**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, 2021or**

**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: 333-226123-05**

**Central Index Key Number of the issuing entity:0001790013**

**Benchmark 2019-B14 Mortgage Trust**

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

** **

**Central Index Key Number of the depositor: 0001013611**

**J.P. Morgan Chase CommercialMortgage Securities Corp.**

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

** **

**Central Index Key Number of the sponsor: 0000835271**

**JPMorgan Chase Bank, NationalAssociation**

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

** **

**Central Index Key Number of the sponsor: 0001701238**

**Citi Real Estate Funding Inc.**

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

** **

**Central Index Key Number of the sponsor: 0001541294**

**German American Capital Corporation**

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

** **

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

**the issuing entity)** | **38-4129034**

**38-4129035**

**38-4129036**

**38-7235623**

**(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) 834-5467**

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 large acceleratedfiler, 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 if asmaller reporting company)                          Smaller reporting company                    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 complying withany new or revised financial accounting standards provided pursuant to Section13(a) of the Exchange Act.  o

Indicate by check mark whether the registrant has filed areport on and attestation to its management’s assessment of the effectivenessof its internal control over financial reporting under Section 404(b) of theSarbanes-Oxley Act (15 U.S.C. 7262(b)) by the registered public accounting firmthat prepared or issued its audit report. o

Indicate by check mark whether the registrant is a shell company(as defined in Rule 12b-2 of the Act).  oYes ⌧ No

State the aggregate market value of the voting and non-votingcommon equity held by non-affiliates computed by reference to the price atwhich the common equity was last sold, or the average bid and asked price ofsuch common equity, as of the last business day of the registrant’s mostrecently completed second fiscal quarter.

Not applicable.

Indicate by check mark whether the registrant has filed alldocuments and reports required to be filed by Section 12, 13 or 15(d) of theSecurities Exchange Act of 1934 subsequent to the distribution of securitiesunder a plan confirmed by a court.  oYes oNo

Not applicable.

Indicate the number of shares outstanding of each of theregistrant’s classes of common stock, as of the latest practicable date.

Not applicable.

**DOCUMENTS INCORPORATED BY REFERENCE**

** **

List hereunder the following documents if incorporated byreference and the Part of the Form 10-K (e.g., Part I, Part II, etc.) intowhich the document is incorporated: (1) Any annual report to security holders;(2) Any proxy or information statement; and (3) Any prospectus filed pursuantto Rule 424(b) or (c) under the Securities Act of 1933. The listed documentsshould be clearly described for identification purposes (e.g., annual report tosecurity holders for fiscal year ended December 24, 1980).

Not applicable.

 

** **

**EXPLANATORY NOTES**

The 225 Bush Mortgage Loan, The Essex MortgageLoan, the Harvey Building Products Mortgage Loan, the Legends at Village WestMortgage Loan, the Hilton Cincinnati Netherland Plaza Mortgage Loan and the 8West Centre Mortgage Loan, which constituted approximately 4.5%, 4.3%, 3.8%,3.8%, 2.7% and 2.0%, respectively, of the asset pool of the issuing entity asof its cut-off date, are each an asset of the issuing entity and are each partof a loan combination that includes (a) with respect to the 225 Bush MortgageLoan, four other *pari passu* loans, which are not assets of the issuingentity, (b) with respect to The Essex Mortgage Loan, two other *pari passu*loans and two subordinate companion loans, each of which are not assets of theissuing entity, (c) with respect to the Harvey Building Products Mortgage Loan,two other *pari passu* loans, which are not assets of the issuing entity,(d) with respect to the Legends at Village West Mortgage Loan, two other *paripassu* loans, which are not assets of the issuing entity, (e) with respectto the Hilton Cincinnati Netherland Plaza Mortgage Loan, two other *paripassu* loans, which are not assets of the issuing entity and (f) withrespect to the 8 West Centre Mortgage Loan, one other *pari passu* loan,which is not an asset of the issuing entity. These loan combinations, includingthe 225 Bush Mortgage Loan, The Essex Mortgage Loan, the Harvey Building ProductsMortgage Loan, the Legends at Village West Mortgage Loan, the Hilton CincinnatiNetherland Plaza Mortgage Loan and the 8 West Centre Mortgage Loan, are beingserviced and administered pursuant to the Pooling and Servicing Agreement,which is incorporated by reference as Exhibit 4.1 to this Annual Report on Form10-K. 

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Osborn Triangle Mortgage Loan, whichconstituted approximately 3.0% of the asset pool of the issuing entity as ofits cut-off date.  The Osborn Triangle Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the OsbornTriangle Mortgage Loan, 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 J.P. Morgan ChaseCommercial Mortgage Securities Trust 2019-OSB transaction (the “JPMCC2019-OSB Transaction”). This loan combination, including the OsbornTriangle Mortgage Loan, is being serviced and administered pursuant to thetrust and servicing agreement for the JPMCC 2019-OSB 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 Grand Canal Shoppes Mortgage Loan, whichconstituted approximately 2.3% of the asset pool of the issuing entity as ofits cut-off date.  The Grand Canal Shoppes Mortgage Loan is an asset ofthe issuing entity and is part of a loan combination that includes the GrandCanal Shoppes Mortgage Loan, twenty-three other *pari passu* loans and onesubordinate companion loan, which are not assets of the issuing entity. A *paripassu* portion of the loan combination was securitized in the Morgan StanleyCapital I Trust 2019-H7 transaction, Commission File Number 333-227446-05 (the“MSC 2019-H7 Transaction”). This loan combination, including the GrandCanal Shoppes Mortgage Loan, is being serviced and administered pursuant to thepooling and servicing agreement for the MSC 2019-H7 Transaction, which isincorporated by reference as Exhibit 4.3 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 600 & 620 National Avenue Mortgage Loan,which constituted approximately 1.5% of the asset pool of the issuing entity asof its cut-off date.  The 600 & 620 National Avenue Mortgage Loan isan asset of the issuing entity and is part of a loan combination that includesthe 600 & 620 National Avenue Mortgage Loan and six other *pari passu*loans, which are not assets of the issuing entity. A *pari passu* portionof the loan combination was securitized in the UBS Commercial Mortgage Trust2019-C17 transaction, Commission File Number 333-227784-04 (the “UBS2019-C17 Transaction”). This loan combination, including the 600 & 620National Avenue Mortgage Loan, is being serviced and administered pursuant tothe pooling and servicing agreement for the UBS 2019-C17 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 900 & 990 Stewart Avenue Mortgage Loan,the City Hyde Park Mortgage Loan and the Sunset North Mortgage Loan, whichconstituted approximately 2.9%, 1.5% and 1.5%, respectively, of the asset poolof the issuing entity as of its cut-off date.  The 900 & 990 StewartAvenue Mortgage Loan, the City Hyde Park Mortgage Loan and the Sunset NorthMortgage Loan are each an asset of the issuing entity and are each part of aloan combination that includes (a) with respect to the 900 & 990 StewartAvenue Mortgage Loan, one other *pari passu* loan, which is not an assetof the issuing entity, (b) with respect to the City Hyde Park Mortgage Loan, threeother *pari passu* loans, which are not assets of the issuing entity or(c) with respect to the Sunset North Mortgage Loan, three other *pari passu*loans, which are not assets of the issuing entity. The other *pari passu*portion of each loan combination was securitized in the Benchmark 2019-B13Mortgage Trust transaction, Commission File Number 333-226943-04 (the “Benchmark2019-B13 Transaction”). These loan combinations, including the 900 &990 Stewart Avenue Mortgage Loan, the City Hyde Park Mortgage Loan and theSunset North Mortgage Loan, are being serviced and administered pursuant to thepooling and servicing agreement for the Benchmark 2019-B13 Transaction, whichis incorporated by reference as Exhibit 4.5 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 Tysons Tower Mortgage Loan and the 230 ParkAvenue South Mortgage Loan, which constituted approximately 3.0% and 2.3%,respectively, of the asset pool of the issuing entity as of its cut-offdate.  The Tysons Tower Mortgage Loan and the 230 Park Avenue SouthMortgage Loan are each an asset of the issuing entity and are each part of aloan combination that includes (a) with respect to the Tysons Tower MortgageLoan, five other *pari passu* loans, which are not assets of the issuingentity or (b) with respect to the 230 Park Avenue South Mortgage Loan, sixother *pari passu* loans, which are not assets of the issuing entity. A *paripassu* portion of each loan combination was securitized in the BANK2019-BNK21 transaction, Commission File Number 333-228375-02 (the “BANK2019-BNK21 Transaction”). These loan combinations, including the TysonsTower Mortgage Loan and the 230 Park Avenue South Mortgage Loan, are beingserviced and administered pursuant to the pooling and servicing agreement forthe BANK 2019-BNK21 Transaction, which is incorporated by reference as Exhibit4.6 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 180 Water Mortgage Loan, which constitutedapproximately 3.8% of the asset pool of the issuing entity as of its cut-offdate.  The 180 Water Mortgage Loan is an asset of the issuing entity andis part of a loan combination that includes the 180 Water Mortgage Loan, fourother *pari passu* loans and one subordinate companion loan, which are notassets of the issuing entity.  This loan combination, including the 180Water Mortgage Loan, was serviced under the Pooling and Servicing Agreement forthe issuing entity prior to the closing of the securitization of a *paripassu* portion of the 180 Water loan combination in the COMM 2019-GC44Mortgage Trust transaction, Commission File Number 333-226943-05 (the “COMM2019-GC44 Transaction”).  After the closing of the COMM 2019-GC44Transaction on December 12, 2019, this loan combination, including the 180Water Mortgage Loan was, and will continue to be, serviced and administeredpursuant to the pooling and servicing agreement with respect to the COMM2019-GC44 Transaction, which is incorporated by reference as Exhibit 4.7 tothis 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 Innovation Park Mortgage Loan, whichconstituted approximately 4.5% of the asset pool of the issuing entity as ofits cut-off date.  The Innovation Park Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the InnovationPark Mortgage Loan and two other *pari passu* loans, which are not assetsof the issuing entity.  This loan combination, including the InnovationPark Mortgage Loan, was serviced under the Pooling and Servicing Agreement forthe issuing entity prior to the closing of the securitization of a *paripassu* portion of the Innovation Park loan combination in the Benchmark2019-B15 Mortgage Trust transaction, Commission File Number 333-228597-04 (the“Benchmark 2019-B15 Transaction”).  After the closing of theBenchmark 2019-B15 Transaction on December 18, 2019, this loan combination,including the Innovation Park Mortgage Loan was, and will continue to be,serviced and administered pursuant to the pooling and servicing agreement withrespect to the Benchmark 2019-B15 Transaction, which is incorporated byreference as Exhibit 4.8 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.

Midland Loan Services, a Divisionof PNC Bank, National Association is the master servicer and special servicerof the mortgage loans serviced under the Pooling and Servicing Agreement, theprimary servicer of the 180 Water Mortgage Loan, the 900 & 990 StewartAvenue Mortgage Loan, the Grand Canal Shoppes Mortgage Loan, the City Hyde ParkMortgage Loan, the Innovation Park Mortgage Loan and the Sunset North MortgageLoan and the special servicer of the Innovation Park Mortgage Loan prior toJuly 19, 2021. As a result, Midland Loan Services, a Division of PNC Bank,National Association is a “servicer” as defined in Item 1108(a)(2)(iii) ofRegulation 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 Midland Loan Services, a Division of PNC Bank, NationalAssociation in the capacities 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 the TysonsTower Mortgage Loan, the 230 Park Avenue South Mortgage Loan and the 600 &620 National Avenue Mortgage Loan. As a result, Wells Fargo Bank, NationalAssociation 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 Wells Fargo Bank, National Association in the capacities described above arelisted in the Exhibit Index.

Wells Fargo Bank, National Association is the custodian ofthe mortgage loans serviced under the Pooling and Servicing Agreement, the 180Water Mortgage Loan, the Tysons Tower Mortgage Loan, the Osborn TriangleMortgage Loan, the 900 & 990 Stewart Avenue Mortgage Loan, the 230 ParkAvenue South Mortgage Loan, the Grand Canal Shoppes Mortgage Loan, the CityHyde Park Mortgage Loan, the Sunset North Mortgage Loan and the 600 & 620National Avenue 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, the GrandCanal Shoppes Mortgage Loan and the 600 & 620 National Avenue MortgageLoan.  As a result, Pentalpha Surveillance LLC is a servicing functionparticipant in the capacities described above, because it is servicing mortgageloans that constituted 5% or more of the assets of the issuing entity as of itscut-off date. The assessments of compliance with applicable servicing criteriaand accountants’ attestation reports delivered by Pentalpha Surveillance LLC inthe capacities described above are listed in the Exhibit Index.

Park Bridge Lender Services LLC is the operating advisor ofthe Innovation Park Mortgage Loan, the 180 Water Mortgage Loan, the TysonsTower Mortgage Loan, the Osborn Triangle Mortgage Loan, the 900 & 990Stewart Avenue Mortgage Loan, the 230 Park Avenue South Mortgage Loan, the CityHyde Park Mortgage Loan and the Sunset North Mortgage Loan.  As a result,Park Bridge 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.

Rialto Capital Advisors, LLC isthe special servicer of the Tysons Tower Mortgage Loan, the 230 Park AvenueSouth Mortgage Loan and the 600 & 620 National Avenue Mortgage Loan. These mortgage loans constitute more than 5%, but less than 10%, of the poolassets of the issuing entity.  Therefore, the Depositor included in thisAnnual Report on Form 10-K an assessment of compliance with applicableservicing criteria for Rialto Capital Advisors, LLC and an accountants’attestation report pursuant to Item 1122 of Regulation AB because RialtoCapital Advisors, 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 ofRialto Capital Advisors, LLC because Rialto Capital Advisors, LLC is anunaffiliated servicer servicing less than 10% of pool assets.

SitusHoldings, LLC is the special servicer of the Grand Canal Shoppes Mortgage Loanand the Osborn Triangle Mortgage Loan.  These mortgage loansconstitute more than 5%, but less than 10%, of the pool assets of the issuingentity.  Therefore, the Depositor included in this Annual Report on Form10-K an assessment of compliance with applicable servicing criteria for Situs Holdings, LLC and anaccountants’ attestationreport pursuant to Item 1122 of Regulation AB because Rialto Capital Advisors,LLC is servicing more than 5% of the pool assets.  However, the Depositoris not required to include in this Annual Report on Form 10-K a servicer compliancestatement pursuant to Item 1123 of Regulation AB of SitusHoldings, LLC because Situs Holdings, LLCis an unaffiliated servicer servicing less than 10% of pool assets.

CWCapitalAsset Management LLC is the special servicer of the 180 Water Mortgage Loan,the Sunset North Mortgage Loan, the City Hyde Park Mortgage Loan and the 900& 990 Stewart Avenue Mortgage Loan.  These mortgage loans constitutemore than 5%, but less than 10%, of the pool assets of the issuingentity.  Therefore, the Depositor included in this Annual Report on Form10-K an assessment of compliance with applicable servicing criteria forCWCapital Asset Management LLC and an accountants’ attestation report pursuantto Item 1122 of Regulation AB because CWCapital Asset Management LLC isservicing more than 5% of the pool assets.  However, the Depositor is notrequired to include in this Annual Report on Form 10-K a servicer compliancestatement pursuant to Item 1123 of Regulation AB of CWCapital Asset ManagementLLC because CWCapital Asset Management LLC is an unaffiliated servicerservicing less than 10% of pool assets.

Wells Fargo Bank, NationalAssociation acts as trustee of the 225 Bush Mortgage Loan, The Essex MortgageLoan, the Harvey Building Products Mortgage Loan, the Legends at Village WestMortgage Loan, the Hilton Cincinnati Netherland Plaza Mortgage Loan, the 8 WestCentre Mortgage Loan, the Osborn Triangle Mortgage Loan, the Grand CanalShoppes Mortgage Loan, the 900 & 990 Stewart Avenue Mortgage Loan, theSunset North Mortgage Loan, the City Hyde Park Mortgage Loan and the 180 WaterMortgage Loan.  Pursuant to the Pooling and Servicing Agreement, the trustand servicing agreement for the JPMCC 2019-OSB Transaction, the pooling andservicing agreement for the MSC 2019-H7 Transaction, the pooling and servicingagreement for the Benchmark 2019-B13 Transaction and the pooling and servicingagreement for the COMM 2019-GC44 Transaction, the trustee is required toprovide an assessment of compliance with applicable servicing criteria solelywith respect to Item 1122(d)(2)(iii) of Regulation AB (regarding advances offunds or guarantees regarding collections, cash flows or distributions, and anyinterest or other fees charged for such advances, are made, reviewed andapproved as specified in the transaction agreements). However, during thereporting period, the trustee did not perform any servicing function withrespect to the servicing criteria specified in Item 1122(d)(2)(iii) ofRegulation AB.  The master servicer or the special servicer, to the extentrequired, performed the servicing function identified with respect to Item1122(d)(2)(iii) of Regulation AB, and each such party included Item1122(d)(2)(iii) of Regulation AB in the assessment of compliance withapplicable servicing criteria and accountant’s attestation report for thesubject transaction.  As a result, this Annual Report on Form 10-K doesnot include an assessment of compliance with applicable servicing criteria ofthe trustee. One or more other servicers of the 225 Bush Mortgage Loan, TheEssex Mortgage Loan, the Harvey Building Products Mortgage Loan, the Legends atVillage West Mortgage Loan, the Hilton Cincinnati Netherland Plaza MortgageLoan, the 8 West Centre Mortgage Loan, the Osborn Triangle Mortgage Loan, theGrand Canal Shoppes Mortgage Loan, the 900 & 990 Stewart Avenue MortgageLoan, the Sunset North Mortgage Loan, the City Hyde Park Mortgage Loan and the180 Water Mortgage Loan have delivered one or more assessments of compliancewith respect to Item 1122(d)(2)(iii) of Regulation AB.

Wilmington Trust, NationalAssociation acts as trustee of the 600 & 620 National Avenue Mortgage Loan,the Tysons Tower Mortgage Loan, the 230 Park Avenue South Mortgage Loan and theInnovation Park Mortgage Loan.  Pursuant to the pooling and servicingagreement for the UBS 2019-C17 Transaction, the pooling and servicing agreementfor the BANK 2019-BNK21 Transaction and the pooling and servicing agreement forthe Benchmark 2019-B15 Transaction, the trustee is required to provide anassessment of compliance with applicable servicing criteria solely with respectto Item 1122(d)(2)(iii) of Regulation AB (regarding advances of funds orguarantees regarding collections, cash flows or distributions, and any interestor other fees charged for such advances, are made, reviewed and approved asspecified in the transaction agreements). However, during the reporting period,the trustee did not perform any servicing function with respect to theservicing criteria specified in Item 1122(d)(2)(iii) of Regulation AB. The master servicer or the special servicer, to the extent required, performedthe servicing function identified with respect to Item 1122(d)(2)(iii) ofRegulation AB, and each such party included Item 1122(d)(2)(iii) of RegulationAB in the assessment of compliance with applicable servicing criteria andaccountant’s attestation report for the subject transaction.  As a result,this Annual Report on Form 10-K does not include an assessment of compliancewith applicable servicing criteria of the trustee. One or more other servicersof the 600 & 620 National Avenue Mortgage Loan, the Tysons Tower MortgageLoan, the 230 Park Avenue South Mortgage Loan and the Innovation Park MortgageLoan have delivered one or more assessments of compliance with respect to Item1122(d)(2)(iii) of Regulation AB.

This Annual Report on Form 10-Kincludes assessments of compliance with applicable servicing criteria andaccountants’ attestation reports from CoreLogic Solutions, LLC.  Thisentity was engaged by the primary servicer of the 600 & 620 National AvenueMortgage Loan, the Tysons Tower Mortgage Loan and the 230 Park Avenue SouthMortgage Loan to remit tax payments received from the escrow accounts ofborrowers to local taxing authorities, to report tax amounts due, to verify taxparcel information, and to verify non-escrow tax payments. These servicingfunctions are included within the servicing criteria set forth in Items1122(d)(4)(xi) and 1122(d)(4)(xii) of Regulation AB.  Therefore, under theprinciples-based definition of “servicer” set forth in Item 1101(j) ofRegulation AB that looks to the functions that an entity performs, this vendoris a “servicer” for the purposes of Item 1122 of Regulation AB.  *See*Compliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

This Annual Report on Form 10-Kincludes an assessment of compliance with applicable servicing criteria,accountants’ attestation report and servicer compliance statement fromComputershare Trust Company, National Association (“CTCNA”).  CTCNAwas engaged by Wells Fargo Bank, National Association (“Wells Fargo”),in its capacity as certificate administrator and custodian, to perform certainspecified servicing functions identified in the assessment of compliance withapplicable servicing criteria and accountants’ attestation reports.  WellsFargo engaged CTCNA in connection with the sale of Wells Fargo’s corporatetrust services business to CTCNA and its affiliates.  Further, under theprinciples-based definition of “servicer” set forth in Item 1101(j) ofRegulation AB that looks to the functions that an entity performs, this partyis a “servicer” for the purposes of Item 1123 of Regulation AB.  SeeCompliance 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 Osborn Triangle Mortgage Loan, the Grand Canal ShoppesMortgage Loan, the 600 & 620 National Avenue Mortgage Loan, the 900 &990 Stewart Avenue Mortgage Loan, the Sunset North Mortgage Loan, the City HydePark Mortgage Loan, the Tysons Tower Mortgage Loan, the 230 Park Avenue SouthMortgage Loan, the 180 Water Mortgage Loan and the Innovation Park MortgageLoan are 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.

Withrespect to the *pari passu* loan combinations that include theOsborn Triangle Mortgage Loan, the Tysons Tower Mortgage Loan, the 230Park Avenue South Mortgage Loan, the 600 & 620 National Avenue MortgageLoan, the 900 & 990 Stewart Avenue Mortgage Loan,the Grand Canal Shoppes Mortgage Loan, the City Hyde Park Mortgage Loan, theSunset North Mortgage Loan, the 180 Water Mortgage Loan and the Innovation Park Mortgage Loan,(i) thereports on assessment of compliance with servicing criteria and attestationreports on assessment of compliance with servicing criteria of KeyBank NationalAssociation as primary servicer of the Osborn Triangle Mortgage Loan, LNRPartners, LLC as special servicer of the Innovation Park Mortgage Loan on andafter July 19, 2021 and Citibank, N.A. as custodian of the Innovation ParkMortgage Loan, listed on the Exhibit Index are omitted from this Annual Reporton Form 10-K as they are not required to be included on this Annual Report onForm 10-K per Instruction 3 to Item 1122 of Regulation AB because they areparties performing activities that address servicing criteria relating to 5% orless of the assets of the issuing entity; and (ii) the servicer compliancestatements of KeyBank National Association as primary servicer of the OsbornTriangle Mortgage Loan, LNR Partners, LLC as special servicer of the InnovationPark Mortgage Loan on and after July 19, 2021, Situs Holdings, LLC as specialservicer of the Osborn Triangle Mortgage Loan and the Grand Canal ShoppesMortgage Loan, Rialto Capital Advisors, LLC as special servicer of the TysonsTower Mortgage Loan, the 230 Park Avenue South Mortgage Loan and the 600 &620 National Avenue Mortgage Loan and CWCapital Asset Management LLC as specialservicer of the 900 & 990 Stewart Avenue Mortgage Loan, the Sunset NorthMortgage Loan, the City Hyde Park Mortgage Loan and the 180 Water MortgageLoan, listed on the Exhibit Index are omitted from this Annual Report on Form10-K as they are not required by Item 1123 of Regulation AB to be included onthis Annual Report on Form 10-K because they are each an unaffiliated partythat is not a “servicer” that meets the criteria in Item 1108(a)(2)(i) through(iii) of Regulation AB.

**PART I**

**Item 1.  Business.**

Omitted.

**Item 1A.  Risk Factors.**

Omitted.

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

None.

**Item 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 externalcreditenhancement or other support for the certificates within this transaction as describedunder 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 CWCapital Asset Management LLC, as Special Servicer,and Wells Fargo Bank, National Association, as Trustee, CertificateAdministrator and Custodian.

From time to time, CWCapital Asset Management LLC, a Delawarelimited liability company (“CWCAM”), is a party to lawsuits and otherlegal proceedings as part of its duties as a special servicer (e.g.,enforcement of loan obligations) and/or arising in the ordinary course ofbusiness.  Other than as set forth in the following paragraphs, there arecurrently no legal proceedings pending, and no legal proceedings known to becontemplated by governmental authorities, against CWCAM or of which any of itsproperty is the subject, that are material to the certificateholders.

On December 17, 2015, U.S. Bank National Association, thetrustee under five pooling and servicing agreements for (i) Wachovia BankCommercial Mortgage Trust 2007-C30, (ii) COBALT CMBS Commercial Trust 2007-C2,(iii) Wachovia Bank Commercial Mortgage Trust 2007-C31, (iv) ML-CFC CommercialMortgage Trust 2007-5 and (v) ML-CFC Commercial Mortgage Trust 2007-6 commenceda proceeding with the Second Judicial District Court of Ramsey County,Minnesota (the “State Court”) for a declaratory judgment as to theproper allocation of certain proceeds (“Disputed Proceeds”) received byCWCAM in connection with the sale of the Peter Cooper Village and StuyvesantTown property in New York, New York securing loans held by those trusts. CWCAM was the special servicer of such property.  The petition requeststhe State Court to instruct the trustee, the trust beneficiaries, and any otherinterested parties as to the amount of the Disputed Proceeds, if any, thatconstitute penalty interest and/or the amount of the Disputed Proceeds, if any,that constitute gain-on-sale proceeds, with respect to each trust.  OnFebruary 24, 2016, CWCAM made a limited appearance with the State Court to filea motion to dismiss this proceeding based on lack of jurisdiction, mootness,standing and forum non conveniens.  On July 19, 2016, the State Courtdenied CWCAM’s motion to dismiss.  On July 22, 2016, the action wasremoved to federal court in Minnesota (“Federal Court”).  OnOctober 21, 2016, the Federal Court held a hearing on the motion to transferthe action to the United States District Court for the Southern District of NewYork (“SDNY Court”), a motion to remand to state court and a motion tohear CWCAM’s request for reconsideration of the motion to dismiss.  OnMarch 14, 2017, the Federal Court reserved the determination on the motion tohear CWCAM’s request for reconsideration of the motion to dismiss, denied themotion to remand the matter to state court and granted the motion to transferthe proceeding to the SDNY Court.  Cross motions for judgment on thepleadings were filed but the SDNY Court was unable to decide the case based onthe pleadings and the SDNY Court ordered discovery.  All fact discoverywas completed in December, 2018 and expert discovery was completed on March 15,2019.  The parties submitted cross motions for summary judgment, and onMarch 19, 2020, theSDNY Court entered an opinion andorder in which it granted summary judgment in CWCAM’s favor and held that CWCAMwas entitled to the entire amount of penalty interest and that CWCAM’sdetermination of Yield Maintenance was correct.  In the 127-page opinion,the SDNY Court found for CWCAM on every issue presented by the trustee’spetition, namely, that the funds in dispute constitute penalty interest andyield maintenance, not gain-on-sale proceeds, and that the amount of penaltyinterest and yield maintenance was correctly calculated. An appeal of the SDNYCourt’s decision was taken on April 29, 2020.  Oral argument on the appealoccurred on June 21, 2021. The parties await the decision of the appealscourt.  

On December 1, 2017, a complaint against CWCAM and others wasfiled in the United States District Court for the Southern District of New Yorkstyled as CWCapital Cobalt Vr Ltd. v. CWCapital Investments LLC, et al., No.17-cv-9463 (the “Original Complaint”). The gravamen of theOriginal  Complaint alleged breaches of a contract and fiduciary duties byCWCAM’s affiliate, CWCapital Investments LLC in its capacity as collateralmanager for the collateralized debt obligation transaction involving CWCapitalCobalt Vr, Ltd. In total, there are 14 counts pled in the Original Complaint.Of those 14, 5 claims were asserted against CWCAM for aiding and abetting breachof fiduciary duty, conversion and unjust enrichment. On May 23, 2018, theOriginal Complaint was dismissed for lack of subject matterjurisdiction.   On June 28, 2018, CWCapital Cobalt Vr Ltd. filed asubstantially similar complaint in the Supreme Court of the State of New York,County of New York styled as CWCapital Cobalt Vr Ltd. v. CWCapital InvestmentsLLC, et al., Index No. 653277/2018 (the “New Complaint”).  Thegravamen of the New Complaint is the same as the previous complaint filed inthe United State District Court for the Southern District of New York.  Intotal there are 16 counts pled in the New Complaint. Of those 16 counts, 5claims were asserted against CWCAM for aiding and abetting breach of fiduciaryduty, conversion and unjust enrichment, 1 count seeks a declaratory judgementthat the plaintiff has the right to enforce the contracts in question and 1count seeks an injunction requiring the defendants to recognize the plaintiffas the directing holder for the trusts in question. On January 11, 2019, theplaintiff dismissed with prejudice the declaratory judgment and injunctioncounts.  The New Complaint and related summons was not served on thedefendants until July 13, 2018 and July 16, 2018.  The plaintiff’s motionfor a preliminary injunction was denied by the court on July 31, 2018.  OnAugust 3, 2018, the defendants, including CWCAM, filed a motion to dismiss theNew Complaint in its entirety. On August 20, 2019, the court entered an ordergranting defendants’ motion almost in its entirety, dismissing 11 of the 16counts and partially dismissing 2 additional counts.  Of the remainingcounts, 2 are asserted against CWCAM for aiding and abetting breach offiduciary duty and unjust enrichment.  On September 19, 2019, CWCapitalCobalt Vr Ltd. filed a notice of appeal relating to the August 20, 2019dismissal order and on September 26, 2019, filed an amended complaint againstCWCI and CWCAM attempting to address deficiencies relating to certain of theclaims dismissed by the August, 20, 2019 order.  CWCI and CWCAM filed itsMotion to Dismiss the amended complaint on October 28, 2019.  The courtheard argument on the Motion to Dismiss the amended complaint on January 22,2020 and on October 23, 2020, the court granted the motion dismissing the amendedclaims.  On November 30, 2020, CWCapital Cobalt Vr Ltd filed a notice ofappeal relating to the October 23, 2020 dismissal order.  On April 27,2021, the First Department affirmed the dismissal as to claims against CWCAMthat were part of the August 20, 2019 dismissal, but reversed the dismissal oftwo counts for breach of the Collateral Management Agreement againstCWCI.  CWCI has sought leave to file an appeal of the decision.  Bothrequests for leave were denied by the First Department.  The plaintiff hasalso sought leave to appeal the dismissal of the claims against CWCAM. CWCAM believes that it has performed its obligations under the related poolingand servicing agreements in good faith and the remaining allegations in the NewComplaint are without merit.  

On January 24, 2016 PSW NYC LLC commenced a complaint (the“PSW Complaint”) with the Supreme Court of the State of New York, County of NewYork (the “PSW Court”) against Bank of America, N.A. as trustee under thepooling and servicing agreements for Wachovia Bank Commercial Mortgage Trust2007-C30 and COBALT CMBS Commercial Trust 2007-C2, U.S. Bank NationalAssociation as trustee under the pooling and servicing agreements for WachoviaBank Commercial Mortgage Trust 2007-C31, ML-CFC Commercial Mortgage Trust2007-5 and ML-CFC Commercial Mortgage Trust 2007-6 (collectively, the “PSWTrusts”), PCV-M Holdings LLC and CWCapital Asset Management LLC, individuallyand as special servicer for the PSW Trusts (collectively, the “Defendants”)seeking either (a) damages in an amount to be determined by the PSW Court butalleged by the plaintiffs to be approximately $500,000,000 – such amount beingthe amount PSW NYC LLC alleges would have been recovered on certain mezzanineloans (the “PCVST Mezzanine Loans”) related to the Peter Cooper Village andStuyvesant Town property (the “PCVST Property”) in New York City which PSW NYCLLC sold to an entity related to the Defendants pursuant to a settlementagreement related to certain prior litigation (the “2010 Settlement Agreement”)or (b) the rescission of the 2010 Settlement Agreement which would result in,among other things, the rescission of the sale of the PCVST Mezzanine Loans anda claim for certain proceeds from the sale of the PCVST Property. PSW NYC LLC allegesthat the Defendants procured the 2010 Settlement Agreement by fraud and furtherthat the terms of the 2010 Settlement Agreement were breached by theDefendants. On February 26, 2016, CWCAM

on behalf of itself and the otherDefendants filed a motion to dismiss the PSW Complaint (the “CWCAM Motion toDismiss”). On April 11, 2016, PSW NYC LLC opposed the CWCAM Motion to Dismissand cross-moved for a partial summary judgment on liability regardingallegations of breach of the 2010 Settlement Agreement (the “PSWCross-Motion”). On May 5, 2016, the Defendants subsequently filed its reply andopposition to the PSW Cross-Motion. On August 23, 2016, oral arguments wereprovided to the PSW Court regarding the PSW Complaint, the CWCAM Motion toDismiss and the PSW Cross-Motion and the PSW Court took such arguments underadvisement. On October 31, 2016, the PSW Court issued an order granting theCWCAM Motion to Dismiss, denying the PSW Cross-Motion and dismissing the PSWComplaint with prejudice. Subsequently, PSW NYC LLC filed a notice of appealrelating to such order. On February 21, 2017, PSW NYC LLC filed its appeal andsupporting brief arguing that the PSW Court erred by finding no breach of theassignment agreement and no fraudulent inducement. Oral argument was heard onMay 4, 2017 at which point the court took the arguments under advisement. OnMay 25, 2017, the New York 1st Department appellate court affirmedthe dismissal of all PSW claims and denied a request for leave to appeal to theNew York Court of Appeals on September 12, 2017.  

On March 31, 2016, RAIT Preferred Funding II LTD. (“RAITPreferred Funding”) commenced a complaint (“RAIT Complaint”) withthe Supreme Court of the State of New York, County of New York (the “RAITCourt”), claiming it owns $18,500,000 of a mortgage loan secured by thedevelopment of the One Congress Street Property in Boston, Massachusetts (the “Loan”)and seeking (a) a declaratory judgment stating that RAIT Preferred Funding isthe directing lender under a co-lender agreement dated March 28, 2007 and apooling and servicing agreement dated March 1, 2007 (collectively, the “OperativeAgreements”) and was the directing lender at the time of the impropermodification of the Loan, (b) a declaratory judgment stating that RAIT PreferredFunding has the right to terminate the special servicer, (c) monetary damagesfor the value of the bonds and fees paid to CWCAM as the special servicer ofthe Loan and (d) other things.  On May 17, 2016, CWCAM filed a motion todismiss the RAIT Complaint (“Motion to Dismiss”) stating that the RAITComplaint did not state a claim and the essential facts of the RAIT Complaintare negated by affidavits and evidentiary materials submitted with the RAITComplaint.  On June 14, 2016, RAIT Preferred Funding filed a Memorandum ofLaw in Opposition to the Motion to Dismiss (“Opposition”) stating thatthe claims in the RAIT Complaint were properly stated.  On June 30, 2016,CWCAM filed a reply in support of the Motion to Dismiss and in response to theOpposition, stating that each of CWCAM’s arguments is supported by the expresslanguage of the agreements between the parties, the documentary evidence andNew York case law.  On September 30, 2016, RAIT Preferred Funding andCWCAM entered into a confidential Settlement Agreement (the “2016 Settlement”),which provides for a stay of the RAIT Preferred Funding litigation (the “LitigationStay”) through August 25, 2017.  Pursuant to the terms of the 2016Settlement, upon satisfaction of a term of the 2016 Settlement by August 25,2017 (or such later date agreed to by the parties), the RAIT Preferred Fundinglitigation will be dismissed, with prejudice.  On May 19, 2017 theBorrower repaid the Loan in accordance with the terms of the notes andsatisfied the condition to dismissal with prejudice.  RAIT has refused todismiss the case and is claiming that the B Note should be paid in full. CWCAM believes that it has performed its obligations under the OperativeAgreements in good faith, and that the action should be dismissed withprejudice.  On August 29, 2017, the RAIT Court granted leave to RAITPreferred Funding to amend its complaint.  On September 20, 2017, RAITPreferred Funding filed an Amended Complaint (the “RAIT Amended Complaint”),which omits its original claims, adds Wells Fargo Bank as a defendant, andseeks (a) specific performance requiring repayment of the $18,500,000 principalamount of the B Note or, in the alternative, monetary damages, including the$18,500,000 principal amount of the B Note, in an amount to be determined attrial, (b) monetary damages on any fees paid to CWCAM as special servicer orWells Fargo Bank as master servicer in connection with the borrower’s repaymentof the Loan, (c) a declaratory judgment that RAIT Preferred Funding is entitledto recover the full $18,500,000 principal amount of the B Note, (d) punitivedamages against CWCAM, and (e) other things.  On October 11, 2017, CWCAMfiled a motion to dismiss the RAIT Amended Complaint (“CWCAM Motion toDismiss Amended Complaint”) stating that the RAIT Amended Complaint did notstate a claim and the essential facts of the RAIT Amended Complaint are negatedby the Operative Agreements and other admissible evidentiary materials. On November 13, 2017, Wells Fargo Bank filed a motion to dismiss the RAITAmended Complaint (the “Wells Fargo Motion to Dismiss Amended Complaint”)and joined the CWCAM Motion to Dismiss Amended Complaint.  On January 29,2018, the court dismissed all claims but for breach of contract and discoveryhas commenced.  CWCAM filed a Motion for Summary Judgement on March 18,2019.   This matter was settled and the case dismissed on May 15,2019.  

 

In December 2014, Phoenix LightSF Limited and certain related entities and the National Credit UnionAdministration (NCUA) filed complaints in the United States District Court forthe Southern District of New York against Wells Fargo Bank, alleging claimsagainst Wells Fargo Bank in its capacity as trustee for a number of residentialmortgage-backed securities trusts. Complaints raising similar allegations havebeen filed by Commerzbank AG in the Southern District of New York and by IKBInternational and IKB Deutsche Industriebank in New York state court. In eachcase, the plaintiffs allege that Wells Fargo Bank, as trustee, caused losses toinvestors, and plaintiffs assert causes of action based upon, among otherthings, the trustee’s alleged failure to notify and enforce repurchaseobligations of mortgage loan sellers for purported breaches of representationsand warranties, notify investors of alleged events of default, and abide byappropriate standards of care following alleged events of default. Wells FargoBank previously settled two class action lawsuits with similar allegations thatwere filed in November 2014 and December 2016 by institutional investors in theSouthern District of New York and New York state court, respectively. Inaddition, Park Royal I LLC and Park Royal II LLC have filed complaints in NewYork state court alleging Wells Fargo Bank, N.A., as trustee, failed to takeappropriate actions upon learning of defective mortgage loan documentation. InMarch 2021, the Company entered into an agreement to resolve the case filed bythe NCUA.

 

In addition to the foregoingcases, in August 2014 and August 2015 Nomura Credit & Capital Inc. (“Nomura”)and Natixis Real Estate Holdings, LLC (“Natixis”) filed a total of seventhird-party complaints against Wells Fargo Bank in New York state court. In theunderlying first-party actions, Nomura and Natixis have been sued for allegedbreaches of representations and warranties made in connection with residentialmortgage-backed securities sponsored by them. In the third-party actions,Nomura and Natixis allege that Wells Fargo Bank, as master servicer, primaryservicer or securities administrator, failed to notify Nomura and Natixis oftheir own breaches, failed to properly oversee the primary servicers, andfailed to adhere to accepted servicing practices. Natixis additionally allegesthat Wells Fargo Bank failed to perform default oversight duties. Wells FargoBank has asserted counterclaims alleging that Nomura and Natixis failed toprovide Wells Fargo Bank notice of their representation and warranty breaches.

 

With respect to each of the foregoing litigations, WellsFargo Bank believes plaintiffs' claims are without merit and intends to contestthe claims vigorously, but there can be no assurances as to the outcome of thelitigations or the possible impact of the litigations on Wells Fargo Bank orthe related RMBS trusts.

**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 21, 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 Osborn Triangle Mortgage Loan,which is being serviced and administered pursuant to the trust and servicingagreement for the JPMCC 2019-OSB Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit L to the trust andservicing agreement for the JPMCC 2019-OSB 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 JPMCC2019-OSB 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 Grand Canal Shoppes MortgageLoan, which is being serviced and administered pursuant to the pooling andservicing agreement for the MSC 2019-H7 Transaction, are attached hereto underItem 15 to this Annual Report on Form 10-K. Attached as Exhibit AA to thepooling and servicing agreement for the MSC 2019-H7 Transaction incorporated byreference as Exhibit 4.3 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the MSC2019-H7 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the 600 & 620 National AvenueMortgage Loan, which is being serviced and administered pursuant to the poolingand servicing agreement for the UBS 2019-C17 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit Z to thepooling and servicing agreement for the UBS 2019-C17 Transaction incorporatedby reference as Exhibit 4.4 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the UBS2019-C17 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicing criteriafor asset-backed securities and related attestation reports on such assessmentsof compliance with respect to the 900 & 990 Stewart Avenue Mortgage Loan,the Sunset North Mortgage Loan and the City Hyde Park Mortgage Loan, which arebeing serviced and administered pursuant to the pooling and servicing agreementfor the Benchmark 2019-B13 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 Benchmark 2019-B13 Transaction incorporated byreference as Exhibit 4.5 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for theBenchmark 2019-B13 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 Tysons Tower Mortgage Loan andthe 230 Park Avenue South Mortgage Loan, which are being serviced andadministered pursuant to the pooling and servicing agreement for the BANK2019-BNK21 Transaction, are attached hereto under Item 15 to this Annual Reporton Form 10-K. Attached as Exhibit Z to the pooling and servicing agreement forthe BANK 2019-BNK21 Transaction incorporated by reference as Exhibit 4.6 tothis Annual Report on Form 10-K is a chart identifying the entitiesparticipating in a servicing function for the BANK 2019-BNK21 Transaction responsiblefor 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 180 Water Mortgage Loan, which isbeing serviced and administered pursuant to the pooling and servicing agreementfor the COMM 2019-GC44 Transaction, are attached hereto under Item 15 to thisAnnual Report on Form 10-K. Attached as Schedule II to the pooling andservicing agreement for the COMM 2019-GC44 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 COMM2019-GC44 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 Innovation Park Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the Benchmark 2019-B15 Transaction, are attached hereto underItem 15 to this Annual Report on Form 10-K. Attached as Exhibit O to thepooling and servicing agreement for the Benchmark 2019-B15 Transactionincorporated by reference as Exhibit 4.8 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theBenchmark 2019-B15 Transaction responsible for each applicable servicingcriteria set forth in Item 1122(d).

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

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

**PART IV**

**Item 15. 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           Pooling and Servicing Agreement, dated as of November 1,2019, between J.P. Morgan Chase Commercial Mortgage Securities Corp., asDepositor, Midland Loan Services, a Division of PNC Bank, National Association,as Master Servicer and as Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator and 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/A filed onDecember 17, 2019 under Commission File No. 333-226123-05 and incorporated byreference herein).

4.2           Trust and Servicing Agreement, dated as of June 13, 2019,among J.P. Morgan Chase Commercial Mortgage Securities Corp., as Depositor,KeyBank National Association, as Servicer, Situs Holdings, LLC, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administratorand as Trustee, and Park Bridge Lender Services LLC, as Operating Advisor(filed as Exhibit 4.2 to the registrant’s Current Report on Form 8-K filed onNovember 21, 2019 under Commission File No. 333-226123-05 and incorporated byreference herein).

4.3           Pooling and Servicing Agreement, dated as of July 1,2019, between Morgan Stanley Capital I Inc., as Depositor, Midland LoanServices, a Division of PNC Bank, National Association, as Master Servicer, LNRPartners, LLC, as Special Servicer, Wells Fargo Bank, National Association, asCertificate Administrator and Trustee, and Pentalpha Surveillance LLC, asOperating Advisor and as Asset Representations Reviewer (filed as Exhibit 4.5to the registrant’s Current Report on Form 8-K/A filed on December 17, 2019under Commission File No. 333-226123-05 and incorporated by reference herein).

4.4           Pooling and Servicing Agreement, dated and effective asof October 1, 2019, among Banc of America Merrill Lynch Commercial MortgageInc., as Depositor, Wells Fargo Bank, National Association, as Master Servicer,Rialto Capital Advisors, LLC, as Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator, Wilmington Trust, NationalAssociation, as Trustee, and Park Bridge Lender Services LLC, as OperatingAdvisor and as Asset Representations Reviewer (filed as Exhibit 4.3 to theregistrant’s Current Report on Form 8-K filed on November 21, 2019 underCommission File No. 333-226123-05 and incorporated by reference herein).

4.5           Pooling and Servicing Agreement, dated as of October 1,2019, between Deutsche Mortgage & Asset Receiving Corporation, asDepositor, Midland Loan Services, a Division of PNC Bank, National Association,as Master Servicer, CWCapital Asset Management LLC, as Special Servicer, WellsFargo Bank, National Association, as Trustee, Wells Fargo Bank, NationalAssociation, as Certificate Administrator, as Paying Agent and as Custodian,and Park Bridge Lender Services LLC, as Operating Advisor and as AssetRepresentations Reviewer (filed as Exhibit 4.4 to the registrant’s CurrentReport on Form 8-K filed on November 21, 2019 under Commission File No.333-226123-05 and incorporated by reference herein).

4.6           Pooling and Servicing Agreement, dated and effective asof October 1, 2019, among UBS Commercial Mortgage Securitization Corp., asDepositor, Wells Fargo Bank, National Association, as Master Servicer, RialtoCapital Advisors, LLC, as Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator, Wilmington Trust, NationalAssociation, as Trustee, and Pentalpha Surveillance LLC, as Operating Advisorand as Asset Representations Reviewer (filed as Exhibit 4.6 to the registrant’sCurrent Report on Form 8-K filed on November 21, 2019 under Commission File No.333-226123-05 and incorporated by reference herein).

4.7           Pooling and Servicing Agreement, dated as of December 1,2019, among Deutsche Mortgage & Asset Receiving Corporation, as Depositor,Midland Loan Services, a Division of PNC Bank, National Association, as MasterServicer, Rialto Capital Advisors, LLC, as Special Servicer, Wells Fargo Bank,National Association, as Trustee, Wells Fargo Bank, National Association, asCertificate Administrator, Paying Agent and Custodian, and Park Bridge LenderServices LLC, as Operating Advisor and as Asset Representations Reviewer (filedas Exhibit 99.1 to the registrant’s Current Report on Form 8-K filed onDecember 18, 2019 under Commission File No. 333-226123-05 and incorporated byreference herein).

4.8           Pooling and Servicing Agreement, dated as of December 1, 2019,among Citigroup Commercial Mortgage Securities Inc., 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, Park Bridge Lender Services LLC, as Operating Advisor and as AssetRepresentations Reviewer, Citibank, N.A., as Certificate Administrator, andWilmington Trust, National Association, as Trustee (filed as Exhibit 99.1 tothe registrant’s Current Report on Form 8-K filed on December 26, 2019 underCommission File No. 333-226123-05 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        Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer

33.2        Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer (see Exhibit 33.1)

33.3        Wells Fargo Bank, National Association, as Trusteeand Certificate Administrator

33.4        Wells Fargo Bank, National Association, asCustodian

33.5        Pentalpha Surveillance LLC, as Operating Advisor

33.6        Computershare Trust Company, National Association,as Servicing Function Participant for the Trustee and Certificate Administratoron and after November 1, 2021

33.7        Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021        

33.8        Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 225 Bush Mortgage Loan (seeExhibit 33.1)

33.9        Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the 225 Bush Mortgage Loan (seeExhibit 33.1)

33.10      Wells Fargo Bank, National Association, as Trustee of the 225 Bush MortgageLoan (Omitted. See Explanatory Notes.)

33.11      Wells Fargo Bank, National Association, asCustodian of the 225 Bush Mortgage Loan (see Exhibit 33.4)

33.12      Pentalpha Surveillance LLC, as Operating Advisor ofthe 225 Bush Mortgage Loan (see Exhibit 33.5)

33.13      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.14      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of The Essex Mortgage Loan (seeExhibit 33.1)

33.15      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of The Essex Mortgage Loan (seeExhibit 33.1)

33.16      Wells Fargo Bank, National Association, as Trustee of The Essex Mortgage Loan(Omitted. See Explanatory Notes.)

33.17      Wells Fargo Bank, National Association, asCustodian of The Essex Mortgage Loan (see Exhibit 33.4)

33.18      Pentalpha Surveillance LLC, as Operating Advisor ofThe Essex Mortgage Loan (see Exhibit 33.5)

33.19      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.20      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Harvey Building ProductsMortgage Loan (see Exhibit 33.1)

33.21      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Harvey Building ProductsMortgage Loan (see Exhibit 33.1)

33.22      Wells Fargo Bank, National Association, as Trustee of the Harvey BuildingProducts Mortgage Loan (Omitted. See Explanatory Notes.)

33.23      Wells Fargo Bank, National Association, asCustodian of the Harvey Building Products Mortgage Loan (see Exhibit 33.4)

33.24      Pentalpha Surveillance LLC, as Operating Advisor ofthe Harvey Building Products Mortgage Loan (see Exhibit 33.5)

33.25      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.26      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Legends at Village WestMortgage Loan (see Exhibit 33.1)

33.27      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Legends at Village WestMortgage Loan (see Exhibit 33.1)

33.28      Wells Fargo Bank, National Association, as Trustee of the Legends at VillageWest Mortgage Loan (Omitted. See Explanatory Notes.)

33.29      Wells Fargo Bank, National Association, asCustodian of the Legends at Village West Mortgage Loan (see Exhibit 33.4)

33.30      Pentalpha Surveillance LLC, as Operating Advisor ofthe Legends at Village West Mortgage Loan (see Exhibit 33.5)

33.31      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.32      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Hilton Cincinnati NetherlandPlaza Mortgage Loan (see Exhibit 33.1)

33.33      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Hilton Cincinnati NetherlandPlaza Mortgage Loan (see Exhibit 33.1)

33.34      Wells Fargo Bank, National Association, as Trustee of the Hilton CincinnatiNetherland Plaza Mortgage Loan (Omitted. See Explanatory Notes.)

33.35      Wells Fargo Bank, National Association, asCustodian of the Hilton Cincinnati Netherland Plaza Mortgage Loan (see Exhibit33.4)

33.36      Pentalpha Surveillance LLC, as Operating Advisor ofthe Hilton Cincinnati Netherland Plaza Mortgage Loan (see Exhibit 33.5)

33.37      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.38      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 8 West Centre Mortgage Loan(see Exhibit 33.1)

33.39      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the 8 West Centre Mortgage Loan(see Exhibit 33.1)

33.40      Wells Fargo Bank, National Association, as Trustee of the 8 West CentreMortgage Loan (Omitted. See Explanatory Notes.)

33.41      Wells Fargo Bank, National Association, asCustodian of the 8 West Centre Mortgage Loan (see Exhibit 33.4)

33.42      Pentalpha Surveillance LLC, as Operating Advisor ofthe 8 West Centre Mortgage Loan (see Exhibit 33.5)

33.43      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.44      KeyBank National Association, as Primary Servicer of the Osborn TriangleMortgage Loan (Omitted. See Explanatory Notes.)

33.45      Situs Holdings, LLC, as Special Servicer of theOsborn Triangle Mortgage Loan

33.46      Wells Fargo Bank, National Association, as Trustee of the Osborn TriangleMortgage Loan (Omitted. See Explanatory Notes.)

33.47      Wells Fargo Bank, National Association, asCustodian of the Osborn Triangle Mortgage Loan (see Exhibit 33.4)

33.48      Park Bridge Lender Services LLC, as OperatingAdvisor of the Osborn Triangle Mortgage Loan

33.49      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.50      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Grand Canal Shoppes MortgageLoan (see Exhibit 33.1)

33.51      Situs Holdings, LLC, as Special Servicer of theGrand Canal Shoppes Mortgage Loan (see Exhibit 33.45)

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

33.53      Wells Fargo Bank, National Association, asCustodian of the Grand Canal Shoppes Mortgage Loan (see Exhibit 33.4)

33.54      Pentalpha Surveillance LLC, as Operating Advisor ofthe Grand Canal Shoppes Mortgage Loan (see Exhibit 33.5)

33.55      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.56      Wells Fargo Bank, National Association, as PrimaryServicer of the 600 & 620 National Avenue Mortgage Loan

33.57      Rialto Capital Advisors, LLC, as Special Servicerof the 600 & 620 National Avenue Mortgage Loan

33.58      Wilmington Trust, National Association, as Trustee of the 600 & 620National Avenue Mortgage Loan (Omitted. See Explanatory Notes.)

33.59      Wells Fargo Bank, National Association, asCustodian of the 600 & 620 National Avenue Mortgage Loan (see Exhibit 33.4)

33.60      Pentalpha Surveillance LLC, as Operating Advisor ofthe 600 & 620 National Avenue Mortgage Loan (see Exhibit 33.5)

33.61      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 600 & 620 National Avenue Mortgage Loan

33.62      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.63      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 900 & 990 Stewart Avenue MortgageLoan (see Exhibit 33.1)

33.64      CWCapital Asset Management LLC, as SpecialServicer of the 900 & 990 Stewart Avenue Mortgage Loan

33.65      Wells Fargo Bank, National Association, as Trustee of the 900 & 990 StewartAvenue Mortgage Loan (Omitted. See Explanatory Notes.)

33.66      Wells Fargo Bank, National Association, asCustodian of the 900 & 990 Stewart Avenue Mortgage Loan (see Exhibit 33.4)

33.67      Park Bridge Lender Services LLC, as OperatingAdvisor of the 900 & 990 Stewart Avenue Mortgage Loan (see Exhibit 33.48)

33.68      Computershare Trust Company, National Association, asServicing Function Participant for the Custodian on and after November 1, 2021(see Exhibit 33.7)

33.69      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the City Hyde Park Mortgage Loan(see Exhibit 33.1)

33.70      CWCapital Asset Management LLC, as SpecialServicer of the City Hyde Park Mortgage Loan (see Exhibit 33.64)

33.71      Wells Fargo Bank, National Association, as Trustee of the City Hyde ParkMortgage Loan (Omitted. See Explanatory Notes.)

33.72      Wells Fargo Bank, National Association, asCustodian of the City Hyde Park Mortgage Loan (see Exhibit 33.4)

33.73      Park Bridge Lender Services LLC, as OperatingAdvisor of the City Hyde Park Mortgage Loan (see Exhibit 33.48)

33.74      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.75      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Sunset North Mortgage Loan(see Exhibit 33.1)

33.76      CWCapital Asset Management LLC, as SpecialServicer of the Sunset North Mortgage Loan (see Exhibit 33.64)

33.77      Wells Fargo Bank, National Association, as Trustee of the Sunset North MortgageLoan (Omitted. See Explanatory Notes.)

33.78      Wells Fargo Bank, National Association, asCustodian of the Sunset North Mortgage Loan (see Exhibit 33.4)

33.79      Park Bridge Lender Services LLC, as OperatingAdvisor of the Sunset North Mortgage Loan (see Exhibit 33.48)

33.80      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.81      Wells Fargo Bank, National Association, as PrimaryServicer of the Tysons Tower Mortgage Loan (see Exhibit 33.56)

33.82      Rialto Capital Advisors, LLC, as Special Servicerof the Tysons Tower Mortgage Loan (see Exhibit 33.57)

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

33.84      Wells Fargo Bank, National Association, asCustodian of the Tysons Tower Mortgage Loan (see Exhibit 33.4)

33.85      Park Bridge Lender Services LLC, as OperatingAdvisor of the Tysons Tower Mortgage Loan (see Exhibit 33.48)

33.86      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Tysons Tower Mortgage Loan (see Exhibit 33.61)

33.87      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.88      Wells Fargo Bank, National Association, as PrimaryServicer of the 230 Park Avenue South Mortgage Loan (see Exhibit 33.56)

33.89      Rialto Capital Advisors, LLC, as Special Servicerof the 230 Park Avenue South Mortgage Loan (see Exhibit 33.57)

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

33.91      Wells Fargo Bank, National Association, asCustodian of the 230 Park Avenue South Mortgage Loan (see Exhibit 33.4)

33.92      Park Bridge Lender Services LLC, as OperatingAdvisor of the 230 Park Avenue South Mortgage Loan (see Exhibit 33.48)

33.93      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 230 Park Avenue South Mortgage Loan (see Exhibit 33.61)

33.94      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.95      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 180 Water Mortgage Loan (seeExhibit 33.1)

33.96      CWCapital Asset Management LLC, as SpecialServicer of the 180 Water Mortgage Loan (see Exhibit 33.64)

33.97      Wells Fargo Bank, National Association, as Trustee of the 180 Water MortgageLoan (Omitted. See Explanatory Notes.)

33.98      Wells Fargo Bank, National Association, asCustodian of the 180 Water Mortgage Loan (see Exhibit 33.4)

33.99      Park Bridge Lender Services LLC, as OperatingAdvisor of the 180 Water Mortgage Loan (see Exhibit 33.48)

33.100    Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.101    Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Innovation Park Mortgage Loan(see Exhibit 33.1)

33.102    Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Innovation Park Mortgage Loanprior to July 19, 2021 (see Exhibit 33.1)

33.103    LNR Partners, LLC, as Special Servicer of the Innovation Park Mortgage Loan onand after July 19, 2021 (Omitted. See Explanatory Notes.)

33.104    Wilmington Trust, National Association, as Trustee of the Innovation ParkMortgage Loan (Omitted. See Explanatory Notes.)

33.105    Citibank, N.A., as Custodian of the Innovation Park Mortgage Loan (Omitted. SeeExplanatory Notes.)

33.106    Park Bridge Lender Services LLC, as OperatingAdvisor of the Innovation Park Mortgage Loan (see Exhibit 33.48)

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

34.1        Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer

34.2        Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer (see Exhibit 34.1)

34.3        Wells Fargo Bank, National Association, as Trusteeand Certificate Administrator

34.4        Wells Fargo Bank, National Association, asCustodian

34.5        Pentalpha Surveillance LLC, as Operating Advisor

34.6        Computershare Trust Company, National Association,as Servicing Function Participant for the Trustee and Certificate Administratoron and after November 1, 2021

34.7        Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021

34.8        Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 225 Bush Mortgage Loan (seeExhibit 34.1)

34.9        Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the 225 Bush Mortgage Loan (seeExhibit 34.1)

34.10      Wells Fargo Bank, National Association, as Trustee of the 225 Bush MortgageLoan (Omitted. See Explanatory Notes.)

34.11      Wells Fargo Bank, National Association, asCustodian of the 225 Bush Mortgage Loan (see Exhibit 34.4)

34.12      Pentalpha Surveillance LLC, as Operating Advisor ofthe 225 Bush Mortgage Loan (see Exhibit 34.5)

34.13      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.14      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of The Essex Mortgage Loan (seeExhibit 34.1)

34.15      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of The Essex Mortgage Loan (seeExhibit 34.1)

34.16      Wells Fargo Bank, National Association, as Trustee of The Essex Mortgage Loan(Omitted. See Explanatory Notes.)

34.17      Wells Fargo Bank, National Association, asCustodian of The Essex Mortgage Loan (see Exhibit 34.4)

34.18      Pentalpha Surveillance LLC, as Operating Advisor ofThe Essex Mortgage Loan (see Exhibit 34.5)

34.19      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.20      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Harvey Building ProductsMortgage Loan (see Exhibit 34.1)

34.21      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Harvey Building ProductsMortgage Loan (see Exhibit 34.1)

34.22      Wells Fargo Bank, National Association, as Trustee of the Harvey BuildingProducts Mortgage Loan (Omitted. See Explanatory Notes.)

34.23      Wells Fargo Bank, National Association, asCustodian of the Harvey Building Products Mortgage Loan (see Exhibit 34.4)

34.24      Pentalpha Surveillance LLC, as Operating Advisor ofthe Harvey Building Products Mortgage Loan (see Exhibit 34.5)

34.25      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.26      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Legends at Village WestMortgage Loan (see Exhibit 34.1)

34.27      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Legends at Village WestMortgage Loan (see Exhibit 34.1)

34.28      Wells Fargo Bank, National Association, as Trustee of the Legends at VillageWest Mortgage Loan (Omitted. See Explanatory Notes.)

34.29      Wells Fargo Bank, National Association, asCustodian of the Legends at Village West Mortgage Loan (see Exhibit 34.4)

34.30      Pentalpha Surveillance LLC, as Operating Advisor ofthe Legends at Village West Mortgage Loan (see Exhibit 34.5)

34.31      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1, 2021(see Exhibit 34.7)

34.32      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Hilton Cincinnati NetherlandPlaza Mortgage Loan (see Exhibit 34.1)

34.33      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Hilton Cincinnati NetherlandPlaza Mortgage Loan (see Exhibit 34.1)

34.34      Wells Fargo Bank, National Association, as Trustee of the Hilton CincinnatiNetherland Plaza Mortgage Loan (Omitted. See Explanatory Notes.)

34.35      Wells Fargo Bank, National Association, asCustodian of the Hilton Cincinnati Netherland Plaza Mortgage Loan (see Exhibit34.4)

34.36      Pentalpha Surveillance LLC, as Operating Advisor ofthe Hilton Cincinnati Netherland Plaza Mortgage Loan (see Exhibit 34.5)

34.37      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.38      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 8 West Centre Mortgage Loan(see Exhibit 34.1)

34.39      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the 8 West Centre Mortgage Loan(see Exhibit 34.1)

34.40      Wells Fargo Bank, National Association, as Trustee of the 8 West CentreMortgage Loan (Omitted. See Explanatory Notes.)

34.41      Wells Fargo Bank, National Association, asCustodian of the 8 West Centre Mortgage Loan (see Exhibit 34.4)

34.42      Pentalpha Surveillance LLC, as Operating Advisor ofthe 8 West Centre Mortgage Loan (see Exhibit 34.5)

34.43      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.44      KeyBank National Association, as Primary Servicer of the Osborn TriangleMortgage Loan (Omitted. See Explanatory Notes.)

34.45      Situs Holdings, LLC, as Special Servicer of theOsborn Triangle Mortgage Loan

34.46      Wells Fargo Bank, National Association, as Trustee of the Osborn TriangleMortgage Loan (Omitted. See Explanatory Notes.)

34.47      Wells Fargo Bank, National Association, asCustodian of the Osborn Triangle Mortgage Loan (see Exhibit 34.4)

34.48      Park Bridge Lender Services LLC, as OperatingAdvisor of the Osborn Triangle Mortgage Loan

34.49      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.50      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Grand Canal Shoppes MortgageLoan (see Exhibit 34.1)

34.51      Situs Holdings, LLC, as Special Servicer of theGrand Canal Shoppes Mortgage Loan (see Exhibit 34.45)

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

34.53      Wells Fargo Bank, National Association, asCustodian of the Grand Canal Shoppes Mortgage Loan (see Exhibit 34.4)

34.54      Pentalpha Surveillance LLC, as Operating Advisor ofthe Grand Canal Shoppes Mortgage Loan (see Exhibit 34.5)

34.55      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.56      Wells Fargo Bank, National Association, as PrimaryServicer of the 600 & 620 National Avenue Mortgage Loan

34.57      Rialto Capital Advisors, LLC, as Special Servicerof the 600 & 620 National Avenue Mortgage Loan

34.58      Wilmington Trust, National Association, as Trustee of the 600 & 620National Avenue Mortgage Loan (Omitted. See Explanatory Notes.)

34.59      Wells Fargo Bank, National Association, asCustodian of the 600 & 620 National Avenue Mortgage Loan (see Exhibit 34.4)

34.60      Pentalpha Surveillance LLC, as Operating Advisor ofthe 600 & 620 National Avenue Mortgage Loan (see Exhibit 34.5)

34.61      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 600 & 620 National Avenue Mortgage Loan

34.62      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.63      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 900 & 990 Stewart AvenueMortgage Loan (see Exhibit 34.1)

34.64      CWCapital Asset Management LLC, as SpecialServicer of the 900 & 990 Stewart Avenue Mortgage Loan

34.65      Wells Fargo Bank, National Association, as Trustee of the 900 & 990 StewartAvenue Mortgage Loan (Omitted. See Explanatory Notes.)

34.66      Wells Fargo Bank, National Association, asCustodian of the 900 & 990 Stewart Avenue Mortgage Loan (see Exhibit 34.4)

34.67      Park Bridge Lender Services LLC, as OperatingAdvisor of the 900 & 990 Stewart Avenue Mortgage Loan (see Exhibit 34.48)

34.68      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.69      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the City Hyde Park Mortgage Loan(see Exhibit 34.1)

34.70      CWCapital Asset Management LLC, as SpecialServicer of the City Hyde Park Mortgage Loan (see Exhibit 34.64)

34.71      Wells Fargo Bank, National Association, as Trustee of the City Hyde ParkMortgage Loan (Omitted. See Explanatory Notes.)

34.72      Wells Fargo Bank, National Association, asCustodian of the City Hyde Park Mortgage Loan (see Exhibit 34.4)

34.73      Park Bridge Lender Services LLC, as Operating Advisorof the City Hyde Park Mortgage Loan (see Exhibit 34.48)

34.74      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.75      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Sunset North Mortgage Loan(see Exhibit 34.1)

34.76      CWCapital Asset Management LLC, as SpecialServicer of the Sunset North Mortgage Loan (see Exhibit 34.64)

34.77      Wells Fargo Bank, National Association, as Trustee of the Sunset North MortgageLoan (Omitted. See Explanatory Notes.)

34.78      Wells Fargo Bank, National Association, asCustodian of the Sunset North Mortgage Loan (see Exhibit 34.4)

34.79      Park Bridge Lender Services LLC, as OperatingAdvisor of the Sunset North Mortgage Loan (see Exhibit 34.48)

34.80      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.81      Wells Fargo Bank, National Association, as PrimaryServicer of the Tysons Tower Mortgage Loan (see Exhibit 34.56)

34.82      Rialto Capital Advisors, LLC, as Special Servicerof the Tysons Tower Mortgage Loan (see Exhibit 34.57)

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

34.84      Wells Fargo Bank, National Association, asCustodian of the Tysons Tower Mortgage Loan (see Exhibit 34.4)

34.85      Park Bridge Lender Services LLC, as OperatingAdvisor of the Tysons Tower Mortgage Loan (see Exhibit 34.48)

34.86      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Tysons Tower Mortgage Loan (see Exhibit 34.61)

34.87      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.88      Wells Fargo Bank, National Association, as PrimaryServicer of the 230 Park Avenue South Mortgage Loan (see Exhibit 34.56)

34.89      Rialto Capital Advisors, LLC, as Special Servicerof the 230 Park Avenue South Mortgage Loan (see Exhibit 34.57)

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

34.91      Wells Fargo Bank, National Association, asCustodian of the 230 Park Avenue South Mortgage Loan (see Exhibit 34.4)

34.92      Park Bridge Lender Services LLC, as OperatingAdvisor of the 230 Park Avenue South Mortgage Loan (see Exhibit 34.48)

34.93      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 230 Park Avenue South Mortgage Loan (see Exhibit 34.61)

34.94      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.95      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 180 Water Mortgage Loan (seeExhibit 34.1)

34.96      CWCapital Asset Management LLC, as SpecialServicer of the 180 Water Mortgage Loan (see Exhibit 34.64)

34.97      Wells Fargo Bank, National Association, as Trustee of the 180 Water MortgageLoan (Omitted. See Explanatory Notes.)

34.98      Wells Fargo Bank, National Association, asCustodian of the 180 Water Mortgage Loan (see Exhibit 34.4)

34.99      Park Bridge Lender Services LLC, as OperatingAdvisor of the 180 Water Mortgage Loan (see Exhibit 34.48)

34.100    Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.101    Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Innovation Park Mortgage Loan(see Exhibit 34.1)

34.102    Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Innovation Park Mortgage Loanprior to July 19, 2021 (see Exhibit 34.1)

34.103    LNR Partners, LLC, as Special Servicer of the Innovation Park Mortgage Loan onand after July 19, 2021 (Omitted. See Explanatory Notes.)

34.104    Wilmington Trust, National Association, as Trustee of the Innovation Park MortgageLoan (Omitted. See Explanatory Notes.)

34.105    Citibank, N.A., as Custodian of the Innovation Park Mortgage Loan (Omitted. SeeExplanatory Notes.)

34.106    Park Bridge Lender Services LLC, as OperatingAdvisor of the Innovation Park Mortgage Loan (see Exhibit 34.48)

35           Servicer compliance statements.

35.1        Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer

35.2        Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer (see Exhibit 35.1)

35.3        Wells Fargo Bank, National Association, asCertificate Administrator

35.4        Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator on andafter November 1, 2021

35.5        Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 225 Bush Mortgage Loan (seeExhibit 35.1)

35.6        Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the 225 Bush Mortgage Loan (seeExhibit 35.1)

35.7        Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of The Essex Mortgage Loan (seeExhibit 35.1)

35.8        Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of The Essex Mortgage Loan (seeExhibit 35.1)

35.9        Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Harvey Building ProductsMortgage Loan (see Exhibit 35.1)

35.10      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Harvey Building ProductsMortgage Loan (see Exhibit 35.1)

35.11      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Legends at Village WestMortgage Loan (see Exhibit 35.1)

35.12      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Legends at Village WestMortgage Loan (see Exhibit 35.1)

35.13      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Hilton Cincinnati NetherlandPlaza Mortgage Loan (see Exhibit 35.1)

35.14      Midland Loan Services, a Division of PNC Bank, NationalAssociation, as Special Servicer of the Hilton Cincinnati Netherland PlazaMortgage Loan (see Exhibit 35.1)

35.15      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 8 West Centre Mortgage Loan(see Exhibit 35.1)

35.16      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the 8 West Centre Mortgage Loan(see Exhibit 35.1)

35.17      KeyBank National Association, as Primary Servicer of the Osborn TriangleMortgage Loan (Omitted. See Explanatory Notes.)

35.18      Situs Holdings, LLC, as Special Servicer of the Osborn Triangle Mortgage Loan(Omitted. See Explanatory Notes.)

35.19      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Grand Canal Shoppes MortgageLoan (see Exhibit 35.1)

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

35.21      Wells Fargo Bank, National Association, as PrimaryServicer of the 600 & 620 National Avenue Mortgage Loan

35.22      Rialto Capital Advisors, LLC, as Special Servicer of the 600 & 620 NationalAvenue Mortgage Loan (Omitted. See Explanatory Notes.)

35.23      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 900 & 990 Stewart AvenueMortgage Loan (see Exhibit 35.1)

35.24      CWCapital Asset Management LLC, as Special Servicer of the 900 & 990Stewart Avenue Mortgage Loan (Omitted. See Explanatory Notes.)

35.25      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the City Hyde Park Mortgage Loan(see Exhibit 35.1)

35.26      CWCapital Asset Management LLC, as Special Servicer of the City Hyde ParkMortgage Loan (Omitted. See Explanatory Notes.)

35.27      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Sunset North Mortgage Loan(see Exhibit 35.1)

35.28      CWCapital Asset Management LLC, as Special Servicer of the Sunset NorthMortgage Loan (Omitted. See Explanatory Notes.)

35.29      Wells Fargo Bank, National Association, as PrimaryServicer of the Tysons Tower Mortgage Loan (see Exhibit 35.21)

35.30      Rialto Capital Advisors, LLC, as Special Servicer of the Tysons Tower MortgageLoan (Omitted. See Explanatory Notes.)

35.31      Wells Fargo Bank, National Association, as PrimaryServicer of the 230 Park Avenue South Mortgage Loan (see Exhibit 35.21)

35.32      Rialto Capital Advisors, LLC, as Special Servicer of the 230 Park Avenue SouthMortgage Loan (Omitted. See Explanatory Notes.)

35.33      Midland Loan Services, a Division of PNC Bank, NationalAssociation, as Primary Servicer of the 180 Water Mortgage Loan (see Exhibit35.1)

35.34      CWCapital Asset Management LLC, as Special Servicer of the 180 Water MortgageLoan (Omitted. See Explanatory Notes.)

35.35      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Innovation Park Mortgage Loan(see Exhibit 35.1)

35.36      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Innovation Park Mortgage Loanprior to July 19, 2021 (see Exhibit 35.1)

35.37      LNR Partners, LLC, as Special Servicer of the Innovation Park Mortgage Loan onand after July 19, 2021 (Omitted. See Explanatory Notes.)

99.1         MortgageLoan Purchase Agreement, dated as of November21, 2019, between J.P. Morgan Chase Commercial Mortgage Securities Corp. andJPMorgan Chase Bank, National Association (filed as Exhibit 99.1 to theregistrant’s Current Report on Form 8-K filed on November 21, 2019 underCommission File No. 333-226123-05 and incorporated by reference herein).

99.2         MortgageLoan Purchase Agreement, dated as of November21, 2019, between J.P. Morgan Chase Commercial Mortgage Securities Corp. andCiti Real Estate Funding Inc. (filed as Exhibit 99.2 to the registrant’sCurrent Report on Form 8-K filed on November 21, 2019 under Commission File No.333-226123-05 and incorporated by reference herein).

99.3         Mortgage LoanPurchase Agreement, dated as of November21, 2019, between J.P. Morgan Chase Commercial Mortgage Securities Corp. andGerman American Capital Corporation (filed as Exhibit 99.3 to the registrant’sCurrent Report on Form 8-K filed on November 21, 2019 under Commission File No.333-226123-05 and incorporated by reference herein).

99.4         Agreement Between Noteholders, dated as of November 18,2019, by and between DBR Investments Co. Limited, as Initial Note A-1 Holder,DBR Investments Co. Limited, as Initial Note A-2 Holder, UBS AG, by and throughits Branch Office at 1285 Avenue of the Americas, New York, New York, asInitial Note A-3 Holder, UBS AG, by and through its Branch Office at 1285Avenue of the Americas, New York, New York, as Initial Note A-4 Holder, DBRInvestments Co. Limited, as Initial Note A-5 Holder, DBR Investments Co.Limited, as Initial Note A-6 Holder, and DBR Investments Co. Limited, asInitial Note B Holder (filed as Exhibit 99.4 to the registrant’s Current Reporton Form 8-K filed on November 21, 2019 under Commission File No. 333-226123-05and incorporated by reference herein).

99.5         AgreementBetween Noteholders, dated as of November 1,2019, by and among JPMorgan Chase Bank, National Association, as Initial NoteA-1-1 Holder, Initial Note A-1-2 Holder, as Initial Note A-1-3 Holder, and asInitial Note B-1-1 Holder, and Goldman Sachs Bank USA, as Initial Note A-1-4Holder and as Initial Note B-1-2 Holder (filed as Exhibit 99.5 to theregistrant’s Current Report on Form 8-K filed on November 21, 2019 underCommission File No. 333-226123-05 and incorporated by reference herein).

99.6         Co-Lender Agreement, dated as of October 18, 2019, by andbetween JPMorgan Chase Bank, National Association, as Initial Note A-1 Holder,JPMorgan Chase Bank, National Association, as Initial Note A-2 Holder, andJPMorgan Chase Bank, National Association, as Initial Note A-3 Holder (filed asExhibit 99.6 to the registrant’s Current Report on Form 8-K filed on November21, 2019 under Commission File No. 333-226123-05 and incorporated by referenceherein).

99.7         Agreement Between Noteholders, dated as of November 21,2019, by and between DBR Investments Co. Limited, as Initial Note A-1 Holder,DBR Investments Co. Limited, as Initial Note A-2 Holder, DBR Investments Co.Limited, as Initial Note A-3 Holder, DBR Investments Co. Limited, as InitialNote A-4 Holder, DBR Investments Co. Limited, as Initial Note A-5 Holder, andDBR Investments Co. Limited, as Initial Note B Holder (filed as Exhibit 99.7 tothe registrant’s Current Report on Form 8-K filed on November 21, 2019 underCommission File No. 333-226123-05 and incorporated by reference herein).

99.8         Co-Lender Agreement, dated as of October 21, 2019, by andbetween Citi Real Estate Funding Inc., as Initial Note A-1 Holder, Citi RealEstate Funding Inc., as Initial Note A-2 Holder, and Citi Real Estate FundingInc., as Initial Note A-3 Holder (filed as Exhibit 99.8 to the registrant’sCurrent Report on Form 8-K filed on November 21, 2019 under Commission File No.333-226123-05 and incorporated by reference herein).

99.9         Co-Lender Agreement, dated as of November 1, 2019, by andbetween Citi Real Estate Funding Inc., as Initial Note A-1 Holder, Citi RealEstate Funding Inc., as Initial Note A-2 Holder, and Citi Real Estate FundingInc., as Initial Note A-3 Holder (filed as Exhibit 99.9 to the registrant’sCurrent Report on Form 8-K filed on November 21, 2019 under Commission File No.333-226123-05 and incorporated by reference herein).

99.10       Co-Lender Agreement, dated as of June 13, 2019, by andamong JPMorgan Chase Bank, National Association, as Initial Note A-1 Holder,JPMorgan Chase Bank, National Association, as Initial Note A-2 Holder, JPMorganChase Bank, National Association, as Initial Note A-3 Holder, JPMorgan ChaseBank, National Association, as Initial Note A-4 Holder, JPMorgan Chase Bank,National Association, as Initial Note A-5 Holder, JPMorgan Chase Bank, NationalAssociation, as Initial Note A-6 Holder, and JPMorgan Chase Bank, NationalAssociation, as Initial Note B-1 Holder (filed as Exhibit 99.10 to theregistrant’s Current Report on Form 8-K filed on November 21, 2019 underCommission File No. 333-226123-05 and incorporated by reference herein).

99.11       Agreement Between Note Holders, dated as of October 23,2019, by and between Wells Fargo Bank, National Association, as Initial NoteA-1 Holder, Wells Fargo Bank, National Association, as Initial Note A-2 Holder,Wells Fargo Bank, National Association, as Initial Note A-3 Holder, JPMorganChase Bank, National Association, as Initial Note A-4 Holder, JPMorgan ChaseBank, National Association, as Initial Note A-5 Holder, JPMorgan Chase Bank,National Association, as Initial Note A-6 Holder, and JPMorgan Chase Bank,National Association, as Initial Note A-7 Holder (filed as Exhibit 99.11 to theregistrant’s Current Report on Form 8-K filed on November 21, 2019 underCommission File No. 333-226123-05 and incorporated by reference herein).

99.12       Co-Lender Agreement, dated as of September 12, 2019, byand between JPMorgan Chase Bank, National Association, as Initial Note A-1Holder and JPMorgan Chase Bank, National Association, as Initial Note A-2Holder (filed as Exhibit 99.12 to the registrant’s Current Report on Form 8-Kfiled on November 21, 2019 under Commission File No. 333-226123-05 andincorporated by reference herein).

99.13       Co-Lender Agreement, dated as of October 24, 2019, by andbetween JPMorgan Chase Bank, National Association, as Initial Note A-1 Holder,JPMorgan Chase Bank, National Association, as Initial Note A-2 Holder, andJPMorgan Chase Bank, National Association, as Initial Note A-3 Holder (filed asExhibit 99.13 to the registrant’s Current Report on Form 8-K filed on November21, 2019 under Commission File No. 333-226123-05 and incorporated by referenceherein).

99.14       Agreement Between Noteholders, dated as of July 3, 2019,by and between Morgan Stanley Bank, N.A., as Note A-1 Holder, Wells Fargo Bank,National Association, as Note A-2 Holder, JPMorgan Chase Bank, NationalAssociation, as Note A-3 Holder, Goldman Sachs Bank USA, as Note A-4 Holder,and CPPIB Credit Investments II Inc., as Note B Holder (filed as Exhibit 99.14to the registrant’s Current Report on Form 8-K filed on November 21, 2019 underCommission File No. 333-226123-05 and incorporated by reference herein).

99.15       Agreement Between Note Holders, dated as of October 23,2019, by and between Wells Fargo Bank, National Association, as Initial NoteA-1 Holder, Wells Fargo Bank, National Association, as Initial Note A-2 Holder,Wells Fargo Bank, National Association, as Initial Note A-3 Holder, Bank ofAmerica, National Association, as Initial Note A-4 Holder, Bank of America,National Association, as Initial Note A-5 Holder, Bank of America, NationalAssociation, as Initial Note A-6 Holder, and JPMorgan Chase Bank, NationalAssociation, as Initial Note A-7 Holder (filed as Exhibit 99.15 to theregistrant’s Current Report on Form 8-K filed on November 21, 2019 underCommission File No. 333-226123-05 and incorporated by reference herein).

99.16       Co-Lender Agreement, dated as of October 22, 2019, by andbetween JPMorgan Chase Bank, National Association, as Initial Note A-1 Holder,and JPMorgan Chase Bank, National Association, as Initial Note A-2 Holder(filed as Exhibit 99.16 to the registrant’s Current Report on Form 8-K filed onNovember 21, 2019 under Commission File No. 333-226123-05 and incorporated byreference herein).

99.17       Co-Lender Agreement, dated as of September 10, 2019, byand among JPMorgan Chase Bank, National Association, as Initial Note A-1Holder, JPMorgan Chase Bank, National Association, as Initial Note A-2 Holderand JPMorgan Chase Bank, National Association, as Initial Note A-3 Holder(filed as Exhibit 99.17 to the registrant’s Current Report on Form 8-K filed onNovember 21, 2019 under Commission File No. 333-226123-05 and incorporated byreference herein).

99.18       Amended and Restated Agreement Between Note Holders,dated as of November 20, 2019, by and between Wilmington Trust, NationalAssociation, as Trustee for the Benefit of the Registered Holders Of UBS CommercialMortgage Trust 2019-C17, Commercial Mortgage Pass-Through Certificates, Series2019-C17, as Note A-1-1 Holder, Wilmington Trust, National Association, asTrustee for the Benefit of the Registered Holders of Wells Fargo CommercialMortgage Trust 2019-C53, Commercial Mortgage Pass-Through Certificates, Series2019-C53, as Note A-1-2 Holder, JPMorgan Chase Bank, National Association, asInitial Note A-2-1-A Holder, JPMorgan Chase Bank, National Association, asInitial Note A-2-1-B Holder, JPMorgan Chase Bank, National Association, asInitial Note A-2-2-A Holder, JPMorgan Chase Bank, National Association, asInitial Note A-2-2-B Holder, and JPMorgan Chase Bank, National Association, asInitial Note A-2-3 Holder (filed as Exhibit 99.18 to the registrant’s CurrentReport on Form 8-K filed on November 21, 2019 under Commission File No.333-226123-05 and incorporated by reference herein).

99.19       Co-Lender Agreement, dated as of September 17, 2019, byand among JPMorgan Chase Bank, National Association, as Initial Note A-1Holder, JPMorgan Chase Bank, National Association, as Initial Note A-2 Holderand JPMorgan Chase Bank, National Association, as Initial Note A-3 Holder(filed as Exhibit 99.19 to the registrant’s Current Report on Form 8-K filed onNovember 21, 2019 under Commission File No. 333-226123-05 and incorporated byreference 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 to besigned on its behalf by the undersigned, thereunto duly authorized.

J.P. Morgan Chase CommercialMortgage Securities Corp.(Depositor)

/s/ KunalK. Singh

Kunal K.Singh, President and Chief Executive Officer

(senior officer in charge ofsecuritization of the depositor)

Date: March 14, 2022