialto Capital Advisors, LLC isthe special servicer of the Park Tower at Transbay Mortgage Loan, the 230 ParkAvenue South Mortgage Loan, the Storage Post Portfolio Mortgage Loan, theTysons Tower Mortgage Loan and the National Anchored Retail Portfolio MortgageLoan. As a result, Rialto Capital Advisors, LLC is a “servicer” as defined inItem 1108(a)(2)(iii) of Regulation AB, in the capacities described above,because it is servicing mortgage loans that constituted 10% or more of theassets 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 Rialto Capital Advisors, LLC inthe capacities described above are listed in the Exhibit Index.

Park Bridge Lender Services LLC isthe operating advisor of the Park Tower at Transbay Mortgage Loan, the 230 ParkAvenue South Mortgage Loan, the Storage Post Portfolio Mortgage Loan, the 360North Crescent Drive Mortgage Loan, the Tysons Tower Mortgage Loan and theNational Anchored Retail Portfolio Mortgage Loan.  As a result, ParkBridge Lender Services LLC is a servicing function participant in thecapacities described above, because it is servicing mortgage loans that constituted5% or more of the assets of the issuing entity as of its cut-off date. Theassessments of compliance with applicable servicing criteria and accountants’attestation reports delivered by Park Bridge Lender Services LLC in thecapacities described above are listed in the Exhibit Index.

Wilmington Trust, NationalAssociation acts as trustee of  the mortgage loans serviced under thePooling and Servicing Agreement, the Park Tower at Transbay Mortgage Loan, the230 Park Avenue South Mortgage Loan, the Storage Post Portfolio Mortgage Loan,the Tysons Tower Mortgage Loan, the National Anchored Retail Portfolio MortgageLoan, the Midtown Center Mortgage Loan and the 360 North Crescent DriveMortgage Loan.  Pursuant to the Pooling and Servicing Agreement, thepooling and servicing agreement for the BANK 2019-BNK21 Transaction, the trustand servicing agreement for the DCOT 2019-MTC Transaction and the pooling andservicing agreement for the BANK 2019-BNK23 Transaction, the trustee isrequired to provide an assessment of compliance with applicable servicingcriteria 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 Park Tower at Transbay MortgageLoan, the 230 Park Avenue South Mortgage Loan, the Storage Post PortfolioMortgage Loan, the Tysons Tower Mortgage Loan, the National Anchored RetailPortfolio Mortgage Loan, the Midtown Center Mortgage Loan and the 360 NorthCrescent Drive Mortgage Loan have delivered one or more assessments ofcompliance with respect to Item 1122(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 Servicing Agreementand the primary servicer of the Park Tower at Transbay Mortgage Loan, the 230Park Avenue South Mortgage Loan, the Tysons Tower Mortgage Loan, the NationalAnchored Retail Portfolio Mortgage Loan, the Midtown Center Mortgage Loan andthe 360 North Crescent Drive Mortgage Loan to remit tax payments received fromthe escrow accounts of borrowers to local taxing authorities, to report taxamounts due, to verify tax parcel information, and to verify non-escrow taxpayments. These servicing functions are included within the servicing criteriaset forth in Items 1122(d)(4)(xi) and 1122(d)(4)(xii) of Regulation AB. Therefore, under the principles-based definition of “servicer” set forth inItem 1101(j) of Regulation AB that looks to the functions that an entityperforms, this vendor is a “servicer” for the purposes of Item 1122 ofRegulation 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 Park Tower at Transbay Mortgage Loan, the 230 Park AvenueSouth Mortgage Loan, the Tysons Tower Mortgage Loan, the National AnchoredRetail Portfolio Mortgage Loan, the Storage Post Portfolio Mortgage Loan, theMidtown Center Mortgage Loan and the 360 North Crescent Drive Mortgage Loan areomitted from this Annual Report on Form 10-K as the certificate administratorpursuant to the related pooling and servicing agreement or trust and servicingagreement does not perform any activities that address servicing criteria withrespect to the issuing entity and because they are each not a “servicer” thatmeets the criteria in Item 1108(a)(2)(i) through (iii) of Regulation AB.

With respect to the *pari passu*loan combinations that include the Storage Post Portfolio Mortgage Loan and theMidtown Center Mortgage Loan, the servicer compliance statements of MidlandLoan Services, a Division of PNC Bank, National Association as primary servicerof the Storage Post Portfolio Mortgage Loan and CWCapital Asset Management LLCas special servicer of the Midtown Center Mortgage Loan, listed on the ExhibitIndex are omitted from this Annual Report on Form 10-K as they are not requiredby Item 1123 of Regulation AB to be included on this Annual Report on Form 10-Kbecause they are each an unaffiliated party that is not a “servicer” that meetsthe 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. **

[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 BeneficialOwners and 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 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 CWCapital Asset Management LLC, as special servicer,and Wells Fargo Bank, National Association, as certificate administrator and ascustodian.

From time to time, CWCapital AssetManagement LLC, a Delaware limited liability company (“CWCAM”), is a party tolawsuits and other legal proceedings as part of its duties as a specialservicer (e.g., enforcement of loan obligations) and/or arising in the ordinarycourse of business. Other than as set forth in the following paragraphs, thereare currently no legal proceedings pending, and no legal proceedings known tobe contemplated by governmental authorities, against CWCAM or of which any ofits property is the subject, that are material to the certificateholders. 

On December 17, 2015, U.S. Bank National Association, thetrustee under five pooling and servicing agreements for (i) Wachovia BankCommercial Mortgage Trust 2007-C30, (ii) COBALT CMBS Commercial Trust 2007-C2,(iii) Wachovia Bank Commercial Mortgage Trust 2007-C31, (iv) ML-CFC CommercialMortgage Trust 2007-5 and (v) ML-CFC Commercial Mortgage Trust 2007-6 commenceda proceeding with the Second Judicial District Court of Ramsey County,Minnesota (the “State Court”) for a declaratory judgment as to the properallocation of certain proceeds (“Disputed Proceeds”) received by CWCAM inconnection with the sale of the Peter Cooper Village and Stuyvesant Townproperty in New York, New York securing loans held by those trusts.  CWCAMwas the special servicer of such property.  The petition requests theState Court to instruct the trustee, the trust beneficiaries, and any otherinterested parties as to the amount of the Disputed Proceeds, if any, thatconstitute penalty interest and/or the amount of the Disputed Proceeds, if any,that constitute gain-on-sale proceeds, with respect to each trust.  OnFebruary 24, 2016, CWCAM made a limited appearance with the State Court to filea motion to dismiss this proceeding based on lack of jurisdiction, mootness,standing and forum non conveniens.  On July 19, 2016, the State Courtdenied CWCAM’s motion to dismiss.  On July 22, 2016, the action wasremoved to federal court in Minnesota (“Federal Court”).  On October 21,2016, the Federal Court held a hearing on the motion to transfer the action tothe United States District Court for the Southern District of New York (“SDNYCourt”), a motion to remand to state court and a motion to hear CWCAM’s requestfor reconsideration of the motion to dismiss.  On March 14, 2017, theFederal Court reserved the determination on the motion to hear CWCAM’s requestfor reconsideration of the motion to dismiss, denied the motion to remand thematter to state court and granted the motion to transfer the proceeding to theSDNY Court.  Cross motions for judgment on the pleadings were filed butthe SDNY Court was unable to decide the case based on the pleadings and theSDNY Court ordered discovery.  All fact discovery was completed inDecember, 2018 and expert discovery was completed on March 15, 2019.  Theparties submitted cross motions for summary judgment, and on March 19, 2020,the SDNY Court entered an opinion and order in which it granted summaryjudgment in CWCAM’s favor and held that CWCAM was entitled to the entire amountof penalty interest and that CWCAM’s determination of Yield Maintenance wascorrect.  In the 127-page opinion, the SDNY Court found for CWCAM on everyissue presented by the trustee’s petition, namely, that the funds in disputeconstitute penalty interest and yield maintenance, not gain-on-sale proceeds,and that the amount of penalty interest and yield maintenance was correctlycalculated. An appeal of the SDNY Court’s decision was taken on April 29,2020.  Oral argument on the appeal occurred on June 21, 2021.  OnJuly 14, 2022, the Second Circuit entered a decision affirming in part and reversingin part the SDNY Court’s decision and remanding to the SDNY Court for furtherproceedings.  The Second Circuit affirmed the SDNY’s Court holding thatPenalty Interest and Yield Maintenance are paid before Gain-On-SaleProceeds.  The Second Circuit reversed and remanded for furtherproceedings that portion of the SDNY Court’s decision related to approximately$67.2 million in interest on advances.   On January 13, 2023, theparties entered into a settlement agreement, in which (among other things) theyagreed to stipulate that the amount of interest on advances that accrued on orbefore June 3, 2014 is $27.5 million, and that CWCAM would pay that amount intoescrow for distribution to certificateholders upon the entry of an order by theCourt approving the settlement.  U.S. Bank National Association, asTrustee for the trusts, provided notice of the settlement to all parties ininterest via a notice program approved by the Court.  A hearing on thesettlement is scheduled for March 16, 2023.

On December 1, 2017, a complaint against CWCAM and others wasfiled in the United States District Court for the Southern District of New Yorkstyled as CWCapital Cobalt Vr Ltd. v. CWCapital Investments LLC, et al., No.17-cv-9463 (the “Original Complaint”). The gravamen of the Original Complaint alleged breaches of a contract and fiduciary duties by CWCAM’saffiliate, CWCapital Investments LLC in its capacity as collateral manager forthe collateralized debt obligation transaction involving CWCapital Cobalt Vr,Ltd. In total, there are 14 counts pled in the Original Complaint. Of those 14,5 claims were asserted against CWCAM for aiding and abetting breach offiduciary duty, conversion and unjust enrichment. On May 23, 2018, the OriginalComplaint was dismissed for lack of subject matter jurisdiction.   OnJune 28, 2018, CWCapital Cobalt Vr Ltd. filed a substantially similar complaintin the Supreme Court of the State of New York, County of New York styled asCWCapital Cobalt Vr Ltd. v. CWCapital Investments LLC, et al., Index No.653277/2018 (the “New Complaint”).  The gravamen of the New Complaint isthe same as the previous complaint filed in the United State District Court forthe Southern District of New York.  In total there are 16 counts pled inthe New Complaint. Of those 16 counts, 5 claims were asserted against CWCAM foraiding and abetting breach of fiduciary duty, conversion and unjust enrichment,1 count seeks a declaratory judgement that the plaintiff has the right toenforce the contracts in question and 1 count seeks an injunction requiring thedefendants to recognize the plaintiff as the directing holder for the trusts inquestion. On January 11, 2019, the plaintiff dismissed with prejudice thedeclaratory judgment and injunction counts.  The New Complaint and relatedsummons was not served on the defendants until July 13, 2018 and July 16,2018.  The plaintiff’s motion for a preliminary injunction was denied bythe court on July 31, 2018.  On August 3, 2018, the defendants, includingCWCAM, filed a motion to dismiss the New Complaint in its entirety. On August20, 2019, the court entered an order granting defendants’ motion almost in itsentirety, dismissing 11 of the 16 counts and partially dismissing 2 additionalcounts.  Of the remaining counts, 2 are asserted against CWCAM for aidingand abetting breach of fiduciary duty and unjust enrichment.  On September19, 2019, CWCapital Cobalt Vr Ltd. filed a notice of appeal relating to theAugust 20, 2019 dismissal order and on September 26, 2019, filed an amendedcomplaint against CWCI and CWCAM attempting to address deficiencies relating tocertain of the claims dismissed by the August 20, 2019 order.  CWCI andCWCAM filed its Motion to Dismiss the amended complaint on October 28,2019.  The court heard argument on the Motion to Dismiss the amendedcomplaint on January 22, 2020 and on October 23, 2020, the court granted themotion dismissing the amended claims.  On November 30, 2020, CWCapitalCobalt Vr Ltd filed a notice of appeal relating to the October 23, 2020dismissal order.  On April 27, 2021, the First Department affirmed thedismissal as to claims against CWCAM that were part of the August 20, 2019dismissal, but reversed the dismissal of two counts for breach of theCollateral Management Agreement against CWCI.  CWCI sought leave to filean appeal of the decision. The plaintiff also sought leave to appeal thedismissal of the claims against CWCAM.  Both requests for leave weredenied by the First Department.  On May 15, 2020, CWCI and CWCAM filed amotion to renew its motion to dismiss as to 4 of the remaining counts(including the remaining two counts against CWCAM for aiding and abettingbreach of fiduciary duty and unjust enrichment), based on a decision entered byJudge Failla in a trust instruction proceeding  in the US District Courtfor the Southern District of New York awarding summary judgment in favor ofCWCAM.  On September 7, 2021, the court denied the motion to renew. CWCI and CWCAM filed a notice of appeal, which they perfected by the filing oftheir opening brief on July 1, 2022.  On November 15, 2022, the FirstDepartment affirmed the court’s denial of the motion to renew.  On October1, 2021, CWCI and CWCAM moved to reargue the denial of the motion to renew (oralternatively, the motion to dismiss) with respect to certain of Cobalt’sclaims, including the remaining 2 claims against CWCAM, based on the FirstDepartment’s April 27, 2021 decision.  On March 24, 2022, the court deniedthe relief sought in the motion to reargue.  CWCI and CWCAM have appealedthe court’s decision on the motion to reargue and filed their opening brief onJuly 11, 2022.  The appeal was dismissed as being non-appealable on August30, 2022.  CWCAM believes that it has performed its obligations under the relatedpooling and servicing agreements in good faith and the remaining allegations inthe New Complaint are without merit.   

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 and by IKB International and IKB Deutsche Industriebank 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 appealed the district court’s decision to theUnited States Court of Appeals for the Second Circuit. The Company previouslysettled two class actions filed by institutional investors and an action filedby the National Credit Union Administration with similar allegations. Inaddition, Park Royal I LLC and Park Royal II LLC have filed substantiallysimilar lawsuits in New York state court alleging Wells Fargo Bank, N.A., astrustee, failed to take appropriate actions upon learning of defective mortgageloan documentation.

**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 November 15, 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 Park Tower at Transbay MortgageLoan, the 230 Park Avenue South Mortgage Loan, the Storage Post PortfolioMortgage Loan, the Tysons Tower Mortgage Loan and the National Anchored RetailPortfolio Mortgage Loan, which are being serviced and administered pursuant tothe pooling and servicing agreement for the BANK 2019-BNK21 Transaction, are attachedhereto under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit Zto the pooling and servicing agreement for the BANK 2019-BNK21 Transactionincorporated by reference as Exhibit 4.2 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theBANK 2019-BNK21 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 Midtown Center Mortgage Loan,which is being serviced and administered pursuant to the trust and servicingagreement for the DCOT 2019-MTC Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit L to the trust andservicing agreement for the DCOT 2019-MTC Transaction incorporated by referenceas Exhibit 4.3 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the DCOT 2019-MTCTransaction 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 360 North Crescent Drive MortgageLoan, which is being serviced and administered pursuant to the pooling andservicing agreement for the BANK 2019-BNK23 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit Z to thepooling and servicing agreement for the BANK 2019-BNK23 Transactionincorporated by reference as Exhibit 4.4 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theBANK 2019-BNK23 Transaction responsible for each applicable servicing criteriaset forth in Item 1122(d).

The report on assessmentof compliance for the twelve months ended December 31, 2022, furnished pursuantto Item 1122 of Regulation AB by KeyBank National Association (“KeyBank”), asservicer, discloses that the following material instance of noncomplianceoccurred with respect to its platform:

The examination performed by Ernst & Young LLP identifiedan instance of material noncompliance with the servicing criteria set forth inItem 1122(d)(4)(ix) of Regulation AB applicable to KeyBank during the yearended December 31, 2022. During compliance testing, it was discovered, that notall FlexARM loan mortgagors were offered loan rates within 45-60 days beforethe rate change date, as required per the related pool asset documents. Per therelated note, if the holder fails to offer a loan rate within 45-60 days of anychange date a margin of 2.25% is to be used. Given the notification was notmade to the borrowers, a 3% margin was incorrectly applied. The noncompliancein Item 1122 (d)(4)(ix) is related to a servicing portfolio which is whollyowned by the investor and is not held in a publicly traded security.

The following remediation procedures have been initiated byKeyBank: (i) the impacted mortgage loans are currently in the process of beingidentified, (ii) investor contact has been initiated, (iii) corrective actionsare being considered and will be tracked and monitored by senior management,(iv) procedures will be reviewed and revised, if necessary, to include newtracking and action steps to prevent this situation from recurring in thefuture, and (v) training will be provided to the relevant staff members toprevent a recurrence.

**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. Exhibit 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 November 1, 2019, by and among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as General Master Servicer, KeyBank National Association, asGeneral Special Servicer, National Cooperative Bank, N.A., as NCB MasterServicer and as NCB Special Servicer, Wells Fargo Bank, National Association,as Certificate Administrator, Wilmington Trust, National Association, asTrustee, and Pentalpha Surveillance LLC, as Operating Advisor and AssetRepresentations Reviewer (filed as Exhibit 4.1 to the registrant’s CurrentReport on Form 8-K filed on November 15, 2019 under Commission File No.333-226486-10 and incorporated by reference herein). 

4.2          Poolingand Servicing Agreement, dated as of October 1, 2019, by and among Banc ofAmerica Merrill Lynch Commercial Mortgage Inc., as Depositor, Wells Fargo Bank,National Association, as Master Servicer, Rialto Capital Advisors, LLC, asSpecial Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator, Wilmington Trust, National Association, as Trustee, and ParkBridge Lender Services LLC, as Operating Advisor and Asset RepresentationsReviewer (filed as Exhibit 99.5 to the registrant’s Current Report on Form 8-Kfiled on November 15, 2019 under Commission File No. 333-226486-10 andincorporated by reference herein).

4.3          Trustand Servicing Agreement, dated as of October 30, 2019, by and among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, CWCapital Asset Management LLC, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee (filed as Exhibit 99.6 tothe registrant’s Current Report on Form 8-K filed on November 15, 2019 underCommission File No. 333-226486-10 and incorporated by reference herein).

4.4          Poolingand Servicing Agreement, dated as of December 1, 2019, by and among MorganStanley Capital I Inc., as Depositor, Wells Fargo Bank, National Association,as Master Servicer, KeyBank National Association, as Special Servicer, WellsFargo Bank, National Association, as Certificate Administrator, WilmingtonTrust, National Association, as Trustee, and Park Bridge Lender Services LLC,as Operating Advisor and Asset Representations Reviewer (filed as Exhibit 99.1to the registrant’s Current Report on Form 8-K filed on December 16, 2019 underCommission File No. 333-226486-10 and incorporated 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        KeyBank National Association, as General SpecialServicer

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        Pentalpha Surveillance LLC, as Operating Advisor

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, asServicing Function Participant for the Custodian

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

33.13      Rialto Capital Advisors, LLC, as Special Servicerof the Park Tower at Transbay Mortgage Loan

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

33.15      Wells Fargo Bank, National Association, asCustodian of the Park Tower at Transbay Mortgage Loan (see Exhibit 33.7)

33.16      Park Bridge Lender Services LLC, as OperatingAdvisor of the Park Tower at Transbay Mortgage Loan

33.17      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Park Tower at Transbay Mortgage Loan (see Exhibit 33.9)

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

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

33.20      Rialto Capital Advisors, LLC, as Special Servicerof the 230 Park Avenue South Mortgage Loan (see Exhibit 33.13)

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

33.22      Wells Fargo Bank, National Association, asCustodian of the 230 Park Avenue South Mortgage Loan (see Exhibit 33.7)

33.23      Park Bridge Lender Services LLC, as OperatingAdvisor of the 230 Park Avenue South Mortgage Loan (see Exhibit 33.16)

33.24      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 230 Park Avenue South Mortgage Loan (see Exhibit 33.9)

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

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

33.27      Rialto Capital Advisors, LLC, as Special Servicerof the Storage Post Portfolio Mortgage Loan (see Exhibit 33.13)

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

33.29      Wells Fargo Bank, National Association, asCustodian of the Storage Post Portfolio Mortgage Loan (see Exhibit 33.7)

33.30      Park Bridge Lender Services LLC, as OperatingAdvisor of the Storage Post Portfolio Mortgage Loan (see Exhibit 33.16)

33.31      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Storage Post Portfolio Mortgage Loan (see Exhibit 33.9)

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

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

33.34      Rialto Capital Advisors, LLC, as Special Servicer ofthe Tysons Tower Mortgage Loan (see Exhibit 33.13)

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

33.36      Wells Fargo Bank, National Association, asCustodian of the Tysons Tower Mortgage Loan (see Exhibit 33.7)

33.37      Park Bridge Lender Services LLC, as OperatingAdvisor of the Tysons Tower Mortgage Loan (see Exhibit 33.16)

33.38      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Tysons Tower Mortgage Loan (see Exhibit 33.9)

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

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

33.41      Rialto Capital Advisors, LLC, as Special Servicerof the National Anchored Retail Portfolio Mortgage Loan (see Exhibit 33.13)

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

33.43      Wells Fargo Bank, National Association, asCustodian of the National Anchored Retail Portfolio Mortgage Loan (see Exhibit33.7)

33.44      Park Bridge Lender Services LLC, as OperatingAdvisor of the National Anchored Retail Portfolio Mortgage Loan (see Exhibit33.16)

33.45      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the National Anchored Retail Portfolio Mortgage Loan (seeExhibit 33.9)

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

33.47      Wells Fargo Bank, National Association, as PrimaryServicer of the Midtown Center Mortgage Loan (see Exhibit 33.1)

33.48      CWCapital Asset Management LLC, as SpecialServicer of the Midtown Center Mortgage Loan

33.49      Wilmington Trust, National Association, as Trustee of the Midtown CenterMortgage Loan (Omitted. See Explanatory Notes.)

33.50      Wells Fargo Bank, National Association, as Custodianof the Midtown Center Mortgage Loan (see Exhibit 33.7)

33.51      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Midtown Center 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      Wells Fargo Bank, National Association, as PrimaryServicer of the 360 North Crescent Drive Mortgage Loan (see Exhibit 33.1)

33.54      KeyBank National Association, as Special Servicerof the 360 North Crescent Drive Mortgage Loan (see Exhibit 33.3)

33.55      Wilmington Trust, National Association, as Trustee of the 360 North CrescentDrive Mortgage Loan (Omitted. See Explanatory Notes.)

33.56      Wells Fargo Bank, National Association, as Custodianof the 360 North Crescent Drive Mortgage Loan (see Exhibit 33.7)

33.57      Park Bridge Lender Services LLC, as OperatingAdvisor of the 360 North Crescent Drive Mortgage Loan (see Exhibit 33.16)

33.58      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 360 North Crescent Drive Mortgage Loan (see Exhibit 33.9)

33.59      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        KeyBank National Association, as General SpecialServicer

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        Pentalpha Surveillance LLC, as Operating Advisor

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

34.13      Rialto Capital Advisors, LLC, as Special Servicerof the Park Tower at Transbay Mortgage Loan

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

34.15      Wells Fargo Bank, National Association, asCustodian of the Park Tower at Transbay Mortgage Loan (see Exhibit 34.7)

34.16      Park Bridge Lender Services LLC, as OperatingAdvisor of the Park Tower at Transbay Mortgage Loan

34.17      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Park Tower at Transbay Mortgage Loan (see Exhibit 34.9)

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

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

34.20      Rialto Capital Advisors, LLC, as Special Servicerof the 230 Park Avenue South Mortgage Loan (see Exhibit 34.13)

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

34.22      Wells Fargo Bank, National Association, asCustodian of the 230 Park Avenue South Mortgage Loan (see Exhibit 34.7)

34.23      Park Bridge Lender Services LLC, as OperatingAdvisor of the 230 Park Avenue South Mortgage Loan (see Exhibit 34.16)

34.24      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 230 Park Avenue South Mortgage Loan (see Exhibit 34.9)

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

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

34.27      Rialto Capital Advisors, LLC, as Special Servicerof the Storage Post Portfolio Mortgage Loan (see Exhibit 34.13)

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

34.29      Wells Fargo Bank, National Association, asCustodian of the Storage Post Portfolio Mortgage Loan (see Exhibit 34.7)

34.30      Park Bridge Lender Services LLC, as OperatingAdvisor of the Storage Post Portfolio Mortgage Loan (see Exhibit 34.16)

34.31      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Storage Post Portfolio Mortgage Loan (see Exhibit 34.9)

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

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

34.34      Rialto Capital Advisors, LLC, as Special Servicerof the Tysons Tower Mortgage Loan (see Exhibit 34.13)

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

34.36      Wells Fargo Bank, National Association, asCustodian of the Tysons Tower Mortgage Loan (see Exhibit 34.7)

34.37      Park Bridge Lender Services LLC, as OperatingAdvisor of the Tysons Tower Mortgage Loan (see Exhibit 34.16)

34.38      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Tysons Tower Mortgage Loan (see Exhibit 34.9)

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

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

34.41      Rialto Capital Advisors, LLC, as Special Servicerof the National Anchored Retail Portfolio Mortgage Loan (see Exhibit 34.13)

34.42      Wilmington Trust, National Association, as Trustee of the National Anchored RetailPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.43      Wells Fargo Bank, National Association, asCustodian of the National Anchored Retail Portfolio Mortgage Loan (see Exhibit34.7)

34.44      Park Bridge Lender Services LLC, as OperatingAdvisor of the National Anchored Retail Portfolio Mortgage Loan (see Exhibit34.16)

34.45      CoreLogic Solutions, LLC, as Servicing Function Participantof the National Anchored Retail Portfolio Mortgage Loan (see Exhibit 34.9)

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

34.47      Wells Fargo Bank, National Association, as PrimaryServicer of the Midtown Center Mortgage Loan (see Exhibit 34.1)

34.48      CWCapital Asset Management LLC, as Special Servicerof the Midtown Center Mortgage Loan

34.49      Wilmington Trust, National Association, as Trustee of the Midtown CenterMortgage Loan (Omitted. See Explanatory Notes.)

34.50      Wells Fargo Bank, National Association, asCustodian of the Midtown Center Mortgage Loan (see Exhibit 34.7)

34.51      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Midtown Center 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      Wells Fargo Bank, National Association, as PrimaryServicer of the 360 North Crescent Drive Mortgage Loan (see Exhibit 34.1)

34.54      KeyBank National Association, as Special Servicerof the 360 North Crescent Drive Mortgage Loan (see Exhibit 34.3)

34.55      Wilmington Trust, National Association, as Trustee of the 360 North CrescentDrive Mortgage Loan (Omitted. See Explanatory Notes.)

34.56      Wells Fargo Bank, National Association, asCustodian of the 360 North Crescent Drive Mortgage Loan (see Exhibit 34.7)

34.57      Park Bridge Lender Services LLC, as OperatingAdvisor of the 360 North Crescent Drive Mortgage Loan (see Exhibit 34.16)

34.58      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 360 North Crescent Drive Mortgage Loan (see Exhibit 34.9)

34.59      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        KeyBank National Association, as General SpecialServicer

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

35.8        Rialto Capital Advisors, LLC, as Special Servicerof the Park Tower at Transbay Mortgage Loan

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

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

35.11      Midland Loan Services, a Division of PNC Bank, National Association, as PrimaryServicer of the Storage Post Portfolio Mortgage Loan (Omitted. See ExplanatoryNotes.) 

35.12      Rialto Capital Advisors, LLC, as Special Servicerof the Storage Post Portfolio Mortgage Loan (see Exhibit 35.8)

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 35.8)

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 35.8)

35.17      Wells Fargo Bank, National Association, as PrimaryServicer of the Midtown Center Mortgage Loan (see Exhibit 35.1)

35.18      CWCapital Asset Management LLC, as Special Servicer of the Midtown CenterMortgage Loan (Omitted. See Explanatory Notes.)

35.19      Wells Fargo Bank, National Association, as PrimaryServicer of the 360 North Crescent Drive Mortgage Loan (see Exhibit 35.1)

35.20      KeyBank National Association, as Special Servicerof the 360 North Crescent Drive Mortgage Loan (see Exhibit 35.3)

99.1        MortgageLoan Purchase Agreement, dated and effective as of October 25, 2019, betweenWells Fargo Commercial Mortgage Securities, Inc. and Bank of America, NationalAssociation (filed as Exhibit 99.1 to the registrant’s Current Report on Form8-K filed on November 15, 2019 under Commission File No. 333-226486-10 andincorporated by reference herein).

99.2        MortgageLoan Purchase Agreement, dated and effective as of October 25, 2019, betweenWells Fargo Commercial Mortgage Securities, Inc. and Wells Fargo Bank, NationalAssociation (filed as Exhibit 99.2 to the registrant’s Current Report on Form8-K filed on November 15, 2019 under Commission File No. 333-226486-10 andincorporated by reference herein).

99.3        MortgageLoan Purchase Agreement, dated and effective as of October 25, 2019, betweenWells Fargo Commercial Mortgage Securities, Inc. and Morgan Stanley MortgageCapital Holdings LLC (filed as Exhibit 99.3 to the registrant’s Current Reporton Form 8-K filed on November 15, 2019 under Commission File No. 333-226486-10and incorporated by reference herein).

99.4        MortgageLoan Purchase Agreement, dated and effective as of October 25, 2019, betweenWells Fargo Commercial Mortgage Securities, Inc. and National Cooperative Bank,N.A. (filed as Exhibit 99.4 to the registrant’s Current Report on Form 8-Kfiled on November 15, 2019 under Commission File No. 333-226486-10 andincorporated by reference herein).

99.5        AgreementBetween Note Holders, dated as of September 16, 2019, by and between Bank ofAmerica, N.A., as Initial Note A-1 Holder, Bank of America, N.A., as InitialNote A-2 Holder, Bank of America, N.A., as Initial Note A-3 Holder, Bank ofAmerica, N.A., as Initial Note A-4 Holder, Bank of America, N.A., as InitialNote A-5 Holder, Bank of America, N.A., as Initial Note A-6 Holder, Bank ofAmerica, N.A., as Initial Note A-7 Holder, Bank of America, N.A., as InitialNote A-8 Holder, Bank of America, N.A., as Initial Note A-9 Holder, and Bank ofAmerica, N.A., as Initial Note A-10 Holder (filed as Exhibit 99.7 to theregistrant’s Current Report on Form 8-K filed on November 15, 2019 underCommission File No. 333-226486-10 and incorporated by reference herein).

99.6        AgreementBetween Note Holders, dated as of October 23, 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, Wells Fargo Bank, NationalAssociation, as Initial Note A-3 Holder, Bank of America, National Association,as Initial Note A-4 Holder, Bank of America, National Association, as InitialNote A-5 Holder, Bank of America, National Association, as Initial Note A-6Holder, and JPMorgan Chase Bank, National Association, as Initial Note A-7Holder (filed as Exhibit 99.8 to the registrant’s Current Report on Form 8-Kfiled on November 15, 2019 under Commission File No. 333-226486-10 andincorporated by reference herein).

99.7        Co-LenderAgreement, dated as of September 30, 2019, by and among Wells Fargo Bank,National Association, as Initial Note A-1-1 Holder, Initial Note A-2-1 Holder,Initial Note A-2-2 Holder, Initial Note A-2-3 Holder and Initial Note B-1-1Holder, Bank of America, N.A., as Initial Note A-1-2 Holder, Initial Note A-2-4Holder, Initial Note A-2-5 Holder and Initial Note B-1-2 Holder, and GoldmanSachs Bank USA, as Initial Note A-1-3 Holder, Initial Note A-2-6 Holder,Initial Note A-2-7 Holder and Initial Note B-1-3 Holder (filed as Exhibit 99.9to the registrant’s Current Report on Form 8-K filed on November 15, 2019 underCommission File No. 333-226486-10 and incorporated by reference herein).

99.8        AgreementBetween Note Holders, dated as of October 23, 2019, by and between MorganStanley Bank, N.A., as Initial Note A-1 Holder, Morgan Stanley Bank, N.A., asInitial Note A-2 Holder, Morgan Stanley Bank, N.A., as Initial Note A-3 Holder,and Morgan Stanley Mortgage Capital Holdings LLC, as Initial Agent (filed asExhibit 99.10 to the registrant’s Current Report on Form 8-K filed on November15, 2019 under Commission File No. 333-226486-10 and incorporated by referenceherein).

99.9        AgreementBetween Note Holders, dated as of November 15, 2019, by and between Wells FargoBank, National Association, as Initial Note A-1 Holder, and Wells Fargo Bank,National Association, as Initial Note A-2 Holder (filed as Exhibit 99.11 to theregistrant’s Current Report on Form 8-K filed on November 15, 2019 underCommission File No. 333-226486-10 and incorporated by reference herein).

99.10      AgreementBetween Note Holders, dated as of October 23, 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, Wells Fargo Bank, NationalAssociation, as Initial Note A-3 Holder, JPMorgan Chase Bank, NationalAssociation, as Initial Note A-4 Holder, JPMorgan Chase Bank, NationalAssociation, as Initial Note A-5 Holder, JPMorgan Chase Bank, NationalAssociation, as Initial Note A-6 Holder, and JPMorgan Chase Bank, NationalAssociation, as Initial Note A-7 Holder (filed as Exhibit 99.12 to theregistrant’s Current Report on Form 8-K filed on November 15, 2019 underCommission File No. 333-226486-10 and incorporated by reference herein).

99.11      AgreementBetween Note Holders, dated as of October 23, 2019, by and between MorganStanley Bank, N.A., as Initial Note A-1 Holder, Morgan Stanley Bank, N.A., asInitial Note A-2 Holder, Morgan Stanley Bank, N.A., as Initial Note A-3 Holder,and Morgan Stanley Mortgage Capital Holdings LLC, as Initial Agent (filed asExhibit 99.13 to the registrant’s Current Report on Form 8-K filed on November15, 2019 under Commission File No. 333-226486-10 and incorporated by referenceherein).

(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/ AnthonySfarra

AnthonySfarra, President

(senior officer in charge ofsecuritization of the depositor)

Date: March 15, 2023