**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, 2023or**

**o**** ****TRANSITIONREPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934**

**For the transition period from _____ to _____Commission file number of the issuing entity: 333-228375-02**

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

**BANK 2019-BNK21**

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

** **

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

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

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

** **

**Central Index Key Number of the sponsor: 0001102113**

**Bank of America, NationalAssociation**

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

** **

**Central Index Key Number of the sponsor: 0001541557**

**Morgan Stanley Mortgage CapitalHoldings LLC**

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

** **

**Central Index Key Number of the sponsor: 0000740906**

**Wells Fargo Bank, NationalAssociation**

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

** **

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

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

**38-4128707**

**38-7235580**

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

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

**c/o 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:**

**(646) 855-3953**

Securities registered pursuant to Section 12(b) of the Act:

| Title of each class | Trading Symbol(s) | Name of each exchange on which registered |
|---------------------|-------------------|-------------------------------------------|
| None                |              |                                      |

 

 

Securities registered pursuant to Section 12(g) of theAct:  None.

Indicate by check mark if the registrant is a well-knownseasoned issuer, as defined in Rule 405 of the Securities Act.  o Yes ⌧No

Indicate by check mark if the registrant is not required tofile reports pursuant to Section 13 or Section 15(d) of the Act.  o Yes ⌧No

Indicate by check mark whether the registrant (1) has filedall reports required to be filed by Section 13 or 15(d) of the SecuritiesExchange Act of 1934 during the preceding 12 months (or for such shorter periodthat the registrant was required to file such reports), and (2) has beensubject to such filing requirements for the past 90 days.  ⌧ Yes oNo

Indicate by check mark whether the registrant has submittedelectronically 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          ⌧                                                                                                     Smaller reportingcompany                    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 Park Tower at Transbay Mortgage Loan, the230 Park Avenue South Mortgage Loan, the Storage Post Portfolio Mortgage Loan,the 105 East 17th Street Mortgage Loan, the National Anchored Retail PortfolioMortgage Loan, the Tysons Tower Mortgage Loan and the Landing at Fancher CreekMortgage Loan, which constituted approximately 9.7%, 9.3%, 7.2%, 5.1%, 4.2%,4.2% and 1.7%, respectively, of the asset pool of the issuing entity as of itscut-off date, are each an asset of the issuing entity and are each part of aloan combination that includes (a) with respect to the Park Tower at TransbayMortgage Loan, eight other *pari passu* loans, which are not assets of theissuing entity, (b) with respect to the 230 Park Avenue South Mortgage Loan,five other *pari passu* loans, which are not assets of the issuing entity,(c) with respect to the Storage Post Portfolio Mortgage Loan, two other *paripassu* loans, which are not assets of the issuing entity, (d) with respectto the 105 East 17th Street Mortgage Loan, one other *pari passu* loan,which is not an asset of the issuing entity, (e) with respect to the NationalAnchored Retail Portfolio Mortgage Loan, two other *pari passu* loans,which are not assets of the issuing entity, (f) with respect to the TysonsTower Mortgage Loan, six other *pari passu* loans, which are not assets ofthe issuing entity and (g) with respect to the Landing at Fancher CreekMortgage Loan, one other *pari passu* loan, which is not an asset of theissuing entity. These loan combinations, including the Park Tower at TransbayMortgage Loan, the 230 Park Avenue South Mortgage Loan, the Storage PostPortfolio Mortgage Loan, the 105 East 17th Street Mortgage Loan, the NationalAnchored Retail Portfolio Mortgage Loan, the Tysons Tower Mortgage Loan and theLanding at Fancher Creek Mortgage Loan, are being serviced and administeredpursuant to the Pooling and Servicing Agreement, which is incorporated byreference as Exhibit 4.1 to this Annual Report on Form 10-K. 

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Grand Canal Shoppes Mortgage Loan, whichconstituted approximately 3.4% of the asset pool of the issuing entity as ofits cut-off date.  The Grand Canal Shoppes Mortgage Loan is an asset ofthe issuing entity and is part of a loan combination that includes the GrandCanal Shoppes Mortgage Loan, twenty-three other *pari passu* loans and onesubordinate companion loan, which are not assets of the issuing entity. A *paripassu* portion of the loan combination was securitized in the Morgan StanleyCapital I Trust 2019-H7 transaction, Commission File Number 333-227446-05 (the“MSC 2019-H7 Transaction”). This loan combination, including the GrandCanal Shoppes Mortgage Loan, is being serviced and administered pursuant to thepooling and servicing agreement for the MSC 2019-H7 Transaction, which isincorporated by reference as Exhibit 4.2 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to The Tower at Burbank Mortgage Loan, whichconstituted approximately 5.9% of the asset pool of the issuing entity as ofits cut-off date.  The Tower at Burbank Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes two other *paripassu* loans, which are not assets of the issuing entity. A *pari passu*portion of the loan combination was securitized in the BANK 2019-BNK20transaction, Commission File Number 333-227446-06 (the “BANK 2019-BNK20Transaction”). This loan combination, including The Tower at BurbankMortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the BANK 2019-BNK20 Transaction, which is incorporatedby reference as Exhibit 4.3 to this Annual Report on Form 10-K. The NKXMultifamily Portfolio Mortgage Loan, previously an asset of the issuing entity beingserviced under the pooling and servicing agreement for the BANK 2019-BNK20Transaction, was not an asset of the issuing entity during the reporting periodand is omitted from this Annual Report on Form 10-K and will be omitted fromsubsequent Annual Reports on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Global Data Center Mortgage Loan, whichconstituted approximately 1.0% of the asset pool of the issuing entity as ofits cut-off date.  The Global Data Center Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the Global DataCenter Mortgage Loan and one other *pari passu* loan, which is not anasset of the issuing entity. The other *pari passu* portion of the loancombination was securitized in the UBS Commercial Mortgage Trust 2019-C17transaction, Commission File Number 333-227784-04 (the “UBS 2019-C17Transaction”). This loan combination, including the Global Data CenterMortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the UBS 2019-C17 Transaction, which is incorporated byreference as Exhibit 4.4 to this Annual Report on Form 10-K.

The master servicer of a poolingand servicing agreement or trust and servicing agreement also functions as theprimary servicer of the related mortgage loans serviced and 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 master servicer and certificate administrator of themortgage loans serviced under the Pooling and Servicing Agreement and theprimary servicer of The Tower at Burbank Mortgage Loan and the Global DataCenter Mortgage Loan. As a result, Wells Fargo Bank, National Association is a“servicer” as defined in Item 1108(a)(2)(iii) of Regulation AB, in thecapacities described above, because it is servicing mortgage loans thatconstituted 10% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby Wells Fargo Bank, National Association in the capacities described above arelisted in the Exhibit Index.

Wells Fargo Bank, NationalAssociation is the custodian of the mortgage loans serviced under the Poolingand Servicing Agreement, The Tower at Burbank Mortgage Loan, the Grand CanalShoppes Mortgage Loan and the Global Data Center Mortgage Loan.  As aresult, 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 Exhibit Index.

Rialto Capital Advisors, LLC isthe special servicer of the mortgage loans serviced under the Pooling andServicing Agreement and the Global Data Center Mortgage Loan. As a result,Rialto Capital Advisors, LLC is a “servicer” as defined in Item 1108(a)(2)(iii)of Regulation AB, in the capacities described above, because it is servicingmortgage loans that constituted 10% or more of the assets of the issuing entityas of its cut-off date. The assessments of compliance with applicable servicingcriteria, accountants’ attestation reports and servicer compliance statementsdelivered by Rialto Capital Advisors, LLC in the capacities described above arelisted in the Exhibit Index.

Midland Loan Services, a Divisionof PNC Bank, National Association is the primary servicer of the Storage PostPortfolio Mortgage Loan and the Grand Canal Shoppes Mortgage Loan. As a result,Midland Loan Services, a Division of PNC Bank, National Association is a“servicer” as defined in Item 1108(a)(2)(iii) of Regulation AB, in thecapacities described above, because it is servicing mortgage loans thatconstituted 10% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby Midland Loan Services, a Division of PNC Bank, National Association in thecapacities described above are listed in the Exhibit Index.

Wells Fargo Bank, NationalAssociation acts as trustee of the Grand Canal Shoppes Mortgage Loan. Pursuant to the pooling and servicing agreement for the MSC 2019-H7Transaction, 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 Grand Canal Shoppes Mortgage Loan have delivered one or more assessments ofcompliance with respect to Item 1122(d)(2)(iii) of Regulation AB.

Wilmington Trust, NationalAssociation acts as trustee of the mortgage loans serviced under the Poolingand Servicing Agreement, The Tower at Burbank Mortgage Loan and the Global DataCenter Mortgage Loan.  Pursuant to the Pooling and Servicing Agreement,the pooling and servicing agreement for the BANK 2019-BNK20 Transaction and thepooling and servicing agreement for the UBS 2019-C17 Transaction, the trusteeis required 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 serviced underthe Pooling and Servicing Agreement, The Tower at Burbank Mortgage Loan and theGlobal Data Center 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 ServicingAgreement (except with respect to those mortgageloans for which Midland Loan Services, a Division of PNC Bank, NationalAssociation is the primary servicer) and the primary servicer of TheTower at Burbank Mortgage Loan and the Global Data Center Mortgage Loan toremit tax payments received from the escrow accounts of borrowers to localtaxing authorities, to report tax amounts due, to verify tax parcelinformation, and to verify non-escrow tax payments. These servicing functionsare included within the servicing criteria set forth in Items 1122(d)(4)(xi)and 1122(d)(4)(xii) of Regulation AB.  Therefore, under theprinciples-based definition of “servicer” set forth in Item 1101(j) ofRegulation AB that looks to the functions that an entity performs, this vendoris 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.  *See*Compliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

Theassessments of compliance with applicable servicing criteria, accountants’attestation reports and servicer compliance statements of the certificateadministrator of the Grand Canal Shoppes Mortgage Loan, The Tower at BurbankMortgage Loan and the Global Data Center Mortgage Loan are omitted from thisAnnual Report on Form 10-K as the certificate administrator pursuant to therelated pooling and servicing agreement or trust and servicing agreement doesnot perform any activities that address servicing criteria with respect to theissuing entity and because they are each not a “servicer” that meets thecriteria in Item 1108(a)(2)(i) through (iii) of Regulation AB.

With respect to the *pari passu*loan combinations that include the Grand Canal Shoppes Mortgage Loan, The Towerat Burbank Mortgage Loan and the Global Data Center Mortgage Loan, (i) thereports on assessment of compliance with servicing criteria and attestationreports on assessment of compliance with servicing criteria of Situs Holdings,LLC as special servicer of the Grand Canal Shoppes Mortgage Loan and PentalphaSurveillance LLC as operating advisor of the Grand Canal Shoppes Mortgage Loanand the Global Data Center Mortgage Loan, listed on the Exhibit Index areomitted from this Annual Report on Form 10-K as they are not required to beincluded on this Annual Report on Form 10-K per Instruction 3 to Item 1122 ofRegulation AB because they are parties performing activities that addressservicing criteria relating to 5% or less of the assets of the issuing entity;and (ii) the servicer compliance statements of Situs Holdings, LLC as specialservicer of the Grand Canal Shoppes Mortgage Loan and LNR Partners, LLC asspecial servicer of The Tower at Burbank 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 1C.  Cybersecurity.**

Omitted.

**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 materialpending legal proceeding involving the trust or any party related to the trust,other than routine litigation incidental to the duties of those respectiveparties, and the following, with respect to Wells Fargo Bank, NationalAssociation, as certificate administrator, as trustee and as custodian.

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, IKB International and IKB Deutsche Industriebank (together, IKB) in NewYork state court, and Park Royal I LLC and Park Royal II LLC 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 of default,and abide by appropriate standards of care following alleged events of default.In July 2022, the district court dismissed Phoenix Light’s claims and certainof the claims asserted by Commerzbank AG, and subsequently entered judgment ineach case in favor of Wells Fargo Bank, N.A. In August 2022, Phoenix Light andCommerzbank AG each appealed the district court’s decision to the United StatesCourt of Appeals for the Second Circuit. Phoenix Light dismissed its appeal inMay 2023, terminating its case. In November 2023, Wells Fargo Bank, N.A.entered into an agreement with IKB to resolve IKB’s claims. Wells Fargo Bank,N.A. previously settled two class actions filed by institutional investors andan action filed by the National Credit Union Administration with similarallegations.

**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 entity filedon October 23, 2019 pursuant to Rule 424(b)(2).

**Item 1122 of Regulation AB, Compliance with ApplicableServicing Criteria.**

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the mortgage loans are attachedhereto under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit Zto the Pooling and Servicing Agreement incorporated by reference as Exhibit 4.1to this Annual Report on Form 10-K is a chart identifying the entitiesparticipating in a servicing function for the transaction responsible for eachapplicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Grand Canal Shoppes MortgageLoan, which is being serviced and administered pursuant to the pooling andservicing agreement for the MSC 2019-H7 Transaction, are attached hereto underItem 15 to this Annual Report on Form 10-K. Attached as Exhibit AA to thepooling and servicing agreement for the MSC 2019-H7 Transaction incorporated byreference as Exhibit 4.2 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the MSC2019-H7 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to The Tower at Burbank Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the BANK 2019-BNK20 Transaction, are attached hereto under Item15 to this Annual Report on Form 10-K. Attached as Exhibit Z to the pooling andservicing agreement for the BANK 2019-BNK20 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 BANK2019-BNK20 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 Global Data Center Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the UBS 2019-C17 Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit Z to the pooling andservicing agreement for the UBS 2019-C17 Transaction incorporated by referenceas Exhibit 4.4 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the UBS 2019-C17 Transactionresponsible for each applicable servicing criteria set forth in Item 1122(d).

**Item 1123 of Regulation AB, Servicer Compliance Statement.**

The servicer compliance statements are attached as Exhibitsto this Annual Report on Form 10-K.

**PART IV**

**Item 15. 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, by and among Banc of America Merrill Lynch Commercial Mortgage Inc., asDepositor, Wells Fargo Bank, National Association, as Master Servicer, RialtoCapital Advisors, LLC, as Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator, Wilmington Trust, NationalAssociation, as Trustee, and Park Bridge Lender Services LLC, as OperatingAdvisor and Asset Representations Reviewer (filed as Exhibit 4.1 to theregistrant’s Current Report on Form 8-K filed on October 23, 2019 underCommission File No. 333-228375-02 and incorporated by reference herein).

4.2          Pooling and Servicing Agreement, dated as of July 1,2019, by and among Morgan Stanley Capital I Inc., as Depositor, Midland LoanServices, a Division of PNC Bank, National Association, as Master Servicer, LNRPartners, LLC, as Special Servicer, Wells Fargo Bank, National Association, asCertificate Administrator and Trustee, and Pentalpha Surveillance LLC, asOperating Advisor and Asset Representations Reviewer (filed as Exhibit 4.3 tothe registrant’s Current Report on Form 8-K filed on October 23, 2019 underCommission File No. 333-228375-02 and incorporated by reference herein).

4.3          Pooling and Servicing Agreement, dated as of September 1,2019, by and among Morgan Stanley Capital I Inc., as Depositor, Wells FargoBank, National Association, as General Master Servicer, Midland Loan Services,a Division of PNC Bank, National Association, as General Special Servicer,National Cooperative Bank, N.A., as NCB Master Servicer and as NCB SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Park Bridge LenderServices LLC, as Operating Advisor and Asset Representations Reviewer (filed asExhibit 4.2 to the registrant’s Current Report on Form 8-K filed on October 23,2019 under Commission File No. 333-228375-02 and incorporated by referenceherein).

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

4.5          Agreement Between Note Holders, dated as of September 16,2019, by and between Bank of America, N.A., as Initial Note A-1 Holder, andBank of America, N.A., as Initial Note A-2 Holder, and Bank of America, N.A.,as Initial Note A-3 Holder, and Bank of America, N.A., as Initial Note A-4Holder, and Bank of America, N.A., as Initial Note A-5 Holder, and Bank ofAmerica, N.A., as Initial Note A-6 Holder, and Bank of America, N.A., asInitial Note A-7 Holder, and Bank of America, N.A., as Initial Note A-8 Holder,and Bank of America, N.A., as Initial Note A-9 Holder, and Bank of America,N.A., as Initial Note A-10 Holder (filed as Exhibit 4.5 to the registrant’sCurrent Report on Form 8-K filed on October 23, 2019 under Commission File No.333-228375-02 and incorporated by reference herein).

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

4.7          Agreement Between Note Holders, dated as of October 23,2019, by and between Morgan Stanley Bank, N.A., as Initial Note A-1 Holder,Morgan Stanley Bank, N.A., as Initial Note A-2 Holder, Morgan Stanley Bank,N.A., as Initial Note A-3 Holder, and Morgan Stanley Mortgage Capital HoldingsLLC, as Initial Agent (filed as Exhibit 4.7 to the registrant’s Current Reporton Form 8-K filed on October 23, 2019 under Commission File No. 333-228375-02and incorporated by reference herein).

4.8          Agreement Between Note Holders, dated as of September 26,2019, by and between Wells Fargo Bank, National Association, as Initial NoteA-1 Holder, Wells Fargo Bank, National Association, as Initial Note A-2 Holder,and Wells Fargo Bank, National Association, as Initial Note A-3 Holder (filedas Exhibit 4.8 to the registrant’s Current Report on Form 8-K filed on October23, 2019 under Commission File No. 333-228375-02 and incorporated by referenceherein).

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

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

4.11         Agreement Between Note Holders, dated as of October 23,2019, by and between Morgan Stanley Bank, N.A., as Initial Note A-1 Holder,Morgan Stanley Bank, N.A., as Initial Note A-2 Holder, Morgan Stanley Bank,N.A., as Initial Note A-3 Holder, and Morgan Stanley Mortgage Capital HoldingsLLC, as Initial Agent (filed as Exhibit 4.11 to the registrant’s Current Reporton Form 8-K filed on October 23, 2019 under Commission File No. 333-228375-02and incorporated by reference herein).

4.12         Agreement Between Noteholders, dated as of July 3, 2019,between Morgan Stanley Bank, N.A., as Note A-1 Holder, Wells Fargo Bank,National Association, as Note A-2 Holder, JPMorgan Chase Bank, NationalAssociation, as Note A-3 Holder, Goldman Sachs Bank USA, as Note A-4 Holder,and CPPIB Credit Investments II Inc., as Note B Holder (filed as Exhibit 4.12to the registrant’s Current Report on Form 8-K filed on October 23, 2019 underCommission File No. 333-228375-02 and incorporated by reference herein).

4.13         Agreement Between Note Holders, dated as of October 15,2019, by and between Wells Fargo Bank, National Association, as Initial NoteA-1 Holder, and Wells Fargo Bank, National Association, as Initial Note A-2Holder (filed as Exhibit 4.14 to the registrant’s Current Report on Form 8-Kfiled on October 23, 2019 under Commission File No. 333-228375-02 andincorporated by reference herein).

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

31           Rule 13a-14(d)/15d-14(d) Certifications.

33           Reports on assessment of compliance with servicing criteria for asset-backedsecurities.

33.1        Wells Fargo Bank, National Association, as MasterServicer

33.2        Rialto Capital Advisors, LLC, as Special Servicer

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

33.4        Wells Fargo Bank, National Association, asCertificate Administrator

33.5        Wells Fargo Bank, National Association, asCustodian

33.6        Park Bridge Lender Services LLC, as OperatingAdvisor

33.7        CoreLogic Solutions, LLC, as Servicing FunctionParticipant

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

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

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

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

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

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

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

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

33.16       Computershare Trust Company, National Association, asServicing Function Participant for the Custodian (see Exhibit 33.9)

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

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

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

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

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

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

33.23      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.9)

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

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

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

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

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

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

33.30      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.9)

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

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

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

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

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

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

33.37      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.9)

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

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

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

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

33.42      Park Bridge Lender Services LLC, as OperatingAdvisor of the National Anchored Retail Portfolio Mortgage Loan (see Exhibit33.6)

33.43      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the National Anchored Retail Portfolio Mortgage Loan (seeExhibit 33.7)

33.44      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.9)

33.45      Wells Fargo Bank, National Association, as Primary Servicerof the Tysons Tower Mortgage Loan (see Exhibit 33.1)

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

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

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

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

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

33.51      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.9)

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

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

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

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

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

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

33.58      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.9)

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

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

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

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

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

33.64      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.9)

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

33.66      LNR Partners, LLC, as Special Servicer of TheTower at Burbank Mortgage Loan

33.67      Wilmington Trust, National Association, as Trustee of The Tower at Burbank MortgageLoan (Omitted. See Explanatory Notes.)

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

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

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

33.71      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.9)

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

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

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

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

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

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

33.78      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.9)

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

34.1        Wells Fargo Bank, National Association, as MasterServicer

34.2        Rialto Capital Advisors, LLC, as Special Servicer

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

34.4        Wells Fargo Bank, National Association, asCertificate Administrator

34.5        Wells Fargo Bank, National Association, asCustodian

34.6        Park Bridge Lender Services LLC, as OperatingAdvisor

34.7        CoreLogic Solutions, LLC, as Servicing FunctionParticipant

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

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

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

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

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

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

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

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

34.16      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.9)

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

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

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

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

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

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

34.23      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.9)

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

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

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

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

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

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

34.30      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.9)

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

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

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

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

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

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

34.37      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.9)

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

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

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

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

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

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

34.44      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.9)

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

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

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

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

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

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

34.51      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.9)

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

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

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

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

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

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

34.58      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.9)

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

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

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

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

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

34.64      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.9)

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

34.66      LNR Partners, LLC, as Special Servicer of TheTower at Burbank Mortgage Loan

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

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

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

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

34.71      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.9)

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

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

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

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

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

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

34.78      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.9)

35           Servicer compliance statements.

35.1        Wells Fargo Bank, National Association, as MasterServicer

35.2        Rialto Capital Advisors, LLC, as Special Servicer

35.3        Wells Fargo Bank, National Association, asCertificate Administrator

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

35.22      LNR Partners, LLC, as Special Servicer of The Tower at Burbank Mortgage Loan(Omitted. See Explanatory Notes.)

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

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

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

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

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

(b)   The exhibits required to be filed by theRegistrant pursuant to Item 601 of Regulation S-K are listed above.

(c)    Not Applicable.

 

**SIGNATURES**

Pursuant to the requirements of Section 13 or 15(d) of theSecurities Exchange Act of 1934, the registrant has duly caused this report tobe signed on its behalf by the undersigned, thereunto duly authorized.

Banc of America Merrill LynchCommercial Mortgage Inc.(Depositor)

/s/ Leland F. Bunch, III

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

(senior officer in charge ofsecuritization of the depositor)

Date: March 13, 2024