Management's Assertion

 

Report on Assessment of Compliance with ApplicableServicing Criteria

 

Management of U.S. Bank NationalAssociation (“U.S. Bank”) is responsible for assessing compliance as of and forthe year ended December 31, 2023 with the servicing criteria set forth in Item1122 (d) of Regulation AB applicable to it as set forth on Exhibit A hereto.This report covers asset backed securities transactions within the **U.S. BankCorporate Trust Asset-Backed Securities Platform1 (the “Platform”)**

 

U.S. Bank hereby provides thefollowing report on its assessment of compliance with the servicing criteriaset forth in Item 1122 of Regulation AB applicable to it and as described onExhibit A hereto:

 

1.      U.S. Bank is responsible for assessing itscompliance with the servicing criteria applicable to it as noted on theaccompanying Exhibit A;

 

2.      Except as set forth in paragraph 3 below,U.S. Bank used the criteria set forth in paragraph (d) of Item 1122 ofRegulation AB to assess its compliance with the applicable servicing criteria;

 

3.      The criteria listed in the column titled“Inapplicable Servicing Criteria” on Exhibit A hereto are inapplicable to U.S.Bank based on the servicing activities it performs directly with respect to thePlatform;

 

4.      U.S. Bank has complied, in all materialrespects, with the applicable servicing criteria as of and for the year endedDecember 31, 2023; and

 

5.      Ernst & Young, LLP, a registeredpublic accounting firm, has issued an attestation report on U.S. Bank’sassessment of compliance with the applicable servicing criteria as of and forthe year ended December 31, 2023.

 

 

U.S. BANK NATIONALASSOCIATION  

 

/s/ Jeff Kerr

Name: Jeff Kerr

Title: Executive VicePresident 

 

Date: February 27, 2024

 

 

1 The U.S. Bank Corporate Trust Asset-Backed SecuritiesPlatform (the "Platform") consists of the activities involved in theperformance of servicing functions for which the Company provides documentcustody services for (i) publicly issued asset-backed and mortgage-backedtransactions the securities of which were offered on or after January 1, 2006and (ii) certain asset-backed transactions for which the Issuer has voluntarilyelected to make Regulation AB compliant filings under the Securities ExchangeAct of 1934, as amended.

 

 

**EXHIBIT A to Management’s Assertion**

 

| **Reference**                                               | **Servicing****Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | **Applicable Servicing Criteria** | **Inapplicable  Servicing Criteria** |
|-------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------|--------------------------------------|
| **General********Servicing********Considerations**          |
| 1122(d)(1)(i)                                               | Policiesandproceduresareinstitutedtomonitoranyperformanceorothertriggers

andeventsofdefaultinaccordancewiththetransaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |                              | **X**                                |
| ** **

1122(d)(1)(ii)                                  | If  any material servicing activities are outsourced to third parties, policies  and proceduresareinstitutedtomonitorthethirdparty’sperformanceandcompliance with such servicing  activities.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | ** **

**X****2**            |                                 |
| ** **

1122(d)(1)(iii)                                 | Anyrequirementsinthetransactionagreementstomaintainaback-upservicerfor the Pool Assets are maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |                              | ** **

**X**                    |
| ** **

1122(d)(1)(iv)                                  | A fidelity bond and errors and omissions policy is in  effect on the party participatingintheservicingfunctionthroughoutthereportingperiodintheamount of coverage required by and  otherwise in accordance with the terms of the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                        | ** **

**X**                 |                                 |
| ** **

1122(d)(1)(v)                                   | Aggregationofinformation,asapplicable,ismathematicallyaccurateandthe information  conveyed accurately reflects the information.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |                              | ** **

**X**                    |
| **Cash********Collection********and****Administration**     |
| 1122(d)(2)(i)                                               | Paymentsonpoolassetsaredepositedintotheappropriatecustodialbankaccounts and related bank clearing accounts  no more than two business days following receipt, or such other number of  days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                            |                              | **X**                                |
| 1122(d)(2)(ii)                                              | Disbursementsmadeviawiretransferonbehalfofanobligorortoaninvestorare made only by authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |                              | **X**                                |
| ** **

1122(d)(2)(iii)                                 | ** **

Advancesoffundsorguaranteesregardingcollections,cashflowsordistributions, and any interest  or other fees charged for such advances, are made, reviewed and approved as  specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |                              | ** **

**X**                    |
| 1122(d)(2)(iv)                                              | Therelated  accounts forthetransaction, such as cash reserveaccounts or accounts establishedasaformofovercollateralization,areseparatelymaintained(e.g.,with respect  to commingling of cash) as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                       |                              | **X**                                |
| 1122(d)(2)(v)                                               | Each  custodial account is maintained at a federally insured depository institution  as set forth in the transaction agreements. For purposes of this criterion,  “federally insureddepositoryinstitution”withrespecttoaforeignfinancialinstitutionmeansa foreign financial institution that meets the requirements of Rule  13k-1(b)(1) of the Securities Exchange Act.                                                                                                                                                                                                                                                                                                            |                              | **X**                                |
| ** **

1122(d)(2)(vi)                                  | ** **

Unissuedchecksaresafeguardedsoastopreventunauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |                              | ** **

**X**                    |
| 1122(d)(2)(vii)                                             | Reconciliations are prepared on a monthly basis for  all asset-backed securities related bank accounts, including custodial  accounts and related bank clearing accounts. These reconciliations are (A)  mathematically accurate; (B) prepared within 30 calendar days after the bank  statement cutoff date, or such other number of days specified in the  transaction agreements; (C) reviewed and approved by someone other than the  person who prepared the reconciliation; and (D) contain explanations for  reconciling items. These reconciling items are resolved within 90 calendardaysoftheiroriginalidentification,orsuchothernumberofdaysspecified in the transaction agreements. |                              | **X**                                |
| **Investor********Remittances********and********Reporting** |
|  

1122(d)(3)(i)                                       |  

Reports  to investors, including those to be filed with the Commission, are maintained  in accordance with the transaction agreements and applicable Commissionrequirements.Specifically,suchreports(A)arepreparedinaccordance withtimeframesandothertermssetforthinthetransactionagreements;(B)provide information calculated in  accordance with the terms specified in the transaction agreements; (C) are  filed with the Commission as required by its rules and

regulations;and(D)agreewithinvestors’orthetrustee’srecordsastothetotal unpaid principal balance and  number of Pool Assets serviced by the Servicer.                                                 |                              |  

**X**                        |
|  

1122(d)(3)(ii)                                      |  

Amountsduetoinvestorsareallocatedandremittedinaccordancewithtimeframes, distribution priority and other terms set forth in the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |                              |  

**X**                        |
|  

1122(d)(3)(iii)                                     |  

Disbursementsmadetoaninvestorarepostedwithintwo businessdaystothe Servicer’s investor records,  or such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             |                              |  

**X**                        |
| 1122(d)(3)(iv)                                              | Amountsremittedtoinvestorspertheinvestorreportsagreewithcancelledchecks, or other form  of payment, or custodial bank statements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |                              | **X**                                |
| **Pool********Asset****Administration**                     |
|  

1122(d)(4)(i)                                       |  

Collateralorsecurityonpoolassetsismaintainedasrequiredbythetransaction agreements or related pool  asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |  

**X**                     |                                 |
| 1122(d)(4)(ii)                                              | Poolassetsandrelateddocumentsaresafeguardedasrequiredbythetransaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | **X**                             |                                 |
| 1122(d)(4)(iii)                                             | Anyadditions,removalsorsubstitutionstotheassetpoolaremade,reviewedand approved in  accordance with any conditions or requirements in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | **X**                             |                                 |
|  

1122(d)(4)(iv)                                      |  

Paymentson  poolassets,including anypayoffs,madeinaccordancewith the

relatedpoolassetdocumentsarepostedtotheServicer’sobligorrecordsmaintained no more than two business  days after receipt, or such other number of daysspecified in the transaction agreements, and allocated to  principal, interest or other items (e.g., escrow) in accordance with the  related pool asset documents.                                                                                                                                                                                                                                                                                     |                              |  

**X**                        |
|  

1122(d)(4)(v)                                       | TheServicer’srecordsregardingthepoolassetsagreewiththeServicer’srecords with respect to an obligor’s unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                              |  

**X**                        |
|  

1122(d)(4)(vi)                                      |  

Changeswithrespecttothetermsorstatusofanobligor'spoolassets(e.g.,loan modifications or re-agings) are made, reviewed and approved by  authorized personnel in accordance with the transaction agreements and  related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                             |                              |  

**X**                        |
|  

1122(d)(4)(vii)                                     |  

Lossmitigationorrecoveryactions(e.g.,forbearanceplans,modificationsand deeds in  lieu of foreclosure, foreclosures and repossessions, as applicable) are  initiated,conductedandconcludedinaccordancewiththetimeframesorother  requirements established by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                  |                              |  

**X**                        |
|  

1122(d)(4)(viii)                                    |  

Records  documenting collection efforts are maintained during the period a pool asset is  delinquent in accordance with the transaction agreements.Such records are maintained on at least  a monthly basis, or such other period specified in the transactionagreements,anddescribetheentity’sactivitiesinmonitoringdelinquent pool assets including, for  example, phone calls, letters and payment rescheduling plans in cases where  delinquency is deemed temporary (e.g., illness or unemployment).                                                                                                                                                                         |                              |  

**X**                        |
|  

1122(d)(4)(ix)                                      |  

Adjustmentstointerestratesorratesofreturnforpoolassetswithvariableratesare computed based on the related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |                              |  

**X**                        |
|  

1122(d)(4)(x)                                       |  

Regardinganyfundsheldintrustforanobligor(suchasescrowaccounts):(A)such funds are analyzed, in accordance  with the obligor’s pool asset documents, on at least an annual basis, or such  other period specified in the transaction agreements;

(B) interest on such funds is paid, or credited, to  obligors in accordance with applicablepoolassetdocumentsandstatelaws;and(C)suchfundsarereturnedto theobligorwithin 30 calendardaysoffullrepaymentoftherelated poolassets,or such  other number of days specified in the transaction agreements.                                                                                                                              |                              |  

**X**                        |
|  

1122(d)(4)(xi)                                      |  

Payments  made on behalf of an obligor (such as tax or insurance payments) are made on  or before the related penalty or expiration dates, as indicated on the  appropriatebillsornoticesforsuchpayments,provided thatsuchsupporthasbeen

receivedbytheserviceratleast30calendardayspriortothesedates,orsuchother number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                               |                              |  

**X**                        |
|  

1122(d)(4)(xii)                                     | Anylatepaymentpenaltiesinconnectionwithanypaymenttobemadeonbehalfof an obligor are paid from the Servicer’s funds and not charged to  the obligor, unless the late payment was due to the obligor’s error or  omission.                                                                                                                                                                                                                                                                                                                                                                                                                                                             |                              |  

**X**                        |
|  

1122(d)(4)(xiii)                                    | Disbursementsmadeonbehalfofanobligorarepostedwithintwobusinessdaysto the obligor’s records maintained by the servicer, or such other  number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             |                              |  

**X**                        |
|  

1122(d)(4)(xiv)                                     | Delinquencies,charge-offsanduncollectibleaccountsarerecognizedandrecorded in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |                              |  

**X**                        |
|  

1122(d)(4)(xv)                                      |  

Anyexternalenhancementorothersupport,identified inItem1114(a)(1)through

(3)orItem1115ofRegulationAB,ismaintainedassetforthinthetransaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |                              |  

**X**                        |

 

2Noservicing activitieswereperformedbytheCompanythatrequiredtheservicingcriteriatobecomplied with

 

CorporateTrustABSPlatform(C)