Management's Assertion

 

Report on Assessment of Compliance with ApplicableServicing Criteria

 

Management of U.S. BankNational Association and U.S. Bank Trust Company, National Association(collectively “U.S. Bank”) is responsible for assessing compliance as of andfor the year ended December 31, 2023 with the servicing criteria set forth inItem 1122 (d) of Regulation AB applicable to it as set forth on Exhibit Ahereto. This report covers asset backed securities transactions within the **U.S.Bank Corporate Trust Asset-Backed Securities Platform1 (the“Platform”)**

 

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

 

1.      U.S.Bank is responsible for assessing its compliance with the servicing criteriaapplicable to it as noted on the accompanying Exhibit A;

 

2.      Exceptas set forth in paragraph 3 below, U.S. Bank used the criteria set forth inparagraph (d) of Item 1122 of Regulation AB to assess its compliance with theapplicable servicing criteria;

 

3.      Thecriteria listed in the column titled “Inapplicable Servicing Criteria” onExhibit A hereto are inapplicable to U.S. Bank based on the servicingactivities it performs directly with respect to the Platform;

 

4.      U.S.Bank has complied, in all material respects, with the applicable servicingcriteria as of and for the year ended December 31, 2023; and

 

5.      Ernst& Young, LLP, a registered public accounting firm, has issued anattestation report on U.S. Bank’s assessment of compliance with the applicableservicing criteria as of and for the year ended December 31, 2023.

 

 

1 The U.S. Bank Corporate Trust Asset-Backed SecuritiesPlatform (the "Platform") consists of the activities involved in theperformance of servicing functions for which the Company provides trustee,securities administration, registrar, paying agent and document custodyservices for (i) publicly issued asset-backed and mortgage-backed transactionsthe securities of which were offered on or after January 1, 2006 and (ii)certain asset-backed transactions for which the Issuer has voluntarily electedto make Regulation AB compliant filings under the Securities Exchange Act of1934, as amended.

 

 

U.S. BANK NATIONAL ASSOCIATION

/s/ Jeff Kerr

Name: Jeff Kerr

Title: Executive VicePresident

 

U.S. BANK TRUST COMPANY,NATIONAL ASSOCIATION

/s/ Jeff Kerr

Name: Jeff Kerr

Title: Executive VicePresident

 

Dated: February 27, 2024

** **

** **

**EXHIBIT A to Management’s Assertion**

| **Reference**                                               | **Servicing****Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | **Applicable Servicing Criteria** | **Inapplicable  Servicing Criteria** |
|-------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------|--------------------------------------|
| **General********Servicing********Considerations**          |
| 1122(d)(1)(i)                                               | Policies and procedures are instituted to monitor any  performance or other triggers and events of default in accordance with the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | **X**                             |                                 |
| 1122(d)(1)(ii)                                              | If any material servicing activities are outsourced  to third parties, policies and proceduresareinstitutedtomonitorthethirdparty’sperformanceandcompliance with such servicing  activities.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | ** **

**X****2**            |                                 |
| 1122(d)(1)(iii)                                             | Anyrequirementsinthetransactionagreementstomaintainaback-upservicerfor the Pool Assets are maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |                              | **X**                                |
| 1122(d)(1)(iv)                                              | A fidelity bond and errors and omissions policy is in  effect on the party participatingintheservicingfunctionthroughoutthereportingperiodintheamount of coverage required by and  otherwise in accordance with the terms of the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                        | **X**                             |                                 |
| ** **

1122(d)(1)(v)                                   |  

Aggregationofinformation,asapplicable,ismathematicallyaccurateandthe information  conveyed accurately reflects the information.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | ** **

**X****3**            |                                 |
| **Cash********Collection********and****Administration**     |
| 1122(d)(2)(i)                                               | Paymentsonpoolassetsaredepositedintotheappropriate custodialbankaccounts and related bank clearing accounts no more than two business  days following receipt, or such other number of days specified in the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                           | **X**                             |                                 |
| 1122(d)(2)(ii)                                              | Disbursementsmadeviawiretransferonbehalfofanobligorortoaninvestorare made only by authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | **X**                             |                                 |
| 1122(d)(2)(iii)                                             | Advancesoffundsorguaranteesregardingcollections,cashflowsordistributions, and any  interest or other fees charged for such advances, are made, reviewed and  approved as specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | ** **

**X****4**            |                                 |
| 1122(d)(2)(iv)                                              | The related accounts forthe transaction, such as cash reserve accounts or accounts  establishedasaformofovercollateralization,areseparatelymaintained(e.g.,with  respect to commingling of cash) as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                    | **X**                             |                                 |
| ** **

1122(d)(2)(v)                                   | ** **

Each custodial account is maintained at a federally insured depository  institution as set forth in the transaction agreements. For purposes of this  criterion, “federally insureddepositoryinstitution”withrespecttoaforeignfinancialinstitutionmeansa foreign financial institution that meets the requirements of Rule  13k-1(b)(1) of the Securities Exchange Act.                                                                                                                                                                                                                                                                                                 | ** **

**X**                 |                                 |
| 1122(d)(2)(vi)                                              | Unissuedchecksaresafeguardedsoastopreventunauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | **X**                             |                                 |
| 1122(d)(2)(vii)                                             | Reconciliations are prepared on a monthly basis for  all asset-backed securities related bank accounts, including custodial  accounts and related bank clearing accounts. These reconciliations are (A)  mathematically accurate; (B) prepared within 30 calendar days after the bank  statement cutoff date, or such other number of days specified in the  transaction agreements; (C) reviewed and approved by someone other than the  person who prepared the reconciliation; and (D) contain explanations for  reconciling items. These reconciling items are resolved within 90 calendardaysoftheiroriginalidentification,orsuchothernumberofdaysspecified in the transaction agreements. | **X**                             |                                 |
| **Investor********Remittances********and********Reporting** |
| 1122(d)(3)(i)                                               | Reports to investors, including those to be filed  with the Commission, are maintained in accordance with the transaction  agreements and applicable Commissionrequirements.Specifically,suchreports(A)arepreparedinaccordance  withtimeframesandothertermssetforthinthetransactionagreements;(B)provide information calculated in  accordance with the terms specified in the transaction agreements; (C) are  filed with the Commission as required by its rules and regulations;and(D)agreewithinvestors’orthetrustee’srecordsastothetotal unpaid principal balance and  number of Pool Assets serviced by the Servicer.                                                         | **X**                             |                                 |
| 1122(d)(3)(ii)                                              | Amountsduetoinvestorsareallocatedandremittedinaccordancewithtimeframes, distribution priority and other terms set forth in the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | **X**                             |                                 |
| 1122(d)(3)(iii)                                             | Disbursementsmadetoaninvestorarepostedwithintwobusinessdaystothe Servicer’s investor  records, or such other number of days specified in the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     | **X**                             |                                 |
|  

1122(d)(3)(iv)                                      | Amountsremittedtoinvestorspertheinvestorreportsagreewithcancelledchecks, or other form of payment, or custodial bank  statements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |  

**X**                     |                                 |
| **Pool********Asset****Administration**                     |
| 1122(d)(4)(i)                                               | Collateralorsecurityonpoolassetsismaintainedasrequiredbythetransaction agreements or related pool  asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | **X**                             |                                 |
| 1122(d)(4)(ii)                                              | Poolassetsandrelateddocumentsaresafeguardedasrequiredbythetransaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | **X**                             |                                 |
| 1122(d)(4)(iii)                                             | Anyadditions,removalsorsubstitutionstotheassetpoolaremade,reviewedand approved in  accordance with any conditions or requirements in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | **X**                             |                                 |
|  

1122(d)(4)(iv)                                      |  

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

**X**                        |
|  

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

**X**                        |
| 1122(d)(4)(vi)                                              | Changeswithrespecttothetermsorstatusof anobligor'spoolassets(e.g.,loan modifications or  re-agings) are made, reviewed and approved by authorized personnel in  accordance with the transaction agreements and related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                    |                              | **X**                                |
| 1122(d)(4)(vii)                                             | Lossmitigationorrecoveryactions(e.g.,forbearanceplans,modificationsand deeds in  lieu of foreclosure, foreclosures and repossessions, as applicable) are  initiated,conductedandconcludedinaccordancewiththetimeframesorother  requirements established by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                          |                              | **X**                                |
| 1122(d)(4)(viii)                                            | Records documenting collection efforts are maintained  during the period a pool assetisdelinquentinaccordancewiththetransactionagreements.Suchrecordsare maintained on at least a monthly  basis, or such other period specified in the transactionagreements,anddescribetheentity’sactivitiesinmonitoringdelinquent pool assets including, for  example, phone calls, letters and payment rescheduling plans in cases where  delinquency is deemed temporary (e.g., illness or unemployment).                                                                                                                                                                                            |                              | **X**                                |
| 1122(d)(4)(ix)                                              | Adjustmentstointerestratesorratesofreturnforpoolassetswithvariableratesare computed based on the related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |                              | **X**                                |
| 1122(d)(4)(x)                                               | Regardinganyfundsheldintrustforanobligor(suchasescrowaccounts):(A)such funds are analyzed, in accordance  with the obligor’s pool asset documents, on at least an annual basis, or such  other period specified in the transaction agreements; (B) interest on such  funds is paid, or credited, to obligors in accordance with applicablepoolassetdocumentsandstatelaws;and(C)suchfundsarereturnedto theobligorwithin 30 calendardaysoffullrepaymentoftherelated poolassets,or such  other number of days specified in the transaction agreements.                                                                                                                                       |                              | **X**                                |
| 1122(d)(4)(xi)                                              | Payments made on behalf of an obligor (such as tax or  insurance payments) are made on or before the related penalty or expiration  dates, as indicated on the appropriatebillsornoticesforsuchpayments,provided that suchsupporthas been receivedbytheserviceratleast30calendardayspriortothesedates,orsuchother number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                       |                              | **X**                                |
|  

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

**X**                        |
| 1122(d)(4)(xiii)                                            | Disbursementsmadeonbehalfofanobligorarepostedwithintwobusinessdaysto the obligor’s records maintained by the servicer, or such other  number of days specifiedinthetransaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                              | **X**                                |
| 1122(d)(4)(xiv)                                             | Delinquencies,charge-offsanduncollectibleaccountsarerecognizedandrecorded  in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |                              | **X**                                |
| 1122(d)(4)(xv)                                              | Anyexternalenhancementorothersupport,identified inItem1114(a)(1)through (3)orItem1115ofRegulationAB,ismaintainedassetforthinthetransaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | **X**                             |                                 |

 

2 No servicing activities were performed by the Companythat required the servicing criteria to be complied with.

3 No servicing activities were performed by the Company thatrequired the servicing criteria to be complied with.

4 No servicing activities were performed by the Companythat required the servicing criteria to be complied with.

 

 

Corporate Trust ABS Platform(B)