**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, 2022or**

**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: 333-226943-04**

**Central Index Key Number of the issuing entity:0001785881**

**Benchmark 2019-B13 Mortgage Trust**

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

** **

**Central Index Key Number of the depositor: 0001013454**

**Deutsche Mortgage & AssetReceiving Corporation**

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

** **

**Central Index Key Number of the sponsor: 0001541294**

**German American Capital Corporation**

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

** **

**Central Index Key Number of the sponsor: 0000835271**

**JPMorgan Chase Bank, NationalAssociation**

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

** **

**Central Index Key Number of the sponsor: 0001701238**

**Citi Real Estate Funding Inc.**

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

** **

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

**the issuing entity)** | **38-4128726**

**38-4128727**

**(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 principalexecutive offices of the issuing entity)**

**21045**

**(Zip Code)**

**Registrant’s telephone number,including area code:**

**(212) 250-2500**

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 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                                                                                                       Accelerated filer                                     o

Non-acceleratedfiler          ⌧  (Do not check if asmaller 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

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 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 Sunset North Mortgage Loan, the 900 &990 Stewart Avenue Mortgage Loan, the City Hyde Park Mortgage Loan, theRivertowne Commons Mortgage Loan, the Wind Creek Leased Fee Mortgage Loan andthe Beverly Hills BMW Mortgage Loan, which constituted approximately 7.9%,4.7%, 4.7%, 4.7%, 4.4% and 4.1%, respectively, of the asset pool of the issuingentity as of its cut-off date, are each an asset of the issuing entity and areeach part of a loan combination that includes (a) with respect to the SunsetNorth Mortgage Loan, two other *pari passu* loans, which are not assets ofthe issuing entity, (b) with respect to the 900 & 990 Stewart AvenueMortgage Loan, one other *pari passu* loan, which is not an asset of theissuing entity, (c) with respect to the City Hyde Park Mortgage Loan, two other*pari passu* loans, which are not assets of the issuing entity, (d) withrespect to the Rivertowne Commons Mortgage Loan, one other *pari passu*loan, which is not an asset of the issuing entity, (e) with respect to the WindCreek Leased Fee Mortgage Loan, four other *pari passu* loans, which arenot assets of the issuing entity and (f) with respect to the Beverly Hills BMWMortgage Loan, one other *pari passu* loan, which is not an asset of theissuing entity. These loan combinations, including the Sunset North MortgageLoan, the 900 & 990 Stewart Avenue Mortgage Loan, the City Hyde ParkMortgage Loan, the Rivertowne Commons Mortgage Loan, the Wind Creek Leased FeeMortgage Loan and the Beverly Hills BMW 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 3 Columbus Circle Mortgage Loan, whichconstituted approximately 3.9% of the asset pool of the issuing entity as ofits cut-off date.  The 3 Columbus Circle Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the 3 ColumbusCircle Mortgage Loan, fourteen other *pari passu* loans and twosubordinate companion loans, which are not assets of the issuing entity. A *paripassu* portion of the loan combination was securitized in the Benchmark2019-B10 Mortgage Trust transaction, Commission File Number 333-226943-02 (the“Benchmark 2019-B10 Transaction”). This loan combination, including the3 Columbus Circle Mortgage Loan, is being serviced and administered pursuant tothe pooling and servicing agreement for the Benchmark 2019-B10 Transaction,which is incorporated by reference as Exhibit 4.2 to this Annual Report on Form10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Osborn Triangle Mortgage Loan, whichconstituted approximately 5.3% of the asset pool of the issuing entity as ofits cut-off date.  The Osborn Triangle Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the OsbornTriangle Mortgage Loan, six other *pari passu* loans and one subordinatecompanion loan, which are not assets of the issuing entity. A *pari passu*portion of the loan combination was securitized in the J.P. Morgan ChaseCommercial Mortgage Securities Trust 2019-OSB transaction (the “JPMCC2019-OSB Transaction”). This loan combination, including the OsbornTriangle Mortgage Loan, is being serviced and administered pursuant to thetrust and servicing agreement for the JPMCC 2019-OSB Transaction, which isincorporated by reference as Exhibit 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 30 Hudson Yards Mortgage Loan, whichconstituted approximately 4.2% of the asset pool of the issuing entity as ofits cut-off date.  The 30 Hudson Yards Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the 30 HudsonYards Mortgage Loan, twenty-eight other *pari passu* loans and threesubordinate companion loans, which are not assets of the issuing entity. A *paripassu* portion of the loan combination was securitized in the Hudson Yards2019-30HY Mortgage Trust transaction (the “Hudson Yards 2019-30HYTransaction”). This loan combination, including the 30 Hudson YardsMortgage Loan, is being serviced and administered pursuant to the trust andservicing agreement for the Hudson Yards 2019-30HY Transaction, which isincorporated by reference as Exhibit 4.4 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 5.3% 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-two 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 4.5 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 Woodlands Mall Mortgage Loan, whichconstituted approximately 3.2% of the asset pool of the issuing entity as ofits cut-off date.  The Woodlands Mall Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the WoodlandsMall Mortgage Loan, eight other *pari passu* loans and one subordinatecompanion loan, which are not assets of the issuing entity. A *pari passu*portion of the loan combination was securitized in the Benchmark 2019-B12Mortgage Trust transaction, Commission File Number 333-228597-01 (the “Benchmark2019-B12 Transaction”). This loan combination, including the Woodlands MallMortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the Benchmark 2019-B12 Transaction, which isincorporated by reference as Exhibit 4.6 to this Annual Report on Form 10-K.

The Exhibit Index describes exhibitsprovided by certain parties (in their capacities indicated on the ExhibitIndex) with respect to the Northpoint Tower Mortgage Loan, which constitutedapproximately 2.6% of the asset pool of the issuing entity as of its cut-offdate.  The Northpoint Tower Mortgage Loan is an asset of the issuingentity and is part of a loan combination that includes the Northpoint TowerMortgage Loan and three other *pari passu* loans, which are not assets ofthe issuing entity. A *pari passu* portion of the loan combination wassecuritized in the GS Mortgage Securities Trust 2019-GC42 transaction,Commission File Number 333-226082-04 (the “GSMS 2019-GC42 Transaction”).This loan combination, including the Northpoint Tower Mortgage Loan, is beingserviced and administered pursuant to the pooling and servicing agreement forthe GSMS 2019-GC42 Transaction, which is incorporated by reference as Exhibit4.7 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.

Midland Loan Services, a Divisionof PNC Bank, National Association is the master servicer of the mortgage loansserviced under the Pooling and Servicing Agreement, the primary servicer of theGrand Canal Shoppes Mortgage Loan, the 3 Columbus Circle Mortgage Loan and theWoodlands Mall Mortgage Loan, the special servicer of the Woodlands MallMortgage Loan on and after September 28, 2022 and the primary servicer andspecial servicer of the Northpoint Tower Mortgage Loan. As a result, MidlandLoan Services, a Division of PNC Bank, National Association is a “servicer” asdefined in Item 1108(a)(2)(iii) of Regulation AB, in the capacities describedabove, because it is servicing mortgage loans that constituted 10% or more ofthe assets 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 Midland Loan Services, aDivision of PNC Bank, National Association in the capacities described aboveare listed in the Exhibit Index.

LNR Partners, LLC is the specialservicer of the mortgage loans serviced under the Pooling and ServicingAgreement on and after June 24, 2022 and the 3 Columbus Circle Mortgage Loan.As a result, LNR Partners, LLC 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 LNR Partners, LLC in the capacitiesdescribed above are listed in the Exhibit Index.

Wells Fargo Bank, NationalAssociation  is the certificate administrator of the mortgage loans servicedunder the Pooling and Servicing Agreement and the primary servicer of the 30Hudson Yards Mortgage Loan. As a result, Wells Fargo Bank, NationalAssociation  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 capacitiesdescribed above are listed in the Exhibit Index.

Wells Fargo Bank, NationalAssociation  is the custodian of the mortgage loans serviced under thePooling and Servicing Agreement, the Osborn Triangle Mortgage Loan, the GrandCanal Shoppes Mortgage Loan, the 30 Hudson Yards Mortgage Loan, the 3 ColumbusCircle Mortgage Loan and the Northpoint Tower Mortgage Loan.  As a result,Wells Fargo Bank, National Association  is a servicing functionparticipant in the capacities described above, because it is servicing mortgageloans that constituted 5% or more of the assets of the issuing entity as of itscut-off date. The assessments of compliance with applicable servicing criteriaand accountants’ attestation reports delivered by Wells Fargo Bank, NationalAssociation  in the capacities described above are listed in the ExhibitIndex.

Park Bridge Lender Services LLC isthe operating advisor of the mortgage loans serviced under the Pooling andServicing Agreement, the Osborn Triangle Mortgage Loan and the Northpoint TowerMortgage Loan.  As a result, Park Bridge Lender Services LLC is aservicing function participant in the capacities described above, because it isservicing mortgage loans that constituted 5% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria and accountants’ attestation reports delivered byPark Bridge Lender Services LLC in the capacities described above are listed inthe Exhibit Index.

Pentalpha Surveillance LLC is theoperating advisor of the Grand Canal Shoppes Mortgage Loan, the 3 ColumbusCircle Mortgage Loan and the Woodlands Mall Mortgage Loan.  As a result,Pentalpha Surveillance LLC is a servicing function participant in thecapacities described above, because it is servicing mortgage loans thatconstituted 5% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria andaccountants’ attestation reports delivered by Pentalpha Surveillance LLC in thecapacities described above are listed in the Exhibit Index.

Situs Holdings, LLC is the specialservicer of the Grand Canal Shoppes Mortgage Loan, the Osborn Triangle MortgageLoan and the 30 Hudson Yards Mortgage Loan. As a result, Situs Holdings, LLC isa “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 Situs Holdings, LLC in the capacities described above are listed in theExhibit Index.

Wells Fargo Bank, NationalAssociation  acts as trustee of the Sunset North Mortgage Loan, theRivertowne Commons Mortgage Loan, the 900 & 990 Stewart Avenue MortgageLoan, the City Hyde Park Mortgage Loan, the Wind Creek Leased Fee MortgageLoan, the Beverly Hills BMW Mortgage Loan, the 3 Columbus Circle Mortgage Loan,the Osborn Triangle Mortgage Loan, the Grand Canal Shoppes Mortgage Loan andthe Northpoint Tower Mortgage Loan.  Pursuant to the Pooling and ServicingAgreement, the pooling and servicing agreement for the Benchmark 2019-B10Transaction, the trust and servicing agreement for the JPMCC 2019-OSBTransaction, the pooling and servicing agreement for the MSC 2019-H7Transaction and the pooling and servicing agreement for the GSMS 2019-GC42Transaction, the trustee is required to provide an assessment of compliancewith applicable servicing criteria solely with respect to Item 1122(d)(2)(iii)of Regulation AB (regarding advances of funds or guarantees regardingcollections, cash flows or distributions, and any interest or other feescharged for such advances, are made, reviewed and approved as specified in thetransaction agreements). However, during the reporting period, the trustee didnot perform any servicing function with respect to the servicing criteriaspecified in Item 1122(d)(2)(iii) of Regulation AB.  The master serviceror the special servicer, to the extent required, performed the servicingfunction identified with respect to Item 1122(d)(2)(iii) of Regulation AB, andeach such party included Item 1122(d)(2)(iii) of Regulation AB in theassessment of compliance with applicable servicing criteria and accountant’sattestation report for the subject transaction.  As a result, this AnnualReport on Form 10-K does not include an assessment of compliance withapplicable servicing criteria of the trustee. One or more other servicers ofthe Sunset North Mortgage Loan, the Rivertowne Commons Mortgage Loan, the 900& 990 Stewart Avenue Mortgage Loan, the City Hyde Park Mortgage Loan, theWind Creek Leased Fee Mortgage Loan, the Beverly Hills BMW Mortgage Loan, the 3Columbus Circle Mortgage Loan, the Osborn Triangle Mortgage Loan, the GrandCanal Shoppes Mortgage Loan and the Northpoint Tower Mortgage Loan havedelivered one or more assessments of compliance with respect to Item1122(d)(2)(iii) of Regulation AB.

Wilmington Trust, NationalAssociation acts as trustee of the 30 Hudson Yards Mortgage Loan and theWoodlands Mall Mortgage Loan.  Pursuant to the trust and servicingagreement for the Hudson Yards 2019-30HY Transaction and the pooling andservicing agreement for the Benchmark 2019-B12 Transaction, the trustee isrequired to 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 special servicer,to the extent required, performed the servicing function identified withrespect to Item 1122(d)(2)(iii) of Regulation AB, and each such party includedItem 1122(d)(2)(iii) of Regulation AB in the assessment of compliance withapplicable 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 30 Hudson Yards Mortgage Loanand the Woodlands Mall Mortgage Loan have delivered one or more assessments ofcompliance with respect to Item 1122(d)(2)(iii) of Regulation AB.

ThisAnnual Report on Form 10-K includes assessments of compliance with applicableservicing criteria and accountants’ attestation reports from CoreLogicSolutions, LLC  This entity was engaged by the primary servicer of the 30Hudson Yards Mortgage Loan to remit tax payments received from the escrowaccounts of borrowers to local taxing authorities, to report tax amounts due,to verify tax parcel information, and to verify non-escrow tax payments. Theseservicing functions are included within the servicing criteria set forth inItems 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 3 Columbus Circle Mortgage Loan, the Osborn TriangleMortgage Loan, the 30 Hudson Yards Mortgage Loan, the Grand Canal ShoppesMortgage Loan, the Northpoint Tower Mortgage Loan and the Woodlands MallMortgage 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.

With respect to the *pari passu*loan combinations that include the Osborn Triangle Mortgage Loan and the Woodlands Mall Mortgage Loan, (i) the reports onassessment of compliance with servicing criteria and attestation reports onassessment of compliance with servicing criteria of Pacific Life InsuranceCompany as special servicer of the Woodlands Mall Mortgage Loan prior toSeptember 28, 2022 and Citibank, N.A. as custodian of the Woodlands MallMortgage Loan, listed on the Exhibit Index are omitted from this Annual Reporton Form 10-K as they are not required to be included on this Annual Report onForm 10-K per Instruction 3 to Item 1122 of Regulation AB because they areparties performing activities that address servicing criteria relating to 5% orless of the assets of the issuing entity; and (ii) the servicer compliancestatements of KeyBank National Association as primary servicer of the OsbornTriangle Mortgage Loan and Pacific Life Insurance Company as special servicerof the Woodlands Mall Mortgage Loan prior to September 28, 2022, 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.**

[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 Obligor FinancialInformation.**

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, astrustee and as custodian.

From time to time, CWCapital Asset Management LLC, a Delawarelimited liability company (“CWCAM”), is a party to lawsuits and other legalproceedings as part of its duties as a special servicer (e.g., enforcement ofloan obligations) and/or arising in the ordinary course of business. Other thanas set forth in the following paragraphs, there are currently no legal proceedingspending, and no legal proceedings known to be contemplated by governmentalauthorities, against CWCAM or of which any of its property is the subject, thatare 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 the StateCourt 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 but theSDNY Court was unable to decide the case based on the pleadings and the SDNYCourt ordered discovery.  All fact discovery was completed in December,2018 and expert discovery was completed on March 15, 2019.  The partiessubmitted cross motions for summary judgment, and on March 19, 2020, the SDNYCourt entered an opinion and order in which it granted summary judgment inCWCAM’s favor and held that CWCAM was entitled to the entire amount of penaltyinterest and that CWCAM’s determination of Yield Maintenance was correct. In the 127-page opinion, the SDNY Court found for CWCAM on every issuepresented 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 andreversing in part the SDNY Court’s decision and remanding to the SDNY Court forfurther proceedings.  The Second Circuit affirmed the SDNY’s Court holdingthat Penalty 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 amended complaint onJanuary 22, 2020 and on October 23, 2020, the court granted the motiondismissing the amended claims.  On November 30, 2020, CWCapital Cobalt VrLtd filed a notice of appeal relating to the October 23, 2020 dismissalorder.  On April 27, 2021, the First Department affirmed the dismissal asto claims against CWCAM that were part of the August 20, 2019 dismissal, butreversed the dismissal of two counts for breach of the Collateral Management Agreementagainst CWCI.  CWCI sought leave to file an appeal of the decision. Theplaintiff also sought leave to appeal the dismissal of the claims againstCWCAM.  Both requests for leave were denied by the First Department. On May 15, 2020, CWCI and CWCAM filed a motion to renew its motion to dismissas to 4 of the remaining counts (including the remaining two counts againstCWCAM for aiding and abetting breach of fiduciary duty and unjust enrichment),based on a decision entered by Judge Failla in a trust instructionproceeding  in the US District Court for the Southern District of New Yorkawarding summary judgment in favor of CWCAM.  On September 7, 2021, thecourt denied the motion to renew.  CWCI and CWCAM filed a notice ofappeal, which they perfected by the filing of their opening brief on July 1,2022.  On November 15, 2022, the First Department affirmed the court’sdenial of the motion to renew.  On October 1, 2021, CWCI and CWCAM movedto reargue the denial of the motion to renew (or alternatively, the motion todismiss) with respect to certain of Cobalt’s claims, including the remaining 2claims against CWCAM, based on the First Department’s April 27, 2021decision.  On March 24, 2022, the court denied the relief sought in themotion to reargue.  CWCI and CWCAM have appealed the court’s decision onthe motion to reargue and filed their opening brief on July 11, 2022.  Theappeal was dismissed as being non-appealable on August 30, 2022.  CWCAMbelieves that it has performed its obligations under the related pooling andservicing agreements in good faith and the remaining allegations in the NewComplaint 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 October 17, 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 ScheduleII to the Pooling and Servicing Agreement incorporated by reference as Exhibit4.1 to 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 3 Columbus Circle Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the Benchmark 2019-B10 Transaction, are attached hereto underItem 15 to this Annual Report on Form 10-K. Attached as Schedule II to thepooling and servicing agreement for the Benchmark 2019-B10 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 theBenchmark 2019-B10 Transaction responsible for each applicable servicingcriteria 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 Osborn Triangle Mortgage Loan,which is being serviced and administered pursuant to the trust and servicingagreement for the JPMCC 2019-OSB 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 JPMCC 2019-OSB Transaction incorporated byreference as Exhibit 4.3 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the JPMCC2019-OSB 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 30 Hudson Yards Mortgage Loan,which is being serviced and administered pursuant to the trust and servicingagreement for the Hudson Yards 2019-30HY Transaction, are attached hereto underItem 15 to this Annual Report on Form 10-K. Attached as Schedule I to the trustand servicing agreement for the Hudson Yards 2019-30HY Transaction incorporatedby reference as Exhibit 4.4 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the HudsonYards 2019-30HY 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 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 4.5 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 Woodlands Mall Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the Benchmark 2019-B12 Transaction, are attached hereto underItem 15 to this Annual Report on Form 10-K. Attached as Exhibit O to thepooling and servicing agreement for the Benchmark 2019-B12 Transactionincorporated by reference as Exhibit 4.6 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theBenchmark 2019-B12 Transaction responsible for each applicable servicingcriteria 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 Northpoint Tower Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the GSMS 2019-GC42 Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit AA to the pooling andservicing agreement for the GSMS 2019-GC42 Transaction incorporated byreference as Exhibit 4.7 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the GSMS2019-GC42 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The report on assessment of compliance for the twelve monthsended December 31, 2022, furnished pursuant to Item 1122 of Regulation AB byKeyBank National Association (“KeyBank”), as servicer, discloses that the followingmaterial instance of noncompliance occurred 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 new trackingand action steps to prevent this situation from recurring in the future, and(v) training will be provided to the relevant staff members to prevent arecurrence.

**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          Pooling and Servicing Agreement, dated as of October 1,2019, between Deutsche Mortgage & Asset Receiving Corporation, asDepositor, Midland Loan Services, a Division of PNC Bank, National Association,as Master Servicer, CWCapital Asset Management LLC, as Special Servicer, WellsFargo Bank, National Association, as Certificate Administrator, as Paying Agentand as Custodian, Wells Fargo Bank, National Association, as Trustee, and ParkBridge Lender Services LLC, as Operating Advisor and as Asset RepresentationsReviewer (filed as Exhibit 4.1 to the registrant’s Current Report on Form 8-Kfiled on October 17, 2019 under Commission File No. 333-226943-04 andincorporated by reference herein).

4.2          Pooling and Servicing Agreement, dated as of April 1,2019, between Deutsche Mortgage & Asset Receiving Corporation, asDepositor, KeyBank National Association, as Master Servicer, LNR Partners, LLC,as Special Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator, Paying Agent and Custodian, Wells Fargo Bank, NationalAssociation, as Trustee, and Pentalpha Surveillance LLC, as Operating Advisorand Asset Representations Reviewer (filed as Exhibit 4.5 to the registrant’sCurrent Report on Form 8-K filed on October 17, 2019 under Commission File No.333-226943-04 and incorporated by reference herein).

4.3          Trust and Servicing Agreement, dated as of June 13, 2019,by and among J.P. Morgan Chase Commercial Mortgage Securities Corp., asDepositor, KeyBank National Association, as Servicer, Situs Holdings, LLC, asSpecial Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator and Trustee, and Park Bridge Lender Services LLC, as OperatingAdvisor (filed as Exhibit 4.2 to the registrant’s Current Report on Form 8-Kfiled on October 17, 2019 under Commission File No. 333-226943-04 andincorporated by reference herein).

4.4          Trust and Servicing Agreement, dated as of July 6, 2019,between Deutsche Mortgage & Asset Receiving Corporation, as Depositor, WellsFargo Bank, National Association, as Master Servicer, Situs Holdings, LLC, asSpecial Servicer, Wilmington Trust, National Association, as Trustee, and WellsFargo Bank, National Association, as Certificate Administrator, Paying Agentand Custodian (filed as Exhibit 4.4 to the registrant’s Current Report on Form8-K filed on October 17, 2019 under Commission File No. 333-226943-04 andincorporated by reference herein).

4.5          Pooling and Servicing Agreement, dated and effective asof July 1, 2019, between Morgan Stanley Capital I Inc., as Depositor, MidlandLoan Services, a Division of PNC Bank, National Association, as MasterServicer, LNR Partners, LLC, as Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator and Trustee, and PentalphaSurveillance LLC, as Operating Advisor and Asset Representations Reviewer(filed as Exhibit 4.3 to the registrant’s Current Report on Form 8-K filed onOctober 17, 2019 under Commission File No. 333-226943-04 and incorporated byreference herein).

4.6          Pooling and Servicing Agreement, dated as of August 1,2019, among Citigroup Commercial Mortgage Securities Inc., as Depositor,Midland Loan Services, a Division of PNC Bank, National Association, as MasterServicer, Midland Loan Services, a Division of PNC Bank, National Association,as a Special Servicer, Pacific Life Insurance Company, solely with respect tothe Woodlands Mall Loan Combination, as a Special Servicer, Trimont Real EstateAdvisors, LLC, solely with respect to The Centre Loan Combination, as a SpecialServicer, Pentalpha Surveillance LLC, as Operating Advisor and AssetRepresentations Reviewer, Citibank, N.A., as Certificate Administrator, andWilmington Trust, National Association, as Trustee (filed as Exhibit 4.6 to theregistrant’s Current Report on Form 8-K filed on October 17, 2019 underCommission File No. 333-226943-04 and incorporated by reference herein).

4.7          Pooling and Servicing Agreement, dated as of September 1,2019, by and among GS Mortgage Securities Corporation II, as Depositor, MidlandLoan Services, a Division of PNC Bank, National Association, as Master Servicerand as Special Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator and as Trustee, and Park Bridge Lender Services LLC, as OperatingAdvisor and Asset Representations Reviewer (filed as Exhibit 4.7 to theregistrant’s Current Report on Form 8-K filed on October 17, 2019 underCommission File No. 333-226943-04 and incorporated by reference herein).

4.8          Co-Lender Agreement, dated as of September 10, 2019, byand among JPMorgan Chase Bank, National Association, as Initial Note A-1Holder, JPMorgan Chase Bank, National Association, as Initial Note A-2 Holder,and JPMorgan Chase Bank, National Association, as Initial Note A-3 Holder(filed as Exhibit 4.8 to the registrant’s Current Report on Form 8-K filed onOctober 17, 2019 under Commission File No. 333-226943-04 and incorporated byreference herein).

4.9          Co-Lender Agreement, dated as of June 13, 2019, by andamong JPMorgan Chase Bank, National Association, as Initial Note A-1 Holder,Initial Note A-2 Holder, Initial Note A-3 Holder, Initial Note A-4 Holder,Initial Note A-5 Holder and Initial Note A-6 Holder, and JPMorgan Chase Bank,National Association, as Initial Note B-1 Holder (filed as Exhibit 4.9 to theregistrant’s Current Report on Form 8-K filed on October 17, 2019 underCommission File No. 333-226943-04 and incorporated by reference herein).

4.10         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 4.10to the registrant’s Current Report on Form 8-K filed on October 17, 2019 under CommissionFile No. 333-226943-04 and incorporated by reference herein).

4.11         Co-Lender Agreement, dated as of October 17, 2019, by andbetween Citi Real Estate Funding Inc., as Initial Note A-1 Holder, and CitiReal Estate Funding Inc., as Initial Note A-2 Holder (filed as Exhibit 4.11 tothe registrant’s Current Report on Form 8-K filed on October 17, 2019 underCommission File No. 333-226943-04 and incorporated by reference herein).

4.12         Co-Lender Agreement, dated as of September 12, 2019, byand between JPMorgan Chase Bank, National Association, as Initial Note A-1Holder, and JPMorgan Chase Bank, National Association, as Initial Note A-2Holder (filed as Exhibit 4.12 to the registrant’s Current Report on Form 8-Kfiled on October 17, 2019 under Commission File No. 333-226943-04 andincorporated by reference herein).

4.13         Co-Lender Agreement, dated as of September 17, 2019, byand among JPMorgan Chase Bank, National Association, as Initial Note A-1Holder, JPMorgan Chase Bank, National Association, as Initial Note A-2 Holder,and JPMorgan Chase Bank, National Association, as Initial Note A-3 Holder(filed as Exhibit 4.13 to the registrant’s Current Report on Form 8-K filed onOctober 17, 2019 under Commission File No. 333-226943-04 and incorporated byreference herein).

4.14         Co-Lender Agreement, dated as of August 20, 2019, betweenCantor Commercial Real Estate Lending, L.P., as Note A-1 Holder, DBRInvestments Co. Limited, as Note A-2 Holder, DBR Investments Co. Limited, asNote A-3 Holder, DBR Investments Co. Limited, as Note A-4 Holder, DBR InvestmentsCo. Limited, as Note A-5 Holder, and DBR Investments Co. Limited, as Note A-6Holder (filed as Exhibit 4.14 to the registrant’s Current Report on Form 8-Kfiled on October 17, 2019 under Commission File No. 333-226943-04 andincorporated by reference herein).

4.15         Co-Lender Agreement, dated as of July 6, 2019, by andbetween Deutsche Bank AG, New York Branch, as an Initial Note A Holder, WellsFargo Bank, National Association, as an Initial Note A Holder, Goldman SachsBank USA, as an Initial Note A Holder, Deutsche Bank AG, New York Branch, asInitial Note B-1 Holder, Goldman Sachs Bank USA, as Initial Note B-2 Holder,and Wells Fargo Bank, National Association, as Initial Note B-3 Holder (filedas Exhibit 4.15 to the registrant’s Current Report on Form 8-K filed on October17, 2019 under Commission File No. 333-226943-04 and incorporated by referenceherein).

4.16         Co-Lender Agreement, dated as of September 17, 2019,between Deutsche Bank AG, New York Branch, as Note A-1 Holder, Deutsche BankAG, New York Branch, as Note A-2 Holder and Deutsche Bank AG, New York Branch,as Note A-3 Holder (filed as Exhibit 4.16 to the registrant’s Current Report onForm 8-K filed on October 17, 2019 under Commission File No. 333-226943-04 andincorporated by reference herein).

4.17         Agreement Between Noteholders, dated as of March 13,2019, by and Between JPMorgan Chase Bank, National Association, as Initial NoteA-1-1 Holder, Initial Note A-1-2 Holder, Initial Note A-1-3 Holder, InitialNote A-1-4 Holder, Initial Note A-1-5 Holder, Initial Note A-1-6 Holder,Initial Note A-1-7 Holder and Initial Note A-1-8 Holder, Deutsche Bank AG,acting through its New York Branch, as Note A-2-1 Holder, Note A-2-2 Holder,Note A-2-3 Holder, Note A-2-4 Holder and Note A-2-5 Holder, JPMorgan ChaseBank, National Association, as Initial Note B-1 Holder and Deutsche Bank AG,acting through its New York Branch, as Note B-2 Holder (filed as Exhibit 4.17 tothe registrant’s Current Report on Form 8-K filed on October 17, 2019 underCommission File No. 333-226943-04 and incorporated by reference herein).

4.18         Agreement Between Noteholders, dated as of August 8,2019, by and between Deutsche Bank AG, New York Branch, as Initial Note A-1-1Holder, Deutsche Bank AG, New York Branch, as Initial Note A-1-2 Holder,Deutsche Bank AG, New York Branch, as Initial Note A-2 Holder, Deutsche BankAG, New York Branch, as Initial Note A-3 Holder, Deutsche Bank AG, New YorkBranch, as Initial Note A-4 Holder, Deutsche Bank AG, New York Branch, asInitial Note A-5 Holder, Deutsche Bank AG, New York Branch, as Initial Note A-6Holder, Deutsche Bank AG, New York Branch, as Initial Note A-7 Holder, andDeutsche Bank AG, New York Branch, as Initial Note B Holder (filed as Exhibit4.18 to the registrant’s Current Report on Form 8-K filed on October 17, 2019under Commission File No. 333-226943-04 and incorporated by reference herein).

4.19         Co-Lender Agreement, dated as of August 9, 2019, by andbetween Citi Real Estate Funding Inc., as Initial Note A-1 Holder, Citi RealEstate Funding Inc., as Initial Note A-2-1 Holder, Citi Real Estate FundingInc., as Initial Note A-2-2 Holder, and Citi Real Estate Funding Inc., asInitial Note A-3 Holder (filed as Exhibit 4.19 to the registrant’s CurrentReport on Form 8-K filed on October 17, 2019 under Commission File No.333-226943-04 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        Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer

33.2        CWCapital Asset Management LLC, as Special Servicerprior to June 24, 2022

33.3        LNR Partners, LLC, as Special Servicer on and afterJune 24, 2022

33.4        Wells Fargo Bank, National Association, as Trusteeand Certificate Administrator

33.5        Wells Fargo Bank, National Association, asCustodian

33.6        Park Bridge Lender Services LLC, as OperatingAdvisor

33.7        Computershare Trust Company, National Association,as Servicing Function Participant for the Trustee and Certificate Administrator

33.8        Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian

33.9        Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Sunset North Mortgage Loan(see Exhibit 33.1)

33.10      CWCapital Asset Management LLC, as Special Servicerof the Sunset North Mortgage Loan prior to June 24, 2022 (see Exhibit 33.2)

33.11      LNR Partners, LLC, as Special Servicer of theSunset North Mortgage Loan on and after June 24, 2022 (see Exhibit 33.3)

33.12      Wells Fargo Bank, National Association, as Trustee of the Sunset North MortgageLoan (Omitted. See Explanatory Notes.)

33.13      Wells Fargo Bank, National Association, asCustodian of the Sunset North Mortgage Loan (see Exhibit 33.5)

33.14      Park Bridge Lender Services LLC, as OperatingAdvisor of the Sunset North Mortgage Loan (see Exhibit 33.6)

33.15      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.8)

33.16      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the City Hyde Park Mortgage Loan(see Exhibit 33.1)

33.17      CWCapital Asset Management LLC, as Special Servicerof the City Hyde Park Mortgage Loan prior to June 24, 2022 (see Exhibit 33.2)

33.18      LNR Partners, LLC, as Special Servicer of the CityHyde Park Mortgage Loan on and after June 24, 2022 (see Exhibit 33.3)

33.19      Wells Fargo Bank, National Association, as Trustee of the City Hyde ParkMortgage Loan (Omitted. See Explanatory Notes.)

33.20      Wells Fargo Bank, National Association, asCustodian of the City Hyde Park Mortgage Loan (see Exhibit 33.5)

33.21      Park Bridge Lender Services LLC, as OperatingAdvisor of the City Hyde Park Mortgage Loan (see Exhibit 33.6)

33.22       Computershare Trust Company, National Association, asServicing Function Participant for the Custodian (see Exhibit 33.8)

33.23      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Rivertowne Commons MortgageLoan (see Exhibit 33.1)

33.24      CWCapital Asset Management LLC, as Special Servicerof the Rivertowne Commons Mortgage Loan prior to June 24, 2022 (see Exhibit33.2)

33.25      LNR Partners, LLC, as Special Servicer of theRivertowne Commons Mortgage Loan on and after June 24, 2022 (see Exhibit 33.3)

33.26      Wells Fargo Bank, National Association, as Trustee of the Rivertowne CommonsMortgage Loan (Omitted. See Explanatory Notes.)

33.27      Wells Fargo Bank, National Association, asCustodian of the Rivertowne Commons Mortgage Loan (see Exhibit 33.5)

33.28      Park Bridge Lender Services LLC, as OperatingAdvisor of the Rivertowne Commons Mortgage Loan (see Exhibit 33.6)

33.29      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.8)

33.30      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 900 & 990 Stewart AvenueMortgage Loan (see Exhibit 33.1)

33.31      CWCapital Asset Management LLC, as Special Servicerof the 900 & 990 Stewart Avenue Mortgage Loan prior to June 24, 2022 (seeExhibit 33.2)

33.32      LNR Partners, LLC, as Special Servicer of the 900& 990 Stewart Avenue Mortgage Loan on and after June 24, 2022 (see Exhibit33.3)

33.33      Wells Fargo Bank, National Association, as Trustee of the 900 & 990 StewartAvenue Mortgage Loan (Omitted. See Explanatory Notes.)

33.34      Wells Fargo Bank, National Association, asCustodian of the 900 & 990 Stewart Avenue Mortgage Loan (see Exhibit 33.5)

33.35      Park Bridge Lender Services LLC, as OperatingAdvisor of the 900 & 990 Stewart Avenue Mortgage Loan (see Exhibit 33.6)

33.36      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.8)

33.37      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Wind Creek Leased Fee MortgageLoan (see Exhibit 33.1)

33.38      CWCapital Asset Management LLC, as Special Servicerof the Wind Creek Leased Fee Mortgage Loan prior to June 24, 2022 (see Exhibit33.2)

33.39      LNR Partners, LLC, as Special Servicer of the WindCreek Leased Fee Mortgage Loan on and after June 24, 2022 (see Exhibit 33.3)

33.40      Wells Fargo Bank, National Association, as Trustee of the Wind Creek Leased FeeMortgage Loan (Omitted. See Explanatory Notes.)

33.41      Wells Fargo Bank, National Association, asCustodian of the Wind Creek Leased Fee Mortgage Loan (see Exhibit 33.5)

33.42      Park Bridge Lender Services LLC, as OperatingAdvisor of the Wind Creek Leased Fee Mortgage Loan (see Exhibit 33.6)

33.43      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.8)

33.44      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Beverly Hills BMW MortgageLoan (see Exhibit 33.1)

33.45      CWCapital Asset Management LLC, as Special Servicerof the Beverly Hills BMW Mortgage Loan prior to June 24, 2022 (see Exhibit33.2)

33.46      LNR Partners, LLC, as Special Servicer of theBeverly Hills BMW Mortgage Loan on and after June 24, 2022 (see Exhibit 33.3)

33.47      Wells Fargo Bank, National Association, as Trustee of the Beverly Hills BMWMortgage Loan (Omitted. See Explanatory Notes.)

33.48      Wells Fargo Bank, National Association, asCustodian of the Beverly Hills BMW Mortgage Loan (see Exhibit 33.5)

33.49      Park Bridge Lender Services LLC, as OperatingAdvisor of the Beverly Hills BMW Mortgage Loan (see Exhibit 33.6)

33.50      Computershare Trust Company, National Association, asServicing Function Participant for the Custodian (see Exhibit 33.8)

33.51      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 3 Columbus Circle MortgageLoan (see Exhibit 33.1)

33.52      LNR Partners, LLC, as Special Servicer of the 3Columbus Circle Mortgage Loan (see Exhibit 33.3)

33.53      Wells Fargo Bank, National Association, as Trustee of the 3 Columbus CircleMortgage Loan (Omitted. See Explanatory Notes.)

33.54      Wells Fargo Bank, National Association, asCustodian of the 3 Columbus Circle Mortgage Loan (see Exhibit 33.5)

33.55      Pentalpha Surveillance LLC, as Operating Advisorof the 3 Columbus Circle Mortgage Loan

33.56      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.8)

33.57      KeyBank National Association, as Primary Servicerof the Osborn Triangle Mortgage Loan

33.58      Situs Holdings, LLC, as Special Servicer of theOsborn Triangle Mortgage Loan

33.59      Wells Fargo Bank, National Association, as Trustee of the Osborn TriangleMortgage Loan (Omitted. See Explanatory Notes.)

33.60      Wells Fargo Bank, National Association, asCustodian of the Osborn Triangle Mortgage Loan (see Exhibit 33.5)

33.61      Park Bridge Lender Services LLC, as OperatingAdvisor of the Osborn Triangle Mortgage Loan (see Exhibit 33.6)

33.62      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.8)

33.63      Wells Fargo Bank, National Association, as PrimaryServicer of the 30 Hudson Yards Mortgage Loan

33.64      Situs Holdings, LLC, as Special Servicer of the 30Hudson Yards Mortgage Loan (see Exhibit 33.58)

33.65      Wilmington Trust, National Association, as Trustee of the 30 Hudson YardsMortgage Loan (Omitted. See Explanatory Notes.)

33.66      Wells Fargo Bank, National Association, asCustodian of the 30 Hudson Yards Mortgage Loan (see Exhibit 33.5)

33.67      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 30 Hudson Yards Mortgage Loan

33.68      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.8)

33.69      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Grand Canal Shoppes MortgageLoan (see Exhibit 33.1)

33.70      Situs Holdings, LLC, as Special Servicer of the GrandCanal Shoppes Mortgage Loan (see Exhibit 33.58)

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

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

33.73      Pentalpha Surveillance LLC, as Operating Advisorof the Grand Canal Shoppes Mortgage Loan (see Exhibit 33.55)

33.74      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.8)

33.75      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Woodlands Mall Mortgage Loan(see Exhibit 33.1)

33.76      Pacific Life Insurance Company, as Special Servicer of the Woodlands MallMortgage Loan prior to September 28, 2022 (Omitted. See Explanatory Notes.)

33.77      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Woodlands Mall Mortgage Loanon and after September 28, 2022 (see Exhibit 33.1)

33.78      Wilmington Trust, National Association, as Trustee of the Woodlands MallMortgage Loan (Omitted. See Explanatory Notes.)

33.79      Citibank, N.A., as Custodian of the Woodlands Mall Mortgage Loan (Omitted. SeeExplanatory Notes.)

33.80      Pentalpha Surveillance LLC, as Operating Advisorof the Woodlands Mall Mortgage Loan (see Exhibit 33.55)

33.81      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Northpoint Tower Mortgage Loan(see Exhibit 33.1)

33.82      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Northpoint Tower Mortgage Loan(see Exhibit 33.1)

33.83      Wells Fargo Bank, National Association, as Trustee of the Northpoint TowerMortgage Loan (Omitted. See Explanatory Notes.)

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

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

33.86      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.8)

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

34.1        Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer

34.2        CWCapital Asset Management LLC, as Special Servicerprior to June 24, 2022

34.3        LNR Partners, LLC, as Special Servicer on and afterJune 24, 2022

34.4        Wells Fargo Bank, National Association, as Trusteeand Certificate Administrator

34.5        Wells Fargo Bank, National Association, asCustodian

34.6        Park Bridge Lender Services LLC, as OperatingAdvisor

34.7        Computershare Trust Company, National Association,as Servicing Function Participant for the Trustee and Certificate Administrator

34.8        Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian

34.9        Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Sunset North Mortgage Loan(see Exhibit 34.1)

34.10      CWCapital Asset Management LLC, as Special Servicerof the Sunset North Mortgage Loan prior to June 24, 2022 (see Exhibit 34.2)

34.11      LNR Partners, LLC, as Special Servicer of theSunset North Mortgage Loan on and after June 24, 2022 (see Exhibit 34.3)

34.12      Wells Fargo Bank, National Association, as Trustee of the Sunset North MortgageLoan (Omitted. See Explanatory Notes.)

34.13      Wells Fargo Bank, National Association, asCustodian of the Sunset North Mortgage Loan (see Exhibit 34.5)

34.14      Park Bridge Lender Services LLC, as OperatingAdvisor of the Sunset North Mortgage Loan (see Exhibit 34.6)

34.15      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.8)

34.16      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the City Hyde Park Mortgage Loan(see Exhibit 34.1)

34.17      CWCapital Asset Management LLC, as Special Servicerof the City Hyde Park Mortgage Loan prior to June 24, 2022 (see Exhibit 34.2)

34.18      LNR Partners, LLC, as Special Servicer of the CityHyde Park Mortgage Loan on and after June 24, 2022 (see Exhibit 34.3)

34.19      Wells Fargo Bank, National Association, as Trustee of the City Hyde ParkMortgage Loan (Omitted. See Explanatory Notes.)

34.20      Wells Fargo Bank, National Association, asCustodian of the City Hyde Park Mortgage Loan (see Exhibit 34.5)

34.21      Park Bridge Lender Services LLC, as OperatingAdvisor of the City Hyde Park Mortgage Loan (see Exhibit 34.6)

34.22      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.8)

34.23      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Rivertowne Commons MortgageLoan (see Exhibit 34.1)

34.24      CWCapital Asset Management LLC, as Special Servicerof the Rivertowne Commons Mortgage Loan prior to June 24, 2022 (see Exhibit34.2)

34.25      LNR Partners, LLC, as Special Servicer of theRivertowne Commons Mortgage Loan on and after June 24, 2022 (see Exhibit 34.3)

34.26      Wells Fargo Bank, National Association, as Trustee of the Rivertowne CommonsMortgage Loan (Omitted. See Explanatory Notes.)

34.27      Wells Fargo Bank, National Association, asCustodian of the Rivertowne Commons Mortgage Loan (see Exhibit 34.5)

34.28      Park Bridge Lender Services LLC, as OperatingAdvisor of the Rivertowne Commons Mortgage Loan (see Exhibit 34.6)

34.29      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.8)

34.30      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 900 & 990 Stewart AvenueMortgage Loan (see Exhibit 34.1)

34.31      CWCapital Asset Management LLC, as Special Servicerof the 900 & 990 Stewart Avenue Mortgage Loan prior to June 24, 2022 (seeExhibit 34.2)

34.32      LNR Partners, LLC, as Special Servicer of the 900& 990 Stewart Avenue Mortgage Loan on and after June 24, 2022 (see Exhibit34.3)

34.33      Wells Fargo Bank, National Association, as Trustee of the 900 & 990 StewartAvenue Mortgage Loan (Omitted. See Explanatory Notes.)

34.34      Wells Fargo Bank, National Association, asCustodian of the 900 & 990 Stewart Avenue Mortgage Loan (see Exhibit 34.5)

34.35      Park Bridge Lender Services LLC, as OperatingAdvisor of the 900 & 990 Stewart Avenue Mortgage Loan (see Exhibit 34.6)

34.36      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.8)

34.37      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Wind Creek Leased Fee MortgageLoan (see Exhibit 34.1)

34.38      CWCapital Asset Management LLC, as Special Servicerof the Wind Creek Leased Fee Mortgage Loan prior to June 24, 2022 (see Exhibit34.2)

34.39      LNR Partners, LLC, as Special Servicer of the WindCreek Leased Fee Mortgage Loan on and after June 24, 2022 (see Exhibit 34.3)

34.40      Wells Fargo Bank, National Association, as Trustee of the Wind Creek Leased FeeMortgage Loan (Omitted. See Explanatory Notes.)

34.41      Wells Fargo Bank, National Association, asCustodian of the Wind Creek Leased Fee Mortgage Loan (see Exhibit 34.5)

34.42      Park Bridge Lender Services LLC, as OperatingAdvisor of the Wind Creek Leased Fee Mortgage Loan (see Exhibit 34.6)

34.43      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.8)

34.44      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Beverly Hills BMW MortgageLoan (see Exhibit 34.1)

34.45      CWCapital Asset Management LLC, as Special Servicerof the Beverly Hills BMW Mortgage Loan prior to June 24, 2022 (see Exhibit34.2)

34.46      LNR Partners, LLC, as Special Servicer of theBeverly Hills BMW Mortgage Loan on and after June 24, 2022 (see Exhibit 34.3)

34.47      Wells Fargo Bank, National Association, as Trustee of the Beverly Hills BMWMortgage Loan (Omitted. See Explanatory Notes.)

34.48      Wells Fargo Bank, National Association, asCustodian of the Beverly Hills BMW Mortgage Loan (see Exhibit 34.5)

34.49      Park Bridge Lender Services LLC, as OperatingAdvisor of the Beverly Hills BMW Mortgage Loan (see Exhibit 34.6)

34.50      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.8)

34.51      Midland Loan Services, a Division of PNC Bank, NationalAssociation, as Primary Servicer of the 3 Columbus Circle Mortgage Loan (seeExhibit 34.1)

34.52      LNR Partners, LLC, as Special Servicer of the 3Columbus Circle Mortgage Loan (see Exhibit 34.3)

34.53      Wells Fargo Bank, National Association, as Trustee of the 3 Columbus CircleMortgage Loan (Omitted. See Explanatory Notes.)

34.54      Wells Fargo Bank, National Association, asCustodian of the 3 Columbus Circle Mortgage Loan (see Exhibit 34.5)

34.55      Pentalpha Surveillance LLC, as Operating Advisorof the 3 Columbus Circle Mortgage Loan

34.56      Computershare Trust Company, National Association, asServicing Function Participant for the Custodian (see Exhibit 34.8)

34.57      KeyBank National Association, as Primary Servicerof the Osborn Triangle Mortgage Loan

34.58      Situs Holdings, LLC, as Special Servicer of theOsborn Triangle Mortgage Loan

34.59      Wells Fargo Bank, National Association, as Trustee of the Osborn TriangleMortgage Loan (Omitted. See Explanatory Notes.)

34.60      Wells Fargo Bank, National Association, asCustodian of the Osborn Triangle Mortgage Loan (see Exhibit 34.5)

34.61      Park Bridge Lender Services LLC, as OperatingAdvisor of the Osborn Triangle Mortgage Loan (see Exhibit 34.6)

34.62      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.8)

34.63      Wells Fargo Bank, National Association, as PrimaryServicer of the 30 Hudson Yards Mortgage Loan

34.64      Situs Holdings, LLC, as Special Servicer of the 30Hudson Yards Mortgage Loan (see Exhibit 34.58)

34.65      Wilmington Trust, National Association, as Trustee of the 30 Hudson YardsMortgage Loan (Omitted. See Explanatory Notes.)

34.66      Wells Fargo Bank, National Association, asCustodian of the 30 Hudson Yards Mortgage Loan (see Exhibit 34.5)

34.67      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 30 Hudson Yards Mortgage Loan

34.68      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.8)

34.69      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Grand Canal Shoppes MortgageLoan (see Exhibit 34.1)

34.70      Situs Holdings, LLC, as Special Servicer of theGrand Canal Shoppes Mortgage Loan (see Exhibit 34.58)

34.71      Wells Fargo Bank, National Association, as Trustee of the Grand Canal Shoppes MortgageLoan (Omitted. See Explanatory Notes.)

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

34.73      Pentalpha Surveillance LLC, as Operating Advisorof the Grand Canal Shoppes Mortgage Loan (see Exhibit 34.55)

34.74      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.8)

34.75      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Woodlands Mall Mortgage Loan(see Exhibit 34.1)

34.76      Pacific Life Insurance Company, as Special Servicer of the Woodlands MallMortgage Loan prior to September 28, 2022 (Omitted. See Explanatory Notes.)

34.77      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Woodlands Mall Mortgage Loanon and after September 28, 2022 (see Exhibit 34.1)

34.78      Wilmington Trust, National Association, as Trustee of the Woodlands MallMortgage Loan (Omitted. See Explanatory Notes.)

34.79      Citibank, N.A., as Custodian of the Woodlands Mall Mortgage Loan (Omitted. SeeExplanatory Notes.)

34.80      Pentalpha Surveillance LLC, as Operating Advisorof the Woodlands Mall Mortgage Loan (see Exhibit 34.55)

34.81      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Northpoint Tower Mortgage Loan(see Exhibit 34.1)

34.82      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Northpoint Tower Mortgage Loan(see Exhibit 34.1)

34.83      Wells Fargo Bank, National Association, as Trustee of the Northpoint TowerMortgage Loan (Omitted. See Explanatory Notes.)

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

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

34.86      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.8)

35           Servicer compliance statements.

35.1        Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer

35.2        CWCapital Asset Management LLC, as Special Servicerprior to June 24, 2022

35.3        LNR Partners, LLC, as Special Servicer on and afterJune 24, 2022

35.4        Wells Fargo Bank, National Association, asCertificate Administrator

35.5        Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator

35.6        Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Sunset North Mortgage Loan(see Exhibit 35.1)

35.7        CWCapital Asset Management LLC, as Special Servicerof the Sunset North Mortgage Loan prior to June 24, 2022 (see Exhibit 35.2)

35.8        LNR Partners, LLC, as Special Servicer of theSunset North Mortgage Loan on and after June 24, 2022 (see Exhibit 35.3)

35.9        Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the City Hyde Park Mortgage Loan(see Exhibit 35.1)

35.10      CWCapital Asset Management LLC, as Special Servicerof the City Hyde Park Mortgage Loan prior to June 24, 2022 (see Exhibit 35.2)

35.11      LNR Partners, LLC, as Special Servicer of the CityHyde Park Mortgage Loan on and after June 24, 2022 (see Exhibit 35.3)

35.12      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Rivertowne Commons MortgageLoan (see Exhibit 35.1)

35.13      CWCapital Asset Management LLC, as Special Servicerof the Rivertowne Commons Mortgage Loan prior to June 24, 2022 (see Exhibit35.2)

35.14      LNR Partners, LLC, as Special Servicer of theRivertowne Commons Mortgage Loan on and after June 24, 2022 (see Exhibit 35.3)

35.15      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 900 & 990 Stewart AvenueMortgage Loan (see Exhibit 35.1)

35.16      CWCapital Asset Management LLC, as Special Servicerof the 900 & 990 Stewart Avenue Mortgage Loan prior to June 24, 2022 (seeExhibit 35.2)

35.17      LNR Partners, LLC, as Special Servicer of the 900& 990 Stewart Avenue Mortgage Loan on and after June 24, 2022 (see Exhibit35.3)

35.18      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Wind Creek Leased Fee MortgageLoan (see Exhibit 35.1)

35.19      CWCapital Asset Management LLC, as Special Servicerof the Wind Creek Leased Fee Mortgage Loan prior to June 24, 2022 (see Exhibit35.2)

35.20      LNR Partners, LLC, as Special Servicer of the WindCreek Leased Fee Mortgage Loan on and after June 24, 2022 (see Exhibit 35.3)

35.21      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Beverly Hills BMW MortgageLoan (see Exhibit 35.1)

35.22      CWCapital Asset Management LLC, as Special Servicerof the Beverly Hills BMW Mortgage Loan prior to June 24, 2022 (see Exhibit35.2)

35.23      LNR Partners, LLC, as Special Servicer of theBeverly Hills BMW Mortgage Loan on and after June 24, 2022 (see Exhibit 35.3)

35.24      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 3 Columbus Circle MortgageLoan (see Exhibit 35.1)

35.25      LNR Partners, LLC, as Special Servicer of the 3Columbus Circle Mortgage Loan (see Exhibit 35.3)

35.26      KeyBank National Association, as Primary Servicer of the Osborn TriangleMortgage Loan (Omitted. See Explanatory Notes.) 

35.27      Situs Holdings, LLC, as Special Servicer of theOsborn Triangle Mortgage Loan

35.28      Wells Fargo Bank, National Association, as PrimaryServicer of the 30 Hudson Yards Mortgage Loan

35.29      Situs Holdings, LLC, as Special Servicer of the 30Hudson Yards Mortgage Loan (see Exhibit 35.27)

35.30      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Grand Canal Shoppes MortgageLoan (see Exhibit 35.1)

35.31      Situs Holdings, LLC, as Special Servicer of theGrand Canal Shoppes Mortgage Loan (see Exhibit 35.27)

35.32      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Woodlands Mall Mortgage Loan(see Exhibit 35.1)

35.33      Pacific Life Insurance Company, as Special Servicer of the Woodlands MallMortgage Loan prior to September 28, 2022 (Omitted. See Explanatory Notes.)

35.34      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Woodlands Mall Mortgage Loanon and after September 28, 2022 (see Exhibit 35.1)

35.35      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Northpoint Tower Mortgage Loan(see Exhibit 35.1)

35.36      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Northpoint Tower Mortgage Loan(see Exhibit 35.1)

99.1         Mortgage Loan Purchase Agreement, dated as of September20, 2019, between Deutsche Mortgage & Asset Receiving Corporation and GermanAmerican Capital Corporation (filed as Exhibit 99.1 to the registrant’s CurrentReport on Form 8-K filed on October 17, 2019 under Commission File No.333-226943-04 and incorporated by reference herein)

99.2         Mortgage Loan Purchase Agreement, dated as of September20, 2019, between Deutsche Mortgage & Asset Receiving Corporation andJPMorgan Chase Bank, National Association (filed as Exhibit 99.2 to theregistrant’s Current Report on Form 8-K filed on October 17, 2019 underCommission File No. 333-226943-04 and incorporated by reference herein)

99.3         Mortgage Loan Purchase Agreement, dated as of September20, 2019, between Deutsche Mortgage & Asset Receiving Corporation and CitiReal Estate Funding Inc. (filed as Exhibit 99.3 to the registrant’s CurrentReport on Form 8-K filed on October 17, 2019 under Commission File No.333-226943-04 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.

Deutsche Mortgage & AssetReceiving Corporation(Depositor)

/s/ HelaineM. Kaplan

Helaine M.Kaplan, President

(senior officer in charge ofsecuritization of the depositor)

Date: March 14, 2023

/s/ MattSmith

Matt Smith, Director

Date: March 14, 2023