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** **

**Deloitte & Touche LLP**

Certified Public Accountants

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Suite 3700

Miami, FL 33131-3090

USA

 

Tel: +1 305 372 3100

 

 

**REPORT OF INDEPENDENTREGISTERED PUBLIC ACCOUNTING FIRM**

 

3650 REIT Loan Servicing, LLC:

 

We have examined management of3650 REIT Loan Servicing, LLC’s assertion, included in the accompanyingManagement’s Report on Assessment of Compliance with SEC Regulation ABServicing Criteria, that 3650 REIT Loan Servicing, LLC (the “Company”) compliedwith the servicing criteria set forth in Item 1122(d) of the Securities andExchange Commission’s Regulation AB for the asset‐backed securitiestransactions for which the Company served as special servicer involvingcommercial mortgage loans in the Commercial Mortgage Pass‐ThroughCertificates, Series 2019‐C15 (“CSAIL 2019‐C15”), the CommercialMortgage Pass‐Through Certificates, Series 2019‐C17 (“CSAIL 2019‐C17”),the Commercial Mortgage Pass‐Through Certificates, Series 2020‐C19(“CSAIL 2020‐C19”), the Commercial Mortgage Pass‐ThroughCertificates, Series 2020‐TMIC (“CSMC 2020‐TMIC”), the CommercialMortgage Pass‐ Through Certificates, Series 2021‐C20 (“CSAIL 2021‐C20”),the Commercial Mortgage Pass‐Through Certificates, Series 2021‐ACEN(“ALEN 2021‐ACEN”), the Commercial Mortgage Pass‐ThroughCertificates, Series 2021‐PF1 (“3650R 2021‐PF1”), the CommercialMortgage Pass‐Through Certificates, Series 2022‐DPM (“TCO 2022‐DPM”),the Commercial Mortgage Pass‐Through Certificates, Series 2022‐ NLP(“JPMCC 2022‐NLP”), the Commercial Mortgage Pass‐ThroughCertificates, Series 2022‐PSB (“BX 2022‐PSB”), the CommercialMortgage Pass‐Through Certificates, Series 2022‐STAY (“INTOWN 2022‐STAY”) and the Commercial Mortgage Pass‐Through Certificates, Series 2022‐PF2(“3650R 2022‐PF2”), and that were registered with the Securities andExchange Commission pursuant to the Securities Act of 1933 (the “Platform”),excluding criteria in Items 1122(d)(1)(iii), (2)(i), (2) (ii), (2)( iii),(2)(iv), (2)(v), (2)(vii), (3)(i)(C), (3)( i) (D), (3)(ii), (3)(iii), (3)(iv),(4)(ii), (4)(iv), (4)(v), (4)(ix), (4)(x), (4)(xi), (4)(xii), (4)(xiii),(4)(xiv) and (4)(xv) (the “servicing criteria”), as of and for the year endedDecember 31, 2022, which management has determined are not applicable to theactivities performed by the Company with respect to the Platform. Exhibit 1 tomanagement’s assertion identifies the individual asset‐backedtransactions defined by management as constituting the Platform. Management isresponsible for the Company’s compliance with the servicing criteria and itsassertion. Our responsibility is to express an opinion on management’sassertion about the Company’s compliance with the servicing criteria based onour examination.

 

Our examination was conductedin accordance with the standards of the Public Company Accounting OversightBoard (United States) and in accordance with attestation standards establishedby the American Institute of Certified Public Accountants. Those standardsrequire that we plan and perform the examination to obtain reasonable assuranceabout whether management’s assertion about compliance with the servicingcriteria is fairly stated, in all material respects, and, accordingly, includedexamining, on a test basis, evidence about the Company’s compliance with theservicing criteria, including tests on a sample basis of the servicingactivities related to the Platform, determining whether the Company performedthose selected activities in compliance with the servicing criteria during thespecified period, and performing such other procedures as we considerednecessary in the circumstances. Our procedures were limited to selectedservicing activities performed by the Company during the period covered by thisreport and, accordingly, such samples may not have included servicingactivities related to each asset‐backed transaction included in thePlatform. Further, an examination is not designed to detect noncompliancearising from errors that may have occurred prior to the period specified abovethat may have affected the balances or amounts calculated or reported by theCompany during the period covered by this report. We believe that the evidencewe obtained in our examination is sufficient and appropriate to provide areasonable basis for our opinion.

 

As described in management’sassertion, for servicing criteria Items 1122(d)(1)(ii) and (d)(4)(i) theCompany has engaged vendors to perform certain activities required by thisservicing criteria. The Company has determined that these vendors are not considereda “servicer” as defined in Item 1101(j) of Regulation AB, and the Company haselected to take responsibility for assessing compliance with the servicingcriteria applicable to these vendors as permitted by the SEC’s *Complianceand Disclosure Interpretation 200.06, Vendors Engaged by Servicers*(“C&DI 200.06”). As permitted by C&DI 200.06, the Company has assertedthat it has policies and procedures in place designed to provide reasonableassurance that the vendors’ activities comply in all material respects with theservicing criteria applicable to this vendor. The Company is solely responsiblefor determining that it meets the SEC requirements to apply C&DI 200.06 forthe vendors and related criteria as described in its assertion, and we performedno procedures with respect to the Company’s determination of its eligibility toapply C&DI 200.06.

 

Our examination does notprovide a legal determination on the Company’s compliance with the servicingcriteria.

 

In our opinion, management’sassertion that the Company complied with the aforementioned servicing criteriaas of and for the year ended December 31, 2022, for the asset‐backedsecurities transactions for which the Company served as special servicerinvolving commercial mortgage loans in CSAIL 2019‐C15, CSAIL 2019‐C17,CSAIL 2020‐C19, CSMC 2020‐TMIC, CSAIL 2021‐C20, ALEN 2021‐ACEN,3650R 2021‐PF1, TCO 2022‐DPM, JPMCC 2022‐NLP, BX 2022‐PSB,INTOWN 2022‐STAY and 3650R 2022‐PF2 and that were registered withthe Securities and Exchange Commission pursuant to the Securities Act of1933,is fairly stated, in all material respects.

 

/s/ Deloitte & Touche LLP

 

Miami, Florida

February 28, 2023