**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, 2019or**

**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: 333-226850-04**

**Central Index Key Number of the issuing entity:0001790441**

**BBCMS Mortgage Trust 2019-C5**

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

** **

**Central Index Key Number of the depositor: 0001541480**

**Barclays Commercial MortgageSecurities LLC**

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

** **

**Central Index Key Number of the sponsor: 0001549574**

**Barclays Capital Real Estate Inc.**

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

** **

**Central Index Key Number of the sponsor: 0001089877**

**KeyBank National Association**

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

** **

**Central Index Key Number of the sponsor: 0001542256**

**Natixis Real Estate Capital LLC**

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

** **

**Central Index Key Number of the sponsor: 0001755531**

**Societe Generale FinancialCorporation**

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

** **

**Central Index Key Number of the sponsor: 0001592182**

** LMF Commercial, LLC**

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

**(formerly known as RialtoMortgage Finance, LLC)**

** **

**Central Index Key Number of the sponsor: 0001722518**

** BSPRT CMBS Finance,LLC**

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

** **

** **

** **

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

**the issuing entity)** | **38-4128798**

**38-4128799**

**38-7235613**

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

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

**c/o Wells Fargo Bank, National Association**

**as Certificate Administrator**

**9062 Old Annapolis Road**

**Columbia, MD**

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

**21045**

**(Zip Code)**

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

**(212) 412-4000**

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 and posted on its corporate Web site, if any, every InteractiveData File required to be submitted and posted pursuant to Rule 405 ofRegulation S-T (Section 232.405 of this chapter) during the preceding 12 months(or for such shorter period that the registrant was required to submit and postsuch files).

Not applicable.

Indicate by check mark if disclosure of delinquent filerspursuant to Item 405 of Regulation S-K (Section 229.405 of this chapter) is notcontained herein, and will not be contained, to the best of registrant’sknowledge, in definitive proxy or information statements incorporated byreference in Part III of this Form 10-K or any amendment to this Form10-K.   

Not applicable.

Indicate by check mark whether the registrant is a largeaccelerated filer, an accelerated filer, a non-accelerated filer, a smaller reportingcompany, or an emerging growth company. See the definitions of “largeaccelerated filer,” “accelerated filer,” “smaller reporting company,” and“emerging growth company” in Rule 12b-2 of the Exchange Act.

Large acceleratedfiler        o                                                                                                       Acceleratedfiler                                     o

Non-acceleratedfiler          ⌧  (Do not check ifa smaller reporting company)                          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 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 all documentsand reports required to be filed by Section 12, 13 or 15(d) of the SecuritiesExchange Act of 1934 subsequent to the distribution of securities under a planconfirmed by a court.  o Yes 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 documents shouldbe clearly described for identification purposes (e.g., annual report tosecurity holders for fiscal year ended December 24, 1980).

Not applicable.

 

** **

**EXPLANATORY NOTES**

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the NEMA San Francisco Mortgage Loan, whichconstituted approximately 4.0% of the asset pool of the issuing entity as ofits cut-off date.  The NEMA San Francisco Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the NEMA SanFrancisco Mortgage Loan and three other *pari passu* loans and threesubordinate companion loans, which are not assets of the issuing entity. A *paripassu* portion of the loan combination was securitized in the NatixisCommercial Mortgage Securities Trust 2019-NEMA transaction (the “NCMS2019-NEMA Transaction”). This loan combination, including the NEMA SanFrancisco Mortgage Loan, is being serviced and administered pursuant to thetrust and servicing agreement for the NCMS 2019-NEMA 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 10000 Santa Monica Boulevard Mortgage Loan,which constituted approximately 3.5% of the asset pool of the issuing entity asof its cut-off date.  The 10000 Santa Monica Boulevard Mortgage Loan is anasset of the issuing entity and is part of a loan combination that includes the10000 Santa Monica Boulevard Mortgage Loan and seven other *pari passu*loans and one subordinate companion loan, which are not assets of the issuingentity. A *pari passu* portion of the loan combination was securitized inthe Natixis Commercial Mortgage Securities Trust 2019-10K transaction (the “NCMS2019-10K Transaction”). This loan combination, including the 10000 SantaMonica Boulevard Mortgage Loan, is being serviced and administered pursuant tothe trust and servicing agreement for the NCMS 2019-10K Transaction, which isincorporated by reference as Exhibit 4.3 to this Annual Report on Form 10-K.

The Exhibit Index describes exhibitsprovided by certain parties (in their capacities indicated on the ExhibitIndex) with respect to the Vanguard Portfolio Mortgage Loan, which constitutedapproximately 0.5% of the asset pool of the issuing entity as of its cut-offdate.  The Vanguard Portfolio Mortgage Loan is an asset of the issuingentity and is part of a loan combination that includes the Vanguard PortfolioMortgage Loan and five other *pari passu* loans and one subordinatecompanion loan, which are not assets of the issuing entity. A *pari passu*portion of the loan combination was securitized in the BBCMS Mortgage Trust2019-C3 transaction, Commission File Number 333-226850-02 (the “BBCMS2019-C3 Transaction”). This loan combination, including the VanguardPortfolio Mortgage Loan, is being serviced and administered pursuant to thepooling and servicing agreement for the BBCMS 2019-C3 Transaction, which isincorporated by reference as Exhibit 4.4 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Moffett Towers II – Buildings 3 & 4Mortgage Loan, which constituted approximately 2.5% of the asset pool of theissuing entity as of its cut-off date.  The Moffett Towers II – Buildings3 & 4 Mortgage Loan is an asset of the issuing entity and is part of a loancombination that includes the Moffett Towers II – Buildings 3 & 4 MortgageLoan and ten other *pari passu* loans and three subordinate companionloans, which are not assets of the issuing entity. A *pari passu* portionof the loan combination was securitized in the MFTII 2019-B3B4 Mortgage Trusttransaction (the “MFTII 2019-B3B4 Transaction”). This loan combination,including the Moffett Towers II – Buildings 3 & 4 Mortgage Loan, is beingserviced and administered pursuant to the trust and servicing agreement for theMFTII 2019-B3B4 Transaction, which is incorporated by reference as Exhibit 4.5to 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 Uline Arena Mortgage Loan, which constitutedapproximately 3.6% of the asset pool of the issuing entity as of its cut-offdate.  The Uline Arena Mortgage Loan is an asset of the issuing entity andis part of a loan combination that includes the Uline Arena Mortgage Loan andfive other *pari passu* loans, which are not assets of the issuing entity.A *pari passu* portion of the loan combination was securitized in the CD2019-CD8 Mortgage Trust transaction, Commission File Number 333-226943-03 (the“CD 2019-CD8 Transaction”). This loan combination, including the UlineArena Mortgage Loan, is being serviced and administered pursuant to the poolingand servicing agreement for the CD 2019-CD8 Transaction, which is incorporatedby reference as Exhibit 4.6 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 Bison Portfolio Mortgage Loan, whichconstituted approximately 2.0% of the asset pool of the issuing entity as ofits cut-off date.  The Bison Portfolio Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the BisonPortfolio 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 CSAIL 2019-C17 Commercial Mortgage Trusttransaction, Commission File Number 333-227081-03 (the “CSAIL 2019-C17Transaction”). This loan combination, including the Bison PortfolioMortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the CSAIL 2019-C17 Transaction, which is incorporatedby reference as Exhibit 4.7 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 Presidential City Mortgage Loan, whichconstituted approximately 4.5% of the asset pool of the issuing entity as ofits cut-off date.  The Presidential City Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the PresidentialCity Mortgage Loan and two other *pari passu* loans and one subordinatecompanion loan, which are not assets of the issuing entity. A *pari passu*portion of the loan combination was securitized in the SG Commercial MortgageSecurities Trust 2019-PREZ transaction (the “SGCMS 2019-PREZ Transaction”).This loan combination, including the Presidential City Mortgage Loan, is beingserviced and administered pursuant to the trust and servicing agreement for theSGCMS 2019-PREZ Transaction, which is incorporated by reference as Exhibit 4.8to 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 GNL Office and Industrial Portfolio MortgageLoan, the Inland Life Storage Portfolio Mortgage Loan and the Ocean Edge Resort& Golf Club Mortgage Loan, which constituted approximately 6.6%, 3.7% and3.0%, respectively, of the asset pool of the issuing entity as of its cut-offdate.  The GNL Office and Industrial Portfolio Mortgage Loan, the Inland LifeStorage Portfolio Mortgage Loan and the Ocean Edge Resort & Golf ClubMortgage Loan are each an asset of the issuing entity and are each part of aloan combination that includes (a) with respect to the GNL Office andIndustrial Portfolio Mortgage Loan and five other *pari passu* loans,which are not assets of the issuing entity, (b) with respect to the Inland LifeStorage Portfolio Mortgage Loan and three other *pari passu* loans, whichare not assets of the issuing entity or (c) with respect to the Ocean EdgeResort & Golf Club Mortgage Loan and one other *pari passu* loan,which is not an asset of the issuing entity. A *pari passu* portion ofeach loan combination was securitized in the CF 2019-CF2 Mortgage Trusttransaction, Commission File Number 333-228697-02 (the “CF 2019-CF2Transaction”). These loan combinations, including the GNL Office andIndustrial Portfolio Mortgage Loan, the Inland Life Storage Portfolio MortgageLoan and the Ocean Edge Resort & Golf Club Mortgage Loan, are beingserviced and administered pursuant to the pooling and servicing agreement forthe CF 2019-CF2 Transaction, which is incorporated by reference as Exhibit 4.9to 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 Ceasar’s Bay Shopping Center Mortgage Loanand the Equinix Data Center Mortgage Loan, which constituted approximately 4.2%and 4.0%, respectively, of the asset pool of the issuing entity as of its cut-offdate.  The Ceasar’s Bay Shopping Center Mortgage Loan and the Equinix DataCenter Mortgage Loan are each an asset of the issuing entity and are each partof a loan combination that includes (a) with respect to the Ceasar’s BayShopping Center Mortgage Loan and one other *pari passu* loan, which isnot an asset of the issuing entity or (b) with respect to the Equinix DataCenter Mortgage Loan and two other *pari passu* loans, which are notassets of the issuing entity. The other *pari passu* portion of each loancombination was securitized in the Wells Fargo Commercial Mortgage Trust2019-C53 transaction, Commission File Number 333-226486-09 (the “WFCM2019-C53 Transaction”). These loan combinations, including the Ceasar’s BayShopping Center Mortgage Loan and the Equinix Data Center Mortgage Loan, arebeing serviced and administered pursuant to the pooling and servicing agreementfor the WFCM 2019-C53 Transaction, which is incorporated by reference asExhibit 4.10 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 NMR Pharmacy Portfolio Mortgage Loan, whichconstituted approximately 1.4% of the asset pool of the issuing entity as ofits cut-off date.  The NMR Pharmacy Portfolio Mortgage Loan is an asset ofthe issuing entity and is part of a loan combination that includes the NMRPharmacy Portfolio Mortgage Loan and one other *pari passu* loan, which isnot an asset of the issuing entity. This loan combination, including the NMRPharmacy Portfolio Mortgage Loan, was serviced under the Pooling and ServicingAgreement for the issuing entity prior to the closing of the securitization ofthe other *pari passu* portion of the NMR Pharmacy Portfolio loancombination in the Wells Fargo Commercial Mortgage Trust 2019-C54 transaction,Commission File Number 333-226486-11 (the “WFCM 2019-C54 Transaction”). After the closing of the WFCM 2019-C54 Transaction on December 3, 2019, thisloan combination, including the NMR Pharmacy Portfolio Mortgage Loan was, andwill continue to be, serviced and administered pursuant to the pooling andservicing agreement with respect to the WFCM 2019-C54 Transaction, which isincorporated by reference as Exhibit 4.11 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.

KeyBank National Association isthe master servicer and special servicer of the mortgage loans serviced underthe Pooling and Servicing Agreement, the primary servicer of the GNL Office andIndustrial Portfolio Mortgage Loan, the Presidential City Mortgage Loan, theNEMA San Francisco Mortgage Loan, the Inland Life Storage Portfolio MortgageLoan, the Ocean Edge Resort & Golf Club Mortgage Loan and the MoffettTowers II – Buildings 3 & 4 Mortgage Loan and the primary servicer andspecial servicer of the 10000 Santa Monica Boulevard Mortgage Loan. As aresult, KeyBank National Association is a “servicer” as defined in Item1108(a)(2)(iii) of Regulation AB, in the capacities described above, because itis servicing mortgage loans that constituted 10% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria, accountants’ attestation reports and servicercompliance statements delivered by KeyBank National Association in thecapacities described above are listed in the Exhibit Index.

Wells Fargo Bank, NationalAssociation is the certificate administrator of the mortgage loans servicedunder the Pooling and Servicing Agreement and the primary servicer of theCeasar’s Bay Shopping Center Mortgage Loan, the Equinix Data Center MortgageLoan and the NMR Pharmacy Portfolio Mortgage Loan. As a result, Wells FargoBank, National Association 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 Wells Fargo Bank, National Association in the capacities describedabove are listed in the Exhibit Index.

Wells Fargo Bank, National Association is the custodian ofthe mortgage loans serviced under the Pooling and Servicing Agreement, thePresidential City Mortgage Loan, the Ceasar’s Bay Shopping Center MortgageLoan, the Equinix Data Center Mortgage Loan, the NEMA San Francisco MortgageLoan, the Uline Arena Mortgage Loan, the 10000 Santa Monica Boulevard MortgageLoan, the Moffett Towers II – Buildings 3 & 4 Mortgage Loan, the BisonPortfolio Mortgage Loan, the NMR Pharmacy Portfolio Mortgage Loan and theVanguard Portfolio Mortgage Loan.  As a result, Wells Fargo Bank, NationalAssociation is a servicing function participant in the capacities describedabove, because it is servicing mortgage loans that constituted 5% or more ofthe assets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria and accountants’ attestationreports delivered by Wells Fargo Bank, National Association in the capacitiesdescribed above are listed in the Exhibit Index.

Pentalpha Surveillance LLC is the operating advisor of themortgage loans serviced under the Pooling and Servicing Agreement and theVanguard Portfolio Mortgage Loan.  As a result, Pentalpha Surveillance LLCis a servicing function participant in the capacities described above, becauseit is servicing mortgage loans that constituted 5% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria and accountants’ attestation reports delivered byPentalpha Surveillance LLC in the capacities described above are listed in theExhibit Index.

Situs Holdings, LLC is the specialservicer of the NEMA San Francisco Mortgage Loan and the Moffett Towers II –Buildings 3 & 4 Mortgage Loan.  These mortgage loans constitute morethan 5%, but less than 10%, of the pool assets of the issuing entity.  Therefore,the Depositor included in this Annual Report on Form 10-K an assessment ofcompliance with applicable servicing criteria for Situs Holdings, LLC and anaccountants’ attestation report pursuant to Item 1122 of Regulation AB becauseSitus Holdings, LLC is servicing more than 5% of the pool assets. However, the Depositor is not required to include in this Annual Report on Form10-K a servicer compliance statement pursuant to Item 1123 of Regulation AB ofSitus Holdings, LLC because Situs Holdings, LLC is an unaffiliated servicerservicing less than 10% of pool assets.

Midland Loan Services, a Divisionof PNC Bank, National Association is the primary servicer and special servicerof the Uline Arena Mortgage Loan, the Bison Portfolio Mortgage Loan and theVanguard Portfolio Mortgage Loan and the special servicer of the Ceasar’s BayShopping Center Mortgage Loan and the Equinix Data Center Mortgage Loan. As aresult, Midland Loan Services, a Division of PNC Bank, National Association isa “servicer” as defined in Item 1108(a)(2)(iii) of Regulation AB, in thecapacities described above, because it is servicing mortgage loans thatconstituted 10% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby Midland Loan Services, a Division of PNC Bank, National Association in thecapacities described above are listed in the Exhibit Index.

Park Bridge Lender Services LLC is the operating advisor ofthe GNL Office and Industrial Portfolio Mortgage Loan, the Ceasar’s BayShopping Center Mortgage Loan, the Equinix Data Center Mortgage Loan, theInland Life Storage Portfolio Mortgage Loan, the Uline Arena Mortgage Loan, theOcean Edge Resort & Golf Club Mortgage Loan, the Bison Portfolio MortgageLoan and the NMR Pharmacy Portfolio Mortgage Loan.  As a result, ParkBridge Lender Services LLC is a servicing function participant in thecapacities described above, because it is servicing mortgage loans thatconstituted 5% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria andaccountants’ attestation reports delivered by Park Bridge Lender Services LLCin the capacities described above are listed in the Exhibit Index.

LNR Partners, LLC is the specialservicer of the GNL Office and Industrial Portfolio Mortgage Loan, the InlandLife Storage Portfolio Mortgage Loan, the Ocean Edge Resort & Golf ClubMortgage Loan and the NMR Pharmacy Portfolio Mortgage Loan. As a result, LNRPartners, LLC is a “servicer” as defined in Item 1108(a)(2)(iii) of RegulationAB, in the capacities described above, because it is servicing mortgage loansthat constituted 10% or more of the assets of the issuing entity as of itscut-off date. The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby LNR Partners, LLC in the capacities described above are listed in theExhibit Index.

Citibank, N.A. is the custodian of the GNL Office andIndustrial Portfolio Mortgage Loan, the Inland Life Storage Portfolio MortgageLoan and the Ocean Edge Resort & Golf Club Mortgage Loan.  As a result,Citibank, N.A. is a servicing function participant in the capacities describedabove, because it is servicing mortgage loans that constituted 5% or more ofthe assets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria and accountants’ attestationreports delivered by Citibank, N.A. in the capacities described above arelisted in the Exhibit Index, and exclude the servicing criteria set forth inItems 1122(d)(4)(i) and 1122(d)(4)(ii) of Regulation AB,  relating to themaintenance of collateral or security on pool assets as required by the poolingand servicing agreement  for the CF 2019-CF2 Transaction  and thesafeguarding of pool assets and related documents as required by the poolingand servicing agreement for the CF 2019-CF2 Transaction, which servicingcriteria have been assessed by U.S. Bank National Association, as a servicingfunction participant, as described below in these Explanatory Notes.

This Annual Report on Form 10-K includes an assessment ofcompliance with applicable servicing criteria and an accountant’s attestationreport from U.S. Bank, National Association. This entity was engaged byCitibank, N.A., as the custodian of the GNL Office and Industrial PortfolioMortgage Loan, the Inland Life Storage Portfolio Mortgage Loan and the OceanEdge Resort & Golf Club Mortgage Loan. to perform certain custodialservices. These custodial services are servicing functions included within theservicing criteria set forth in Items 1122(d)(4)(i) and 1122(d)(4)(ii) ofRegulation AB. Therefore, under the principles-based definition of “servicer”set forth in Item 1101(j) or Regulation AB that looks to the functions that anentity performs, this vendor is a “servicer” for the purposes of Item 1122 ofRegulation AB. See Compliance and Disclosure Interpretations, Section 301.01(Item 1101(j)).

Wells Fargo Bank, NationalAssociation acts as trustee of the NEMA San Francisco Mortgage Loan, the 10000Santa Monica Boulevard Mortgage Loan, the Vanguard Portfolio Mortgage Loan, theMoffett Towers II – Buildings 3 & 4 Mortgage Loan, the Uline Arena MortgageLoan, the Bison Portfolio Mortgage Loan and the Presidential City MortgageLoan.  Pursuant to the trust and servicing agreement for the NCMS 2019-NEMATransaction, the trust and servicing agreement for the NCMS 2019-10KTransaction, the pooling and servicing agreement for the BBCMS 2019-C3Transaction, the trust and servicing agreement for the MFTII 2019-B3B4Transaction, the pooling and servicing agreement for the CD 2019-CD8Transaction, the pooling and servicing agreement for the CSAIL 2019-C17Transaction and the trust and servicing agreement for the SGCMS 2019-PREZTransaction, 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 mortgage loans serviced under the Pooling and Servicing Agreement, the NEMASan Francisco Mortgage Loan, the 10000 Santa Monica Boulevard Mortgage Loan,the Vanguard Portfolio Mortgage Loan, the Moffett Towers II – Buildings 3 &4 Mortgage Loan, the Uline Arena Mortgage Loan, the Bison Portfolio MortgageLoan and the Presidential City Mortgage Loan have delivered one or moreassessments of compliance with respect to Item 1122(d)(2)(iii) of RegulationAB.

Wilmington Trust, NationalAssociation acts as trustee of the Ceasar’s Bay Shopping Center Mortgage Loan,the Equinix Data Center Mortgage Loan and the NMR Pharmacy Portfolio MortgageLoan.  Pursuant to the pooling and servicing agreement for the WFCM2019-C53 Transaction and the pooling and servicing agreement for the WFCM2019-C54 Transaction, the trustee is required to provide an assessment ofcompliance with applicable servicing criteria solely with respect to Item1122(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 Ceasar’s Bay Shopping Center Mortgage Loan, the Equinix Data CenterMortgage Loan and the NMR Pharmacy Portfolio Mortgage Loan have delivered oneor more assessments of compliance with respect to Item 1122(d)(2)(iii) ofRegulation AB.

This Annual Report on Form 10-Kincludes assessments of compliance with applicable servicing criteria andaccountants’ attestation reports from CoreLogic Commercial Real EstateServices, Inc. and National Tax Search, LLC.  These entities were engagedby the primary servicer of the Ceasar’s Bay Shopping Center Mortgage Loan, theEquinix Data Center Mortgage Loan and the NMR Pharmacy Portfolio Mortgage Loanto remit 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, thesevendors are “servicers” for the purposes of Item 1122 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 NEMA San Francisco Mortgage Loan, the 10000 Santa MonicaBoulevard Mortgage Loan, the Vanguard Portfolio Mortgage Loan, the MoffettTowers II – Buildings 3 & 4 Mortgage Loan, the Uline Arena Mortgage Loan,the Bison Portfolio Mortgage Loan, the Presidential City Mortgage Loan, theCeasar’s Bay Shopping Center Mortgage Loan, the Equinix Data Center MortgageLoan, the NMR Pharmacy Portfolio Mortgage Loan, the GNL Office and IndustrialPortfolio Mortgage Loan, the Inland Life Storage Portfolio Mortgage Loan andthe Ocean Edge Resort & Golf Club Mortgage Loan listed on the Exhibit Indexare omitted from this Annual Report on Form 10-K as the certificateadministrator pursuant to the related pooling and servicing agreement or trustand servicing agreement does not perform any activities that address servicingcriteria with respect to the issuing entity and because they are each not a“servicer” that meets the criteria in Item 1108(a)(2)(i) through (iii) ofRegulation AB.

With respect to the *pari passu*loan combinations that include the Presidential City Mortgage Loan, the NEMASan Francisco Mortgage Loan and the Moffett Towers II – Buildings 3 & 4Mortgage Loan, (i) the report on assessment of compliance with servicingcriteria and attestation report on assessment of compliance with servicingcriteria of AEGON USA Realty Advisors, LLC as special servicer of thePresidential City Mortgage Loan, listed on the Exhibit Index are omitted fromthis Annual Report on Form 10-K as they are not required to be included on thisAnnual Report on Form 10-K per Instruction 3 to Item 1122 of Regulation ABbecause it is a party performing activities that address servicing criteriarelating to 5% or less of the assets of the issuing entity; and (ii) theservicer compliance statements of AEGON USA Realty Advisors, LLC as specialservicer of the Presidential City Mortgage Loan and Situs Holdings, LLC asspecial servicer of the NEMA San Francisco Mortgage Loan and the Moffett TowersII – Buildings 3 & 4 Mortgage Loan, listed on the Exhibit Index are omittedfrom this Annual Report on Form 10-K as they are not required by Item 1123 ofRegulation AB to be included on this Annual Report on Form 10-K because they areeach an unaffiliated party that is not a “servicer” that meets the criteria inItem 1108(a)(2)(i) through (iii) of Regulation AB.

**PART I**

**Item 1.  Business.**

Omitted.

**Item 1A.  Risk Factors.**

Omitted.

**Item 1B.  Unresolved Staff Comments.**

None.

**Item 2.  Properties.**

Omitted.

**Item 3.  Legal Proceedings.**

Omitted.

**Item 4.  Mine Safety Disclosures.**

Not applicable.

**PART II**

**Item 5.  Market for Registrant’s Common Equity,Related Stockholder Matters and Issuer Purchases of Equity Securities.**

Omitted.

**Item 6.  Selected Financial Data.**

Omitted.

**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.

**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 Accounting Fees and Services.**

Omitted.

**ADDITIONAL DISCLOSURE ITEMS FOR REGULATION AB**

**Item 1112(b) of Regulation AB, Significant ObligorFinancial Information.**

No single obligor represents 10% or more of the pool assetsheld by the issuing entity. 

**Item 1114(b)(2) of Regulation AB, Significant EnhancementProvider Financial Information.**

No entity or group of affiliated entities provides any external creditenhancement or other support for the certificates within this transaction asdescribed under Item 1114(a) of Regulation AB.

**Item 1115(b) of Regulation AB, Certain DerivativesInstruments (Financial Information).**

No entity or group of affiliated entities provides anyderivative instruments or other support for the certificates within thistransaction as described under Item 1115 of Regulation AB.

**Item 1117 of Regulation AB, Legal Proceedings.**

The registrant knows of no material pending legal proceedinginvolving the trust or any party related to the trust, other than routinelitigation incidental to the duties of those respective parties, and thefollowing, with respect to Wells Fargo Bank, National Association, as trustee,as certificate administrator and as custodian, and Citibank, N.A., as trusteeand as custodian.

Beginning on June 18, 2014, a group of institutionalinvestors filed civil complaints in the Supreme Court of the State of New York,New York County, and later the U.S. District Court for the Southern District ofNew York, against Wells Fargo Bank, N.A., (“Wells Fargo Bank”) in itscapacity as trustee for certain residential mortgage backed securities (“RMBS”)trusts.  The complaints against Wells Fargo Bank alleged that the trusteecaused losses to investors and asserted causes of action based upon, amongother things, the trustee's alleged failure to: (i) notify and enforcerepurchase obligations of mortgage loan sellers for purported breaches ofrepresentations and warranties, (ii) notify investors of alleged events ofdefault, and (iii) abide by appropriate standards of care following allegedevents of default. Relief sought included money damages in an unspecifiedamount, reimbursement of expenses, and equitable relief. In November 2018,Wells Fargo Bank reached an agreement, in which it denied any wrongdoing, toresolve such claims on a classwide basis for the 271 RMBS trusts atissue.  On May 6, 2019, the court entered an order approving thesettlement agreement.  Separate lawsuits against Wells Fargo Bank makingsimilar allegations filed by certain other institutional investors concerningseveral RMBS trusts in New York federal and state court are not covered by theagreement.  With respect to such litigations, Wells Fargo Bank believesplaintiffs' claims are without merit and intends to contest the claimsvigorously, but there can be no assurances as to the outcome of the litigationsor the possible impact of the litigations on Wells Fargo Bank or the RMBStrusts.

In the ordinary course of business, Citibank, N.A. (“Citibank”)is involved in a number of legal proceedings, including in connection with itsrole as trustee of certain RMBS transactions.  Certain of these Citibankas trustee-related matters are disclosed herein. 

On June 18, 2014, a civil action was filed against Citibankin the Supreme Court of the State of New York by a group of investors in 48private-label RMBS trusts for which Citibank allegedly serves or did serve astrustee, asserting claims for purported violations of the Trust Indenture Actof 1939 (the “Trust Indenture Act”), breach of contract, breach offiduciary duty and negligence based on Citibank’s alleged failure to performits duties as trustee for the 48 RMBS trusts.  On November 24, 2014,plaintiffs sought leave to withdraw this action.  On the same day, a smallersubset of similar plaintiff investors in 27 private-label RMBS trusts for whichCitibank allegedly serves or did serve as trustee, filed a new civil actionagainst Citibank in the United States District Court for the Southern Districtof New York asserting similar claims as the prior action filed in statecourt.  In January 2015, the court closed plaintiffs’ original state courtaction.  On September 8, 2015, the federal court dismissed all claims asto 24 of the 27 trusts and allowed certain of the claims to proceed as to theother three trusts. Subsequently, plaintiffs voluntarily dismissed all claimswith respect to two of the three trusts. On April 7, 2017, Citibank filed amotion for summary judgment. Plaintiffs filed its consolidated opposition briefand cross motion for partial summary judgment on May 22, 2017.  Briefingon those motions was completed on August 4, 2017. On March 22, 2018, the courtgranted Citibank’s motion for summary judgment in its entirety, deniedPlaintiffs’ motion for summary judgment and ordered the clerk to close thecase. On April 20, 2018, plaintiffs filed a notice of appeal. Plaintiffs’opening brief was filed on August 3, 2018. Citibank filed its opposition onNovember 2, 2018.  Plaintiffs’ filed their reply on November 16,2018.  On June 7, 2019, the Second Circuit dismissed plaintiffs’ appealfollowing the parties’ filing of a stipulation withdrawing the case withprejudice pursuant to Federal Rule of Appellate Procedure 42.

On November 24, 2015, the same investors that brought thefederal case brought a new civil action in the Supreme Court of the State ofNew York related to 25 private-label RMBS trusts for which Citibank allegedlyserves or did serve as trustee.  This case includes the 24 trustspreviously dismissed in the federal action, and one additional trust.  Theinvestors assert claims for breach of contract, breach of fiduciary duty,breach of duty to avoid conflicts of interest, and violation of New York’sStreit Act (the “Streit Act”).  Following oral argument on Citibank’smotion to dismiss, Plaintiffs filed an amended complaint on August 5,2016.  On June 27, 2017, the state court issued a decision, dismissing theEvent of Default claims, mortgage-file-related claims, the fiduciary dutyclaims, and the conflict of interest claims.  The decision sustainedcertain breach of contract claims including the claim alleging discovery ofbreaches of representations and warranties, a claim related to robo-signing,and the implied covenant of good faith claim.  Citibank appealed the lowercourt’s decision, and on January 16, 2018, the Appellate Division, FirstDepartment, dismissed the claims related to robo-signing and the impliedcovenant of good faith, but allowed plaintiffs’ claim alleging discovery ofbreaches of representations and warranties to proceed.  On June 7, 2019,plaintiffs filed a motion for discontinuance of the action and dismissal ofplaintiffs’ claims with prejudice.

On August 19, 2015, the Federal Deposit Insurance Corporation(“FDIC”) as Receiver for a failed financial institution filed a civilaction against Citibank in the Southern District of New York.  This actionrelates to one private-label RMBS trust for which Citibank formerly served astrustee.  FDIC asserts claims for breach of contract, violation of theStreit Act, and violation of the Trust Indenture Act. Citibank jointly briefeda motion to dismiss with The Bank of New York Mellon and U.S. Bank, N.A.,entities that have also been sued by FDIC in their capacity as trustee, andthese cases have all been consolidated in front of Judge Carter.  OnSeptember 30, 2016, the Court granted the motion to dismiss without prejudicefor lack of subject matter jurisdiction.  On October 14, 2016, FDIC fileda motion for reargument or relief from judgment from the Court’s dismissalorder.  On July 11, 2017, Judge Carter ruled on the motion forreconsideration regarding his dismissal of the action.  He deniedreconsideration of his decision on standing, but granted leave to amend thecomplaint by October 9, 2017.  The FDIC subsequently requested anextension of time to file its amended complaint, which was granted. The FDICfiled its amended complaint on December 8, 2017. Defendants’ jointly filed amotion to dismiss the amended complaint and that joint motion was fully briefedas of May 3, 2018.  On March 20, 2019, the Court granted Defendants’ jointmotion to dismiss the amended complaint. The FDIC's deadline to file a noticeof appeal was April 22, 2019. The FDIC has not appealed. 

There can be no assurances as to the outcome of litigation orthe possible impact of litigation on the trustee or the RMBS trusts. However, Citibank denies liability and continues to vigorously defend againstthese litigations.  Furthermore, neither the above-disclosed litigationsnor any other pending legal proceeding involving Citibank will materiallyaffect Citibank’s ability to perform its duties under the related servicingagreement for this CMBS transaction.

**Item 1119 of Regulation AB, Affiliations and CertainRelationships and Related Transactions.**

The information regarding this Item has been previouslyprovided in the prospectus of the Registrant relating to the issuing entityfiled on November 26, 2019 pursuant to Rule 424(b)(2).

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

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

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the NEMA San Francisco Mortgage Loan,which is being serviced and administered pursuant to the trust and servicingagreement for the NCMS 2019-NEMA Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit K to the trust andservicing agreement for the NCMS 2019-NEMA 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 NCMS 2019-NEMATransaction responsible for each applicable servicing criteria set forth inItem 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the 10000 Santa Monica BoulevardMortgage Loan, which is being serviced and administered pursuant to the trustand servicing agreement for the NCMS 2019-10K Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit K to thetrust and servicing agreement for the NCMS 2019-10K 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 NCMS2019-10K 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 Vanguard Portfolio Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the BBCMS 2019-C3 Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit AA to the pooling andservicing agreement for the BBCMS 2019-C3 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 BBCMS 2019-C3Transaction responsible for each applicable servicing criteria set forth inItem 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Moffett Towers II – Buildings 3& 4 Mortgage Loan, which is being serviced and administered pursuant to thetrust and servicing agreement for the MFTII 2019-B3B4 Transaction, are attachedhereto under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit Lto the trust and servicing agreement for the MFTII 2019-B3B4 Transactionincorporated by reference as Exhibit 4.5 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theMFTII 2019-B3B4 Transaction responsible for each applicable servicing criteriaset forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Uline Arena Mortgage Loan, whichis being serviced and administered pursuant to the pooling and servicingagreement for the CD 2019-CD8 Transaction, are attached hereto under Item 15 tothis Annual Report on Form 10-K. Attached as Schedule II to the pooling andservicing agreement for the CD 2019-CD8 Transaction incorporated by referenceas Exhibit 4.6 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the CD 2019-CD8 Transactionresponsible for each applicable 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 Bison Portfolio Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the CSAIL 2019-C17 Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit AA to the pooling andservicing agreement for the CSAIL 2019-C17 Transaction incorporated byreference as Exhibit 4.7 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the CSAIL2019-C17 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 Presidential City Mortgage Loan,which is being serviced and administered pursuant to the trust and servicingagreement for the SGCMS 2019-PREZ Transaction, are attached hereto under Item15 to this Annual Report on Form 10-K. Attached as Exhibit L to the trust andservicing agreement for the SGCMS 2019-PREZ Transaction incorporated byreference as Exhibit 4.8 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the SGCMS2019-PREZ 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 GNL Office and IndustrialPortfolio Mortgage Loan, the Inland Life Storage Portfolio Mortgage Loan andthe Ocean Edge Resort & Golf Club Mortgage Loan, which are being servicedand administered pursuant to the pooling and servicing agreement for the CF2019-CF2 Transaction, are attached hereto under Item 15 to this Annual Reporton Form 10-K. Attached as Schedule II to the pooling and servicing agreementfor the CF 2019-CF2 Transaction incorporated by reference as Exhibit 4.9 tothis Annual Report on Form 10-K is a chart identifying the entitiesparticipating in a servicing function for the CF 2019-CF2 Transactionresponsible for each applicable 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 Ceasar’s Bay Shopping CenterMortgage Loan and the Equinix Data Center Mortgage Loan, which are beingserviced and administered pursuant to the pooling and servicing agreement forthe WFCM 2019-C53 Transaction, are attached hereto under Item 15 to this AnnualReport on Form 10-K. Attached as Exhibit AA to the pooling and servicingagreement for the WFCM 2019-C53 Transaction incorporated by reference asExhibit 4.10 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the WFCM 2019-C53Transaction responsible for each applicable servicing criteria set forth inItem 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the NMR Pharmacy Portfolio MortgageLoan, which is being serviced and administered pursuant to the pooling andservicing agreement for the WFCM 2019-C54 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit AA to thepooling and servicing agreement for the WFCM 2019-C54 Transaction incorporatedby reference as Exhibit 4.11 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the WFCM2019-C54 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The report on assessment of compliance with applicableservicing criteria furnished pursuant to Item 1122 of Regulation AB by MidlandLoan Services, a Division of PNC Bank National Association (“Midland”)discloses that a material instance of noncompliance occurred, as describedbelow:

Material Instance of Noncompliance

In certain instances, the ScheduleAL Files (Item 1125 of Regulation AB) were not reported in accordance with theterms specified in the transaction agreements, in conflict with Item1122(d)(3)(i): “Reports to investors, including those to be filed with theCommission, are maintained in accordance with the transaction agreements andapplicable Commission requirements. Specifically, such reports: (A) Areprepared in accordance with timeframes and other terms set forth in thetransaction agreements”.  The noncompliance consisted of omitted orinaccurately reported fields as described in (1) and (2) below.  (1) Inconnection with other enhancements Midland made to its manual Schedule ALprocess, starting in April 2019, Midland developed and implemented new ScheduleAL reporting templates for each applicable CMBS transaction that closed priorto April 2019 and for each applicable CMBS transaction going forward. Related to this, Midland made certain template setup errors, along with relatedand other manual inputting of information errors, and the errors were notidentified prior to submission of the applicable Schedule AL Files in certaincases due to breakdowns in quality control.  (2) In one applicabletransaction, the related Schedule AL File for a given month was not savedproperly resulting in the prior month's Schedule AL File being submitted forthe given month instead of the correct Schedule AL File. 

The identified instances did notinvolve the servicing of assets included in this securitization.

Steps Taken to Remedy the Material Instance of Noncompliance

Midland’s Schedule AL reportingprocess was enhanced in April of 2019, however, the process remained manualthroughout the 2019 calendar year.  Errors relating to certain Schedule ALFiles during 2019 were identified during the related audit.  Followingidentification, Midland made staffing changes and additional enhancements andimprovements to its processes and procedures to support its Schedule ALreporting obligations and expects to move to an automated solution for thisprocess.  

Midland is currently remediating theSchedule AL reporting for certain of the CMBS transactions found to be incorrect.

**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. Exhibits, Financial Statement Schedules**

(a) The following is a list of documents filed as part ofthis Annual Report on Form 10-K:

(1) Not applicable

(2) Not applicable

(3) See below

 

4.1          Poolingand Servicing Agreement, dated as of November 1, 2019, by and among BarclaysCommercial Mortgage Securities LLC, as Depositor, KeyBank National Association,as Master Servicer and as Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator and as Trustee, and PentalphaSurveillance LLC, as Operating Advisor and as Asset Representations Reviewer(filed as Exhibit 4.1 to the registrant’s Current Report on Form 8-K filed onNovember 26, 2019 under Commission File No. 333-226850-04 and incorporated byreference herein). 

4.2          Trustand Servicing Agreement, dated as of March 29, 2019, by and among Natixis CommercialMortgage Securities LLC, as Depositor, KeyBank National Association, asServicer, Situs Holdings, LLC, as Special Servicer, and Wells Fargo Bank,National Association, as Trustee, Certificate Administrator and Custodian(filed as Exhibit 4.5 to the registrant’s Current Report on Form 8-K filed onNovember 26, 2019 under Commission File No. 333-226850-04 and incorporated byreference herein).

4.3          Trustand Servicing Agreement, dated as of June 4, 2019, by and among NatixisCommercial Mortgage Securities LLC, as Depositor, KeyBank National Association,as Servicer, KeyBank National Association, as Special Servicer, and Wells FargoBank, National Association, as Trustee and Certificate Administrator (filed asExhibit 4.7 to the registrant’s Current Report on Form 8-K filed on November26, 2019 under Commission File No. 333-226850-04 and incorporated by referenceherein).

4.4          Poolingand Servicing Agreement, dated as of June 1, 2019, by and among BarclaysCommercial Mortgage Securities LLC, as Depositor, Midland Loan Services, aDivision of PNC Bank, National Association, as Master Servicer, Midland LoanServices, a Division of PNC Bank, National Association, as Special Servicer,Wells Fargo Bank, National Association, as Certificate Administrator, WellsFargo Bank, National Association, as Trustee, and Pentalpha Surveillance LLC,as Operating Advisor and as Asset Representations Reviewer (filed as Exhibit4.10 to the registrant’s Current Report on Form 8-K filed on November 26, 2019under Commission File No. 333-226850-04 and incorporated by reference herein).

4.5          Trustand Servicing Agreement, dated as of July 11, 2019, by and among BarclaysCommercial Mortgage Securities LLC, as Depositor, KeyBank National Association,as Servicer, Situs Holdings, LLC, as Special Servicer, and Wells Fargo Bank,National Association, as Certificate Administrator and Trustee (filed asExhibit 4.8 to the registrant’s Current Report on Form 8-K filed on November26, 2019 under Commission File No. 333-226850-04 and incorporated by referenceherein).

4.6          Poolingand Servicing Agreement, dated as of August 1, 2019, by and among DeutscheMortgage & Asset Receiving Corporation, as Depositor, Midland LoanServices, a Division of PNC Bank, National Association, as Master Servicer,Midland Loan Services, a Division of PNC Bank, National Association, as SpecialServicer, Wells Fargo Bank, National Association, as Trustee, Wells Fargo Bank,National Association, Certificate Administrator, Paying Agent and Custodian,and Park Bridge Lender Services LLC, as Operating Advisor and Asset RepresentationsReviewer (filed as Exhibit 4.6 to the registrant’s Current Report on Form 8-Kfiled on November 26, 2019 under Commission File No. 333-226850-04 andincorporated by reference herein).

4.7          Poolingand Servicing Agreement, dated as of September 1, 2019, by and among CreditSuisse Commercial Mortgage Securities Corp., as Depositor, Midland LoanServices, a Division of PNC Bank, National Association, as Master Servicer andas Special Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator and as Trustee, and Park Bridge Lender Services LLC, as OperatingAdvisor and Asset Representations Reviewer (filed as Exhibit 4.9 to theregistrant’s Current Report on Form 8-K filed on November 26, 2019 underCommission File No. 333-226850-04 and incorporated by reference herein).

4.8          Trustand Servicing Agreement, dated as of September 6, 2019, by and among SGCommercial Mortgage Securities, LLC, as Depositor, KeyBank NationalAssociation, as Servicer, AEGON USA Realty Advisors, LLC, as Special Servicer,Wells Fargo Bank, National Association, as Certificate Administrator, WellsFargo Bank, National Association, as Trustee (filed as Exhibit 4.3 to theregistrant’s Current Report on Form 8-K filed on November 26, 2019 underCommission File No. 333-226850-04 and incorporated by reference herein).

4.9          Poolingand Servicing Agreement, dated as of October 1, 2019, by and among CCRECommercial Mortgage Securities, L.P., as Depositor, KeyBank NationalAssociation, as Master Servicer, LNR Partners, LLC and KeyBank NationalAssociation, each as a Special Servicer, Citibank, N.A., as Trustee, Citibank,N.A., as Certificate Administrator, Paying Agent and Custodian, Park BridgeLender Services LLC, as Operating Advisor, and Park Bridge Lender Services LLC(filed as Exhibit 4.2 to the registrant’s Current Report on Form 8-K filed onNovember 26, 2019 under Commission File No. 333-226850-04 and incorporated byreference herein).

4.10        Poolingand Servicing Agreement, dated as of November 1, 2019, by and among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator, Wilmington Trust, National Association,as Trustee, and Park Bridge Lender Services LLC, as Operating Advisor and AssetRepresentations Reviewer (filed as Exhibit 4.4 to the registrant’s CurrentReport on Form 8-K filed on November 26, 2019 under Commission File No.333-226850-04 and incorporated by reference herein).

4.11        Poolingand Servicing Agreement, dated as of December 1, 2019, by and among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, LNR Partners, LLC, as Special Servicer, WellsFargo Bank, National Association, as Certificate Administrator, WilmingtonTrust, National Association, as Trustee, and Park Bridge Lender Services LLC,as Operating Advisor and as Asset Representations Reviewer (filed as Exhibit4.1 to the registrant’s Current Report on Form 8-K filed on December 4, 2019under Commission File No. 333-226850-04 and incorporated by reference herein).

4.12        AgreementBetween Noteholders, dated as of September 12, 2019, by and among KeyBankNational Association, as Initial Note A-1 Holder and KeyBank NationalAssociation, as Initial Note A-2, A-3, A-4, A-5, A-6, A-7 and A-8 Holder (filedas Exhibit 4.11 to the registrant’s Current Report on Form 8-K filed onNovember 26, 2019 under Commission File No. 333-226850-04 and incorporated byreference herein).

4.13        AgreementBetween Noteholders, dated as of September 6, 2019, by and between SocieteGenerale Financial Corporation, as Initial Note A-1A Holder, Societe GeneraleFinancial Corporation, as Initial Note A-1B Holder, Societe Generale FinancialCorporation, as Initial Note A-1C Holder, Societe Generale FinancialCorporation, as Initial Note A-1D Holder, Societe Generale FinancialCorporation, as Initial Note A-1E Holder, Societe Generale FinancialCorporation, as Initial Note A-1F Holder and Societe Generale FinancialCorporation, as Initial Note B Holder (filed as Exhibit 4.12 to theregistrant’s Current Report on Form 8-K filed on November 26, 2019 underCommission File No. 333-226850-04 and incorporated by reference herein).

4.14        AgreementBetween Note Holders, dated as of October 15, 2019, by and between BarclaysCapital Real Estate Inc., as Initial Note A-1 Holder and Barclays Capital RealEstate Inc., as Initial Note A-2 Holder (filed as Exhibit 4.13 to theregistrant’s Current Report on Form 8-K filed on November 26, 2019 underCommission File No. 333-226850-04 and incorporated by reference herein).

4.15        Co-LenderAgreement, dated as of March 27, 2019, by and among Natixis Real Estate CapitalLLC, as Note A-1 Holder, Natixis Real Estate Capital LLC, as Note A-2 Holder,Natixis Real Estate Capital LLC, as Note A-3 Holder, Natixis Real EstateCapital LLC, as Note A-4 Holder, Natixis Real Estate Capital LLC, as Note A-5Holder, Natixis Real Estate Capital LLC, as Note A-B Holder, Natixis RealEstate Capital LLC, as Note B-1 Holder and Natixis Real Estate Capital LLC, asNote B-2 Holder (filed as Exhibit 4.14 to the registrant’s Current Report on Form8-K filed on November 26, 2019 under Commission File No. 333-226850-04 andincorporated by reference herein).

4.16        Co-LenderAgreement, dated as of September 20, 2019, between Rialto Mortgage Finance,LLC, as Note A-1 Holder, Rialto Mortgage Finance, LLC, as Note A-2 Holder,Rialto Mortgage Finance, LLC, as Note A-3 Holder and Rialto Mortgage Finance,LLC, as Note A-4 Holder (filed as Exhibit 4.15 to the registrant’s CurrentReport on Form 8-K filed on November 26, 2019 under Commission File No.333-226850-04 and incorporated by reference herein).

4.17        AgreementBetween Note Holders, dated as of July 2, 2019, by and between KeyBank NationalAssociation, as Initial Note A-1-A Holder, Initial Note A-1-B Holder andInitial Note A-1-C Holder and Barclays Capital Real Estate Inc., as InitialNote A-2-A Holder and Initial Note A-2-B Holder (filed as Exhibit 4.16 to theregistrant’s Current Report on Form 8-K filed on November 26, 2019 underCommission File No. 333-226850-04 and incorporated by reference herein).

4.18        AgreementBetween Noteholders, dated as of July 29, 2019, by and among Cantor CommercialReal Estate Lending, L.P., as Initial Note A-1 Holder, Initial Note A-2 Holder,Initial Note A-3 Holder, Initial Note A-4 Holder and Initial Note A-5 Holderand Natixis Real Estate Capital LLC, as Initial Note A-6 Holder and InitialNote A-7 Holder (filed as Exhibit 4.17 to the registrant’s Current Report onForm 8-K filed on November 26, 2019 under Commission File No. 333-226850-04 andincorporated by reference herein).

4.19        Co-LenderAgreement, dated as of June 4, 2019, by and among Natixis Real Estate CapitalLLC, as Note A-1 Holder, Natixis Real Estate Capital LLC, as Note A-2 Holder,Natixis Real Estate Capital LLC, as Note A-3 Holder, Natixis Real EstateCapital LLC, as Note A-4 Holder, Natixis Real Estate Capital LLC, as Note A-5Holder, Natixis Real Estate Capital LLC, as Note A-6 Holder, Natixis RealEstate Capital LLC, as Note A-7 Holder and Natixis Real Estate Capital LLC, asNote A-B Holder (filed as Exhibit 4.18 to the registrant’s Current Report onForm 8-K filed on November 26, 2019 under Commission File No. 333-226850-04 andincorporated by reference herein).

4.20        AgreementBetween Noteholders, dated as of September 6, 2019, by and among KeyBankNational Association, as Initial Note A-1 Holder and KeyBank NationalAssociation, as Initial Note A-2 Holder (filed as Exhibit 4.19 to theregistrant’s Current Report on Form 8-K filed on November 26, 2019 underCommission File No. 333-226850-04 and incorporated by reference herein).

4.21        Co-LenderAgreement, dated as of July 11, 2019, by and among Barclays Bank PLC, as NoteA-1-A Holder and Note B-1 Holder, Barclays Capital Real Estate Inc., as InitialNote A-1-B Holder, Initial Note A-1-D Holder and Initial Note A-1-E Holder,Bank of America, N.A., as Note A-1-C Holder, Deutsche Bank AG, New York Branch,as Initial Note A-2-A Holder, Initial Note A-2-B Holder, Initial Note A-2-CHolder and Initial Note B-2 Holder and Goldman Sachs Bank USA, as Initial NoteA-3-A Holder, Initial Note A-3-B Holder, Initial Note A-3-C Holder and InitialNote B-3 Holder (filed as Exhibit 4.20 to the registrant’s Current Report onForm 8-K filed on November 26, 2019 under Commission File No. 333-226850-04 andincorporated by reference herein).

4.22        AgreementBetween Note Holders, dated as of September 25, 2019, by and among SocieteGenerale Financial Corporation, as Initial Note A-1 Holder and Societe GeneraleFinancial Corporation, as Initial Note A-2 Holder (filed as Exhibit 4.21 to theregistrant’s Current Report on Form 8-K filed on November 26, 2019 underCommission File No. 333-226850-04 and incorporated by reference herein).

4.23        Co-LenderAgreement, dated as of November 26, 2019, by and between BSPRT CMBS Finance,LLC, as Note A-1 Holder and BSPRT CMBS Finance, LLC, as Note A-2 Holder (filedas Exhibit 4.22 to the registrant’s Current Report on Form 8-K filed onNovember 26, 2019 under Commission File No. 333-226850-04 and incorporated byreference herein).

4.24        Amendedand Restated Co-Lender Agreement, dated as of June 11, 2019, by and amongNatixis Real Estate Capital LLC, as Note A-1 Holder, Natixis Real EstateCapital LLC, as Note A-2 Holder, Natixis Real Estate Capital LLC, as Note A-3Holder, Natixis Real Estate Capital LLC, as Note A-4 Holder, Natixis RealEstate Capital LLC, as Note A-5 Holder, Natixis Real Estate Capital LLC, asNote A-6 Holder and TCM CRE REIT LLC, as Note B Holder (filed as Exhibit 4.23to the registrant’s Current Report on Form 8-K filed on November 26, 2019 underCommission File No. 333-226850-04 and incorporated by reference herein).

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

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

33.1        KeyBank NationalAssociation, as Master Servicer

33.2        KeyBank NationalAssociation, as Special Servicer

33.3        Wells Fargo Bank, NationalAssociation, as Trustee and Certificate Administrator

33.4        Wells Fargo Bank, NationalAssociation, as Custodian

33.5        Pentalpha SurveillanceLLC, as Operating Advisor

33.6        KeyBank NationalAssociation, as Primary Servicer of the NEMA San Francisco Mortgage Loan (seeExhibit 33.2)

33.7        Situs Holdings, LLC, asSpecial Servicer of the NEMA San Francisco Mortgage Loan

33.8        Wells Fargo Bank, National Association, as Trustee of the NEMA San FranciscoMortgage Loan (Omitted. See Explanatory Notes.)

33.9        Wells Fargo Bank, NationalAssociation, as Custodian of the NEMA San Francisco Mortgage Loan (see Exhibit33.4)

33.10       KeyBank National Association, asPrimary Servicer of the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit33.2)

33.11       KeyBank National Association, asSpecial Servicer of the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit33.2)

33.12      Wells Fargo Bank, National Association, as Trustee of the 10000 Santa MonicaBoulevard Mortgage Loan (Omitted. See Explanatory Notes.)

33.13       Wells Fargo Bank, NationalAssociation, as Custodian of the 10000 Santa Monica Boulevard Mortgage Loan(see Exhibit 33.4)

33.14       Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the VanguardPortfolio Mortgage Loan

33.15       Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the VanguardPortfolio Mortgage Loan (see Exhibit 33.14)

33.16      Wells Fargo Bank, National Association, as Trustee of the Vanguard PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.17       Wells Fargo Bank, NationalAssociation, as Custodian of the Vanguard Portfolio Mortgage Loan (see Exhibit33.4)

33.18       Pentalpha Surveillance LLC, asOperating Advisor of the Vanguard Portfolio Mortgage Loan (see Exhibit 33.5)

33.19       KeyBank National Association, asPrimary Servicer of the Moffett Towers II – Buildings 3 & 4 Mortgage Loan(see Exhibit 33.2)

33.20       Situs Holdings, LLC, as SpecialServicer of the Moffett Towers II – Buildings 3 & 4 Mortgage Loan (seeExhibit 33.7)

33.21      Wells Fargo Bank, National Association, as Trustee of the Moffett Towers II – Buildings3 & 4 Mortgage Loan (Omitted. See Explanatory Notes.)

33.22       Wells Fargo Bank, NationalAssociation, as Custodian of the Moffett Towers II – Buildings 3 & 4Mortgage Loan (see Exhibit 33.4)

33.23       Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the UlineArena Mortgage Loan (see Exhibit 33.14)

33.24       Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the UlineArena Mortgage Loan (see Exhibit 33.14)

33.25      Wells Fargo Bank, National Association, as Trustee of the Uline Arena MortgageLoan (Omitted. See Explanatory Notes.)

33.26       Wells Fargo Bank, NationalAssociation, as Custodian of the Uline Arena Mortgage Loan (see Exhibit 33.4)

33.27       Park Bridge Lender ServicesLLC, as Operating Advisor of the Uline Arena Mortgage Loan

33.28       Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the BisonPortfolio Mortgage Loan (see Exhibit 33.14)

33.29       Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the BisonPortfolio Mortgage Loan (see Exhibit 33.14)

33.30      Wells Fargo Bank, National Association, as Trustee of the Bison PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.31       Wells Fargo Bank, NationalAssociation, as Custodian of the Bison Portfolio Mortgage Loan (see Exhibit33.4)

33.32       Park Bridge Lender Services LLC,as Operating Advisor of the Bison Portfolio Mortgage Loan (see Exhibit 33.27)

33.33       KeyBank National Association, asPrimary Servicer of the Presidential City Mortgage Loan (see Exhibit 33.2)

33.34      AEGON USA Realty Advisors, LLC, as Special Servicer of the Presidential CityMortgage Loan (Omitted. See Explanatory Notes.)

33.35      Wells Fargo Bank, National Association, as Trustee of the Presidential CityMortgage Loan (Omitted. See Explanatory Notes.)

33.36       Wells Fargo Bank, NationalAssociation, as Custodian of the Presidential City Mortgage Loan (see Exhibit33.4)

33.37       KeyBank National Association, asPrimary Servicer of the GNL Office and Industrial Portfolio Mortgage Loan (seeExhibit 33.2)

33.38       LNR Partners, LLC, as SpecialServicer of the GNL Office and Industrial Portfolio Mortgage Loan

33.39       Citibank, N.A., as Trustee andCustodian of the GNL Office and Industrial Portfolio Mortgage Loan

33.40       Park Bridge Lender ServicesLLC, as Operating Advisor of the GNL Office and Industrial Portfolio MortgageLoan (see Exhibit 33.27)

33.41       U.S. Bank National Association,as Servicing Function Participant of the GNL Office and Industrial PortfolioMortgage Loan

33.42       KeyBank National Association, asPrimary Servicer of the Inland Life Storage Portfolio Mortgage Loan (seeExhibit 33.2)

33.43       LNR Partners, LLC, as SpecialServicer of the Inland Life Storage Portfolio Mortgage Loan (see Exhibit 33.38)

33.44       Citibank, N.A., as Trustee andCustodian of the Inland Life Storage Portfolio Mortgage Loan (see Exhibit33.39)

33.45       Park Bridge Lender ServicesLLC, as Operating Advisor of the Inland Life Storage Portfolio Mortgage Loan(see Exhibit 33.27)

33.46       U.S. Bank National Association,as Servicing Function Participant of the Inland Life Storage Portfolio MortgageLoan (see Exhibit 33.41)

33.47       KeyBank National Association, asPrimary Servicer of the Ocean Edge Resort & Golf Club Mortgage Loan (seeExhibit 33.2)

33.48       LNR Partners, LLC, as SpecialServicer of the Ocean Edge Resort & Golf Club Mortgage Loan (see Exhibit33.38)

33.49       Citibank, N.A., as Trustee andCustodian of the Ocean Edge Resort & Golf Club Mortgage Loan (see Exhibit33.39)

33.50       Park Bridge Lender ServicesLLC, as Operating Advisor of the Ocean Edge Resort & Golf Club MortgageLoan (see Exhibit 33.27)

33.51       U.S. Bank National Association,as Servicing Function Participant of the Ocean Edge Resort & Golf ClubMortgage Loan (see Exhibit 33.41)

33.52       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Ceasar’s Bay Shopping Center MortgageLoan

33.53       Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the Ceasar’sBay Shopping Center Mortgage Loan (see Exhibit 33.14)

33.54       WilmingtonTrust, National Association, as Trustee of the Ceasar’s Bay Shopping CenterMortgage Loan (Omitted. See Explanatory Notes.)

33.55       Wells Fargo Bank, NationalAssociation, as Custodian of the Ceasar’s Bay Shopping Center Mortgage Loan(see Exhibit 33.4)

33.56       Park Bridge Lender ServicesLLC, as Operating Advisor of the Ceasar’s Bay Shopping Center Mortgage Loan(see Exhibit 33.27)

33.57       CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Ceasar’s BayShopping Center Mortgage Loan

33.58       National Tax Search, LLC, asServicing Function Participant of the Ceasar’s Bay Shopping Center MortgageLoan

33.59       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Equinix Data Center Mortgage Loan (seeExhibit 33.52)

33.60       Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the EquinixData Center Mortgage Loan (see Exhibit 33.14)

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

33.62       Wells Fargo Bank, NationalAssociation, as Custodian of the Equinix Data Center Mortgage Loan (see Exhibit33.4)

33.63       Park Bridge Lender ServicesLLC, as Operating Advisor of the Equinix Data Center Mortgage Loan (see Exhibit33.27)

33.64       CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Equinix DataCenter Mortgage Loan (see Exhibit 33.57)

33.65       National Tax Search, LLC, asServicing Function Participant of the Equinix Data Center Mortgage Loan (seeExhibit 33.58)

33.66       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the NMR Pharmacy Portfolio Mortgage Loan(see Exhibit 33.52)

33.67       LNR Partners, LLC, as SpecialServicer of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 33.38)

33.68      Wilmington Trust, National Association, as Trustee of the NMR PharmacyPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.69       Wells Fargo Bank, NationalAssociation, as Custodian of the NMR Pharmacy Portfolio Mortgage Loan (seeExhibit 33.4)

33.70       Park Bridge Lender ServicesLLC, as Operating Advisor of the NMR Pharmacy Portfolio Mortgage Loan (seeExhibit 33.27)

33.71       CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the NMR PharmacyPortfolio Mortgage Loan (see Exhibit 33.57)

33.72       National Tax Search, LLC, as ServicingFunction Participant of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit33.58)

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

34.1        KeyBank NationalAssociation, as Master Servicer

34.2        KeyBank NationalAssociation, as Special Servicer

34.3        Wells Fargo Bank, NationalAssociation, as Trustee and Certificate Administrator

34.4        Wells Fargo Bank, NationalAssociation, as Custodian

34.5        Pentalpha SurveillanceLLC, as Operating Advisor

34.6        KeyBank NationalAssociation, as Primary Servicer of the NEMA San Francisco Mortgage Loan (seeExhibit 34.2)

34.7        Situs Holdings, LLC, asSpecial Servicer of the NEMA San Francisco Mortgage Loan

34.8        Wells Fargo Bank, National Association, as Trustee of the NEMA San FranciscoMortgage Loan (Omitted. See Explanatory Notes.)

34.9        Wells Fargo Bank, NationalAssociation, as Custodian of the NEMA San Francisco Mortgage Loan (see Exhibit34.4)

34.10       KeyBank National Association, asPrimary Servicer of the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit34.2)

34.11       KeyBank National Association, asSpecial Servicer of the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit34.2)

34.12      Wells Fargo Bank, National Association, as Trustee of the 10000 Santa MonicaBoulevard Mortgage Loan (Omitted. See Explanatory Notes.)

34.13       Wells Fargo Bank, NationalAssociation, as Custodian of the 10000 Santa Monica Boulevard Mortgage Loan(see Exhibit 34.4)

34.14       Midland Loan Services, a Divisionof PNC Bank, National Association, as Primary Servicer of the VanguardPortfolio Mortgage Loan

34.15       Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the VanguardPortfolio Mortgage Loan (see Exhibit 34.14)

34.16      Wells Fargo Bank, National Association, as Trustee of the Vanguard PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.17       Wells Fargo Bank, National Association,as Custodian of the Vanguard Portfolio Mortgage Loan (see Exhibit 34.4)

34.18       Pentalpha Surveillance LLC, asOperating Advisor of the Vanguard Portfolio Mortgage Loan (see Exhibit 34.5)

34.19       KeyBank National Association, asPrimary Servicer of the Moffett Towers II – Buildings 3 & 4 Mortgage Loan(see Exhibit 34.2)

34.20       Situs Holdings, LLC, as Special Servicerof the Moffett Towers II – Buildings 3 & 4 Mortgage Loan (see Exhibit 34.7)

34.21      Wells Fargo Bank, National Association, as Trustee of the Moffett Towers II –Buildings 3 & 4 Mortgage Loan (Omitted. See Explanatory Notes.)

34.22       Wells Fargo Bank, NationalAssociation, as Custodian of the Moffett Towers II – Buildings 3 & 4Mortgage Loan (see Exhibit 34.4)

34.23       Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the UlineArena Mortgage Loan (see Exhibit 34.14)

34.24       Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the UlineArena Mortgage Loan (see Exhibit 34.14)

34.25      Wells Fargo Bank, National Association, as Trustee of the Uline Arena MortgageLoan (Omitted. See Explanatory Notes.)

34.26       Wells Fargo Bank, NationalAssociation, as Custodian of the Uline Arena Mortgage Loan (see Exhibit 34.4)

34.27       Park Bridge Lender ServicesLLC, as Operating Advisor of the Uline Arena Mortgage Loan

34.28       Midland Loan Services, a Divisionof PNC Bank, National Association, as Primary Servicer of the Bison PortfolioMortgage Loan (see Exhibit 34.14)

34.29       Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the BisonPortfolio Mortgage Loan (see Exhibit 34.14)

34.30      Wells Fargo Bank, National Association, as Trustee of the Bison PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.31       Wells Fargo Bank, NationalAssociation, as Custodian of the Bison Portfolio Mortgage Loan (see Exhibit34.4)

34.32       Park Bridge Lender ServicesLLC, as Operating Advisor of the Bison Portfolio Mortgage Loan (see Exhibit34.27)

34.33       KeyBank National Association, asPrimary Servicer of the Presidential City Mortgage Loan (see Exhibit 34.2)

34.34      AEGON USA Realty Advisors, LLC, as Special Servicer of the Presidential CityMortgage Loan (Omitted. See Explanatory Notes.)

34.35      Wells Fargo Bank, National Association, as Trustee of the Presidential CityMortgage Loan (Omitted. See Explanatory Notes.)

34.36       Wells Fargo Bank, NationalAssociation, as Custodian of the Presidential City Mortgage Loan (see Exhibit34.4)

34.37       KeyBank National Association, asPrimary Servicer of the GNL Office and Industrial Portfolio Mortgage Loan (seeExhibit 34.2)

34.38       LNR Partners, LLC, as SpecialServicer of the GNL Office and Industrial Portfolio Mortgage Loan

34.39       Citibank, N.A., as Trustee andCustodian of the GNL Office and Industrial Portfolio Mortgage Loan

34.40       Park Bridge Lender ServicesLLC, as Operating Advisor of the GNL Office and Industrial Portfolio MortgageLoan (see Exhibit 34.27)

34.41       U.S. Bank National Association,as Servicing Function Participant of the GNL Office and Industrial PortfolioMortgage Loan

34.42       KeyBank National Association, asPrimary Servicer of the Inland Life Storage Portfolio Mortgage Loan (seeExhibit 34.2)

34.43       LNR Partners, LLC, as SpecialServicer of the Inland Life Storage Portfolio Mortgage Loan (see Exhibit 34.38)

34.44       Citibank, N.A., as Trustee andCustodian of the Inland Life Storage Portfolio Mortgage Loan (see Exhibit34.39)

34.45       Park Bridge Lender ServicesLLC, as Operating Advisor of the Inland Life Storage Portfolio Mortgage Loan(see Exhibit 34.27)

34.46       U.S. Bank National Association,as Servicing Function Participant of the Inland Life Storage Portfolio MortgageLoan (see Exhibit 34.41)

34.47       KeyBank National Association, asPrimary Servicer of the Ocean Edge Resort & Golf Club Mortgage Loan (seeExhibit 34.2)

34.48       LNR Partners, LLC, as SpecialServicer of the Ocean Edge Resort & Golf Club Mortgage Loan (see Exhibit34.38)

34.49       Citibank, N.A., as Trustee andCustodian of the Ocean Edge Resort & Golf Club Mortgage Loan (see Exhibit34.39)

34.50       Park Bridge Lender ServicesLLC, as Operating Advisor of the Ocean Edge Resort & Golf Club MortgageLoan (see Exhibit 34.27)

34.51       U.S. Bank National Association,as Servicing Function Participant of the Ocean Edge Resort & Golf ClubMortgage Loan (see Exhibit 34.41)

34.52       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Ceasar’s Bay Shopping Center MortgageLoan

34.53       Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the Ceasar’sBay Shopping Center Mortgage Loan (see Exhibit 34.14)

34.54      Wilmington Trust, National Association, as Trustee of the Ceasar’s Bay ShoppingCenter Mortgage Loan (Omitted. See Explanatory Notes.)

34.55       Wells Fargo Bank, NationalAssociation, as Custodian of the Ceasar’s Bay Shopping Center Mortgage Loan(see Exhibit 34.4)

34.56       Park Bridge Lender ServicesLLC, as Operating Advisor of the Ceasar’s Bay Shopping Center Mortgage Loan(see Exhibit 34.27)

34.57       CoreLogic Commercial Real EstateServices, Inc., as Servicing Function Participant of the Ceasar’s Bay ShoppingCenter Mortgage Loan

34.58       National Tax Search, LLC, asServicing Function Participant of the Ceasar’s Bay Shopping Center MortgageLoan

34.59       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Equinix Data Center Mortgage Loan (seeExhibit 34.52)

34.60       Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the EquinixData Center Mortgage Loan (see Exhibit 34.14)

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

34.62       Wells Fargo Bank, NationalAssociation, as Custodian of the Equinix Data Center Mortgage Loan (see Exhibit34.4)

34.63       Park Bridge Lender ServicesLLC, as Operating Advisor of the Equinix Data Center Mortgage Loan (see Exhibit34.27)

34.64       CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Equinix DataCenter Mortgage Loan (see Exhibit 34.57)

34.65       National Tax Search, LLC, asServicing Function Participant of the Equinix Data Center Mortgage Loan (seeExhibit 34.58)

34.66       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the NMR Pharmacy Portfolio Mortgage Loan(see Exhibit 34.52)

34.67       LNR Partners, LLC, as SpecialServicer of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 34.38)

34.68      Wilmington Trust, National Association, as Trustee of the NMR PharmacyPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.69       Wells Fargo Bank, NationalAssociation, as Custodian of the NMR Pharmacy Portfolio Mortgage Loan (seeExhibit 34.4)

34.70       Park Bridge Lender ServicesLLC, as Operating Advisor of the NMR Pharmacy Portfolio Mortgage Loan (seeExhibit 34.27)

34.71       CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the NMR PharmacyPortfolio Mortgage Loan (see Exhibit 34.57)

34.72       National Tax Search, LLC, asServicing Function Participant of the NMR Pharmacy Portfolio Mortgage Loan (seeExhibit 34.58)

35           Servicer compliance statements.

35.1        KeyBank NationalAssociation, as Master Servicer

35.2        KeyBank NationalAssociation, as Special Servicer (see Exhibit 35.1)

35.3        Wells Fargo Bank, NationalAssociation, as Certificate Administrator

35.4        KeyBank National Association,as Primary Servicer of the NEMA San Francisco Mortgage Loan (see Exhibit 35.1)

35.5        Situs Holdings, LLC, as Special Servicer of the NEMA San Francisco MortgageLoan (Omitted. See Explanatory Notes.)

35.6        KeyBank NationalAssociation, as Primary Servicer of the 10000 Santa Monica Boulevard MortgageLoan (see Exhibit 35.1)

35.7        KeyBank NationalAssociation, as Special Servicer of the 10000 Santa Monica Boulevard MortgageLoan (see Exhibit 35.1)

35.8        Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the VanguardPortfolio Mortgage Loan

35.9        Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the VanguardPortfolio Mortgage Loan (see Exhibit 35.8)

35.10       KeyBank National Association, asPrimary Servicer of the Moffett Towers II – Buildings 3 & 4 Mortgage Loan(see Exhibit 35.1)

35.11      Situs Holdings, LLC, as Special Servicer of the Moffett Towers II – Buildings 3& 4 Mortgage Loan (Omitted. See Explanatory Notes.)

35.12       Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the UlineArena Mortgage Loan (see Exhibit 35.8)

35.13       Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the UlineArena Mortgage Loan (see Exhibit 35.8)

35.14       Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the BisonPortfolio Mortgage Loan (see Exhibit 35.8)

35.15       Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the BisonPortfolio Mortgage Loan (see Exhibit 35.8)

35.16       KeyBank National Association, asPrimary Servicer of the Presidential City Mortgage Loan (see Exhibit 35.1)

35.17      AEGON USA Realty Advisors, LLC, as Special Servicer of the Presidential CityMortgage Loan (Omitted. See Explanatory Notes.)

35.18       KeyBank National Association, asPrimary Servicer of the GNL Office and Industrial Portfolio Mortgage Loan (seeExhibit 35.1)

35.19       LNR Partners, LLC, as SpecialServicer of the GNL Office and Industrial Portfolio Mortgage Loan

35.20       KeyBank National Association, asPrimary Servicer of the Inland Life Storage Portfolio Mortgage Loan (seeExhibit 35.1)

35.21       LNR Partners, LLC, as SpecialServicer of the Inland Life Storage Portfolio Mortgage Loan (see Exhibit 35.19)

35.22       KeyBank National Association, asPrimary Servicer of the Ocean Edge Resort & Golf Club Mortgage Loan (seeExhibit 35.1)

35.23       LNR Partners, LLC, as SpecialServicer of the Ocean Edge Resort & Golf Club Mortgage Loan (see Exhibit35.19)

35.24       Wells Fargo Bank, National Association,as Primary Servicer of the Ceasar’s Bay Shopping Center Mortgage Loan

35.25       Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the Ceasar’sBay Shopping Center Mortgage Loan (see Exhibit 35.8)

35.26       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Equinix Data Center Mortgage Loan (seeExhibit 35.24)

35.27       Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the EquinixData Center Mortgage Loan (see Exhibit 35.8)

35.28       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the NMR Pharmacy Portfolio Mortgage Loan(see Exhibit 35.24)

35.29       LNR Partners, LLC, as SpecialServicer of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 35.19)

 

99.1        MortgageLoan Purchase Agreement, dated as of November 5, 2019, among Barclays CapitalReal Estate Inc., Barclays Capital Holdings Inc. and Barclays CommercialMortgage Securities LLC (filed as Exhibit 99.1 to the registrant’s CurrentReport on Form 8-K filed on November 26, 2019 under Commission File No.333-226850-04 and incorporated by reference herein).

99.2        MortgageLoan Purchase Agreement, dated as of November 5, 2019, between KeyBank NationalAssociation and Barclays Commercial Mortgage Securities LLC (filed as Exhibit99.2 to the registrant’s Current Report on Form 8-K filed on November 26, 2019under Commission File No. 333-226850-04 and incorporated by reference herein).

99.3        MortgageLoan Purchase Agreement, dated as of November 5, 2019, between Natixis RealEstate Capital LLC and Barclays Commercial Mortgage Securities LLC (filed asExhibit 99.3 to the registrant’s Current Report on Form 8-K filed on November26, 2019 under Commission File No. 333-226850-04 and incorporated by referenceherein).

99.4        MortgageLoan Purchase Agreement, dated as of November 5, 2019, among Societe GeneraleFinancial Corporation, Société Générale and Barclays Commercial MortgageSecurities LLC (filed as Exhibit 99.4 to the registrant’s Current Report onForm 8-K filed on November 26, 2019 under Commission File No. 333-226850-04 andincorporated by reference herein).

99.5        MortgageLoan Purchase Agreement, dated as of November 5, 2019, between Rialto MortgageFinance, LLC and Barclays Commercial Mortgage Securities LLC (filed as Exhibit99.5 to the registrant’s Current Report on Form 8-K filed on November 26, 2019under Commission File No. 333-226850-04 and incorporated by reference herein).

99.6        MortgageLoan Purchase Agreement, dated as of November 5, 2019, among BSPRT CMBSFinance, LLC, Benefit Street Partners Realty Trust, Inc. and BarclaysCommercial Mortgage Securities LLC (filed as Exhibit 99.6 to the registrant’sCurrent Report on Form 8-K filed on November 26, 2019 under Commission File No.333-226850-04 and incorporated by reference herein).

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

(c)    Not Applicable.

 

**SIGNATURES**

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

Barclays Commercial MortgageSecurities LLC(Depositor)

/s/ DanielVinson

DanielVinson, Chief Executive Officer

(senior officer in charge ofsecuritization of the depositor)

Date: March 19, 2020