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KPMG LLP

Suite 1000

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Charlotte, North Carolina28202-1842

  

 

**Report of Independent Registered Public Accounting Firm**

 

 

The Board of Directors

Wells Fargo Bank, NationalAssociation:

 

We have examined management s assertion,included in the accompanying Management s Assessment, that Wells FargoCommercial Mortgage Servicing, a division of Wells Fargo Bank, NationalAssociation, (the Company) complied with the servicing criteria set forth inItem 1122(d) of the Securities and Exchange Commission s Regulation AB (theServicing Criteria) for Commercial and Multifamily Loans (the Platform) exceptfor servicing criteria 1122(d)(1)(iii), 1122(d)(3)(i)(B-D), 1122(d)(3)(ii-iv),and 1122(d)(4)(xv), which the Company has determined are not applicable to theactivities it performs with respect to the Platform (the Servicing Criteria),as of and for the year ended December 31, 2019. The Company has determined thatservicing criteria 1122(d)(4)(xi) and 1122(d)(4)(xii) are applicable to theactivities the Company performs with respect to the Platform, except forcertain tax payment activities that the Company has engaged various vendors toperform. With respect to applicable servicing criterion 1122(d)(4)(iii), theCompany has determined that there were no activities performed during the yearended December 31, 2019 with respect to the Platform because there were nooccurrences of events that would require the Company to perform suchactivities. Appendix A to Management s Assessment identifies the individualasset-backed transactions and securities defined by management as constitutingthe Platform. Management is responsible for the Company s compliance with theServicing Criteria. Our responsibility is to express an opinion on management sassertion about the Company s compliance with the Servicing Criteria based onour examination.

 

Our examination was conductedin accordance with the standards of the Public Company Accounting OversightBoard (United States) and in accordance with attestation standards establishedby the American Institute of Certified Public Accountants to obtain reasonableassurance and, accordingly, included examining, on a test basis, evidence aboutthe Company s compliance with the Servicing Criteria and performing such otherprocedures as we considered necessary in the circumstances. Our examinationincluded testing selected asset-backed transactions and securities thatcomprise the Platform, testing selected servicing activities related to thePlatform, and determining whether the Company processed those selectedtransactions and performed those selected activities in compliance with theServicing Criteria. Furthermore, our procedures were limited to the selectedtransactions and servicing activities performed by the Company during theperiod covered by this report. Our procedures were not designed to determinewhether errors may have occurred either prior to or subsequent to our teststhat may have affected the balances or amounts calculated or reported by the Companyduring the period covered by this report for the selected transactions or anyother transactions. We believe that our examination provides a reasonable basisfor our opinion. Our examination does not provide a legal determination on theCompany s compliance with the Servicing Criteria.

 

As described in theaccompanying Management s Assessment, for servicing criteria 1122(d)(4)(i),1122(d)(4)(vi), 1122(d)(4)(xi), and 1122(d)(4)(xii), the Company has engagedvarious vendors to perform the activities required by these servicing criteria.The Company has determined that none of these vendors is considered a serviceras defined in Item 1101(j) of Regulation AB, and the Company has elected totake responsibility for assessing compliance with the servicing criteriaapplicable to each vendor as permitted by the SEC s *Compliance andDisclosure Interpretation (C&DI) 200.06, Vendors Engaged by Servicers*(C&DI 200.06). As permitted by C&DI 200.06, the Company has assertedthat it has policies and procedures in place designed to provide reasonableassurance that the vendors activities comply in all material respects with theservicing criteria applicable to each vendor. The Company is solely responsiblefor determining that it meets the SEC requirements to apply C&DI 200.06 forthe vendors and related servicing criteria as described in its assertion, andwe performed no procedures with respect to the Company s eligibility to applyC&DI 200.06.

 

In our opinion, management sassertion that Wells Fargo Commercial Mortgage Servicing, a division of WellsFargo Bank, National Association, complied with the aforementioned ServicingCriteria, including servicing criteria 1122(d)(4)(i) 1122(d)(4)(vi),1122(d)(4)(xi), and 1122(d)(4)(xii) for which compliance is determined based onC&DI 200.06 as described above, as of and for the year ended December 31,2019 is fairly stated, in all material respects.

 

 

/s/ KPMG LLP

 

 

Charlotte, North Carolina 

February 28, 2020

 

 

KPMG LLP is a Delaware limitedliability partnership and the U.S. member 

firm of the KPMG network ofindependent member firms affiliated with 

KPMG International Cooperative(“KPMG International”), a Swiss entity.