**UNITED STATESSECURITIES AND EXCHANGE COMMISSION**

**Washington, D.C. 20549**

**FORM 10-K**

(Mark One)

**x****  ANNUAL REPORT PURSUANT TO SECTION13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934**

**For the fiscal year ended December 31, 2019or**

**o**** ****TRANSITIONREPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934**

**For the transition period from _____ to _____Commission file number of the issuing entity: 333-226943-05**

**Central Index Key Number of the issuing entity:0001792157**

**COMM 2019-GC44 Mortgage Trust**

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

** **

**Central Index Key Number of the depositor: 0001013454**

**Deutsche Mortgage & AssetReceiving Corporation**

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

** **

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

**German American Capital Corporation**

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

** **

**Central Index Key Number of the sponsor: 0001541502**

**Goldman Sachs Mortgage Company**

**(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)**

** **

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

**the issuing entity)** | **38-4129062**

**38-4129063**

**38-4129064**

**38-7235632**

**(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) 250-2500**

Securities registered pursuant to Section 12(b) of the Act:

| Title of each class | Trading Symbol(s) | Name of each exchange on which registered |
|---------------------|-------------------|-------------------------------------------|
| None                |              |                                      |

Securities registered pursuant to Section 12(g) of theAct:  None.

Indicate by check mark if the registrant is a well-knownseasoned issuer, as defined in Rule 405 of the Securities Act.  o Yes ⌧No

Indicate by check mark if the registrant is not required tofile reports pursuant to Section 13 or Section 15(d) of the Act.  o Yes ⌧No

Indicate by check mark whether the registrant (1) has filedall reports required to be filed by Section 13 or 15(d) of the SecuritiesExchange Act of 1934 during the preceding 12 months (or for such shorter periodthat the registrant was required to file such reports), and (2) has beensubject to such filing requirements for the past 90 days.  ⌧ Yes oNo

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

Not applicable.

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

Not applicable.

Indicate by check mark whether the registrant is a largeaccelerated filer, an accelerated filer, a non-accelerated filer, a smallerreporting company, 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 complyingwith any new or revised financial accounting standards provided pursuant toSection 13(a) of the Exchange Act.  o

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

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

Not applicable.

Indicate by check mark whether the registrant has filed 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 180 Water Mortgage Loan, The Shoppes atBlackstone Valley Mortgage Loan, the Elston Retail Collection Mortgage Loan,the PCI Pharma Portfolio Mortgage Loan, the Broadcasting Square Mortgage Loanand the Cobb Place Mortgage Loan, which constituted approximately 6.1%, 5.4%,3.9%, 3.9%, 3.1% and 2.4%, respectively, of the asset pool of the issuingentity as of its cut-off date, are each an asset of the issuing entity and areeach part of a loan combination that includes (a) with respect to the 180 WaterMortgage Loan which is an asset of the issuing entity and two other *paripassu* loans, which are not assets of the issuing entity, (b) with respectto The Shoppes at Blackstone Valley Mortgage Loan which is an asset of theissuing entity and eight other *pari passu* loans, which are not assets ofthe issuing entity, (c) with respect to the Elston Retail Collection MortgageLoan which is an asset of the issuing entity and one other *pari passu*loan, which is not an asset of the issuing entity, (d) with respect to the PCIPharma Portfolio Mortgage Loan which is an asset of the issuing entity and sixother *pari passu* loans, which are not assets of the issuing entity, (e)with respect to the Broadcasting Square Mortgage Loan which is an asset of theissuing entity and one other *pari passu* loan, which is not an asset ofthe issuing entity and (f) with respect to the Cobb Place Mortgage Loan whichis an asset of the issuing entity and one other *pari passu* loan, whichis not an asset of the issuing entity. These loan combinations, including the180 Water Mortgage Loan, The Shoppes at Blackstone Valley Mortgage Loan, theElston Retail Collection Mortgage Loan, the PCI Pharma Portfolio Mortgage Loan,the Broadcasting Square Mortgage Loan and the Cobb Place Mortgage Loan, arebeing serviced and administered pursuant to the Pooling and ServicingAgreement, which is incorporated by reference as Exhibit 4.1 to this AnnualReport on Form 10-K. 

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the USAA Office Portfolio Mortgage Loan and theMillennium Park Plaza Mortgage Loan, which constituted approximately 4.4% and1.5%, respectively, of the asset pool of the issuing entity as of its cut-offdate.  The USAA Office Portfolio Mortgage Loan and the Millennium ParkPlaza Mortgage Loan are each an asset of the issuing entity and are each partof a loan combination that includes the USAA Office Portfolio Mortgage Loan orthe Millennium Park Plaza Mortgage Loan and five other *pari passu* loans,which are not assets of the issuing entity. A *pari passu* portion of eachloan combination was securitized in the Citigroup Commercial Mortgage Trust2019-GC41 transaction, Commission File Number 333-228597-02 (the “CGCMT2019-GC41 Transaction”). These loan combinations, including the USAA OfficePortfolio Mortgage Loan and the Millennium Park Plaza Mortgage Loan, are beingserviced and administered pursuant to the pooling and servicing agreement forthe CGCMT 2019-GC41 Transaction, which is incorporated by reference as Exhibit4.2 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 Wind Creek Leased Fee Mortgage Loan, whichconstituted approximately 1.9% of the asset pool of the issuing entity as ofits cut-off date.  The Wind Creek Leased Fee Mortgage Loan is an asset ofthe issuing entity and is part of a loan combination that includes the WindCreek Leased Fee Mortgage Loan and six other *pari passu* loans, which arenot assets of the issuing entity. A *pari passu* portion of the loancombination was securitized in the Benchmark 2019-B13 Mortgage Trusttransaction, Commission File Number 333-226943-04 (the “Benchmark 2019-B13Transaction”). This loan combination, including the Wind Creek Leased FeeMortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the Benchmark 2019-B13 Transaction, which is incorporatedby 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 Midtown Center Mortgage Loan, which constitutedapproximately 3.2% of the asset pool of the issuing entity as of its cut-offdate.  The Midtown Center Mortgage Loan is an asset of the issuing entityand is part of a loan combination that includes the Midtown Center MortgageLoan and eight other *pari passu* loans and three subordinate companionloans, which are not assets of the issuing entity. A *pari passu* portionof the loan combination was securitized in the DC Office Trust 2019-MTCtransaction (the “DCOT 2019-MTC Transaction”). This loan combination,including the Midtown Center Mortgage Loan, is being serviced and administeredpursuant to the trust and servicing agreement for the DCOT 2019-MTCTransaction, which is incorporated by reference as Exhibit 4.4 to this AnnualReport on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Century Plaza Towers Mortgage Loan, whichconstituted approximately 7.3% of the asset pool of the issuing entity as of itscut-off date.  The Century Plaza Towers Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the CenturyPlaza Towers Mortgage Loan and twenty-seven other *pari passu* loans andthree subordinate companion loans, which are not assets of the issuing entity.A *pari passu* portion of the loan combination was securitized in the CPTS2019-CPT Mortgage Trust transaction (the “CPTS 2019-CPT Transaction”).This loan combination, including the Century Plaza Towers Mortgage Loan, isbeing serviced and administered pursuant to the trust and servicing agreementfor the CPTS 2019-CPT Transaction, which is incorporated by reference asExhibit 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 225 Bush Mortgage Loan, The Essex Site 2Mortgage Loan and the Legends at Village West Mortgage Loan, which constitutedapproximately 4.9%, 3.4% and 3.4%, respectively, of the asset pool of theissuing entity as of its cut-off date.  The 225 Bush Mortgage Loan, TheEssex Site 2 Mortgage Loan and the Legends at Village West Mortgage Loan areeach an asset of the issuing entity and are each part of a loan combinationthat includes (a) with respect to the 225 Bush Mortgage Loan and five other *paripassu* loans and one subordinate companion loan, which are not assets of theissuing entity, (b) with respect to The Essex Site 2 Mortgage Loan and threeother *pari passu* loans and two subordinate companion loans, which arenot assets of the issuing entity or (c) with respect to the Legends at VillageWest Mortgage Loan and two other *pari passu* loans, which are not assetsof the issuing entity. A *pari passu* portion of each loan combination wassecuritized in the Benchmark 2019-B14 Mortgage Trust transaction, CommissionFile Number 333-226123-05 (the “Benchmark 2019-B14 Transaction”). Theseloan combinations, including the 225 Bush Mortgage Loan, The Essex Site 2Mortgage Loan and the Legends at Village West Mortgage Loan, are being servicedand administered pursuant to the pooling and servicing agreement for theBenchmark 2019-B14 Transaction, which is incorporated by reference as Exhibit4.6 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 identified herein. If this report does not identify a separate primary servicer, the servicercompliance statement provided by the master servicer under any such agreementalso encompasses its responsibilities as primary servicer of the relatedmortgage loan or mortgage loans.

Midland Loan Services, a Divisionof PNC Bank, National Association is the master servicer of the mortgage loansserviced under the Pooling and Servicing Agreement, the primary servicer of theUSAA Office Portfolio Mortgage Loan, the Wind Creek Leased Fee Mortgage Loanand the Millennium Park Plaza Mortgage Loan and the primary servicer andspecial servicer of the 225 Bush Mortgage Loan, The Essex Site 2 Mortgage Loanand the Legends at Village West Mortgage Loan. As a result, Midland Loan Services,a Division of PNC Bank, National Association is a “servicer” as defined in Item1108(a)(2)(iii) of Regulation AB, in the capacities described above, because itis servicing mortgage loans that constituted 10% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria, accountants’ attestation reports and servicercompliance statements delivered by Midland Loan Services, a Division of PNCBank, National Association in the capacities described above are listed in theExhibit Index.

Rialto Capital Advisors, LLC isthe special servicer of the mortgage loans serviced under the Pooling andServicing Agreement, the USAA Office Portfolio Mortgage Loan and the MillenniumPark Plaza Mortgage Loan. As a result, Rialto Capital Advisors, LLC is a“servicer” as defined in Item 1108(a)(2)(iii) of Regulation AB, in thecapacities described above, because it is servicing mortgage loans thatconstituted 10% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby Rialto Capital Advisors, LLC in the capacities described above are listed inthe 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 theCentury Plaza Towers Mortgage Loan and the Midtown Center Mortgage Loan. As aresult, Wells Fargo Bank, National Association is a “servicer” as defined inItem 1108(a)(2)(iii) of Regulation AB, in the capacities described above,because it is servicing mortgage loans that constituted 10% or more of theassets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria, accountants’ attestation reportsand servicer compliance statements delivered by Wells Fargo Bank, NationalAssociation in the capacities described above are listed in the Exhibit Index.

Wells Fargo Bank, National Association is the custodian ofthe mortgage loans serviced under the Pooling and Servicing Agreement, the 225Bush Mortgage Loan, The Essex Site 2 Mortgage Loan, the Legends at Village WestMortgage Loan, the Wind Creek Leased Fee Mortgage Loan, the Century PlazaTowers Mortgage Loan and the Midtown Center Mortgage Loan.  As a result,Wells Fargo Bank, National Association is a servicing function participant inthe capacities 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 Wells Fargo Bank, NationalAssociation in the capacities described above are listed in the Exhibit Index.

Park Bridge Lender Services LLC is the operating advisor ofthe mortgage loans serviced under the Pooling and Servicing Agreement, the USAAOffice Portfolio Mortgage Loan, the Wind Creek Leased Fee Mortgage Loan and theMillennium Park Plaza Mortgage Loan.  As a result, Park Bridge LenderServices LLC 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 Park Bridge Lender Services LLC in the capacitiesdescribed above are listed in the Exhibit Index.

Citibank, N.A. is the custodian of the USAA Office PortfolioMortgage Loan and the Millennium Park Plaza Mortgage Loan.  As a result,Citibank, N.A. is a servicing function participant in the capacities describedabove, because it is servicing mortgage loans that constituted 5% or more ofthe assets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria and accountants’ attestationreports delivered by Citibank, N.A. in the capacities described above arelisted in the Exhibit Index. 

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

CWCapital Asset Management LLC isthe special servicer of the Century Plaza Towers Mortgage Loan, the MidtownCenter Mortgage Loan and the Wind Creek Leased Fee Mortgage Loan. As a result,CWCapital Asset Management LLC is a “servicer” as defined in Item1108(a)(2)(iii) of Regulation AB, in the capacities described above, because itis servicing mortgage loans that constituted 10% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria, accountants’ attestation reports and servicercompliance statements delivered by CWCapital Asset Management LLC in thecapacities described above are listed in the Exhibit Index.

Pentalpha Surveillance LLC is the operating advisor of the225 Bush Mortgage Loan, The Essex Site 2 Mortgage Loan and the Legends atVillage West Mortgage Loan.  As a result, Pentalpha Surveillance LLC is aservicing function participant in the capacities described above, because it isservicing mortgage loans that constituted 5% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria and accountants’ attestation reports delivered byPentalpha Surveillance LLC in the capacities described above are listed in theExhibit Index.

Wells Fargo Bank, NationalAssociation acts as trustee of the 180 Water Mortgage Loan, The Shoppes atBlackstone Valley Mortgage Loan, the Elston Retail Collection Mortgage Loan,the PCI Pharma Portfolio Mortgage Loan, the Broadcasting Square Mortgage Loan,the Cobb Place Mortgage Loan, the 225 Bush Mortgage Loan, the Legends atVillage West Mortgage Loan, The Essex Site 2 Mortgage Loan and the Wind CreekLeased Fee Mortgage Loan.  Pursuant to the Pooling and ServicingAgreement, the pooling and servicing agreement for the Benchmark 2019-B14Transaction and the pooling and servicing agreement for the Benchmark 2019-B13Transaction, the trustee is required to provide an assessment of compliancewith applicable servicing criteria solely with respect to Item 1122(d)(2)(iii)of Regulation AB (regarding advances of funds or guarantees regarding collections,cash flows or distributions, and any interest or other fees charged for suchadvances, are made, reviewed and approved as specified in the transactionagreements). However, during the reporting period, the trustee did not performany servicing function with respect to the servicing criteria specified in Item1122(d)(2)(iii) of Regulation AB.  The master servicer or the specialservicer, to the extent required, performed the servicing function identifiedwith respect to Item 1122(d)(2)(iii) of Regulation AB, and each such partyincluded Item 1122(d)(2)(iii) of Regulation AB in the assessment of compliancewith applicable 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 180 Water Mortgage Loan, TheShoppes at Blackstone Valley Mortgage Loan, the Elston Retail CollectionMortgage Loan, the PCI Pharma Portfolio Mortgage Loan, the Broadcasting SquareMortgage Loan, the Cobb Place Mortgage Loan, the 225 Bush Mortgage Loan, theLegends at Village West Mortgage Loan, The Essex Site 2 Mortgage Loan and theWind Creek Leased Fee Mortgage Loan have delivered one or more assessments ofcompliance with respect to Item 1122(d)(2)(iii) of Regulation AB.

Wilmington Trust, NationalAssociation acts as trustee of the USAA Office Portfolio Mortgage Loan, theMillennium Park Plaza Mortgage Loan, the Midtown Center Mortgage Loan and theCentury Plaza Towers Mortgage Loan.  Pursuant to the pooling and servicingagreement for the CGCMT 2019-GC41 Transaction, the trust and servicingagreement for the DCOT 2019-MTC Transaction and the trust and servicingagreement for the CPTS 2019-CPT Transaction, the trustee is required to providean assessment of compliance with applicable servicing criteria solely withrespect to Item 1122(d)(2)(iii) of Regulation AB (regarding advances of fundsor 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 with respectto the servicing criteria specified in Item 1122(d)(2)(iii) of RegulationAB.  The master servicer or the special servicer, to the extent required,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 USAA Office Portfolio MortgageLoan, the Millennium Park Plaza Mortgage Loan, the Midtown Center Mortgage Loanand the Century Plaza Towers Mortgage Loan have delivered one or moreassessments of compliance with respect to Item 1122(d)(2)(iii) of RegulationAB.

This Annual Report on Form 10-Kincludes assessments of compliance with applicable servicing criteria andaccountants’ attestation reports from CoreLogic Commercial Real EstateServices, Inc. and National Tax Search, LLC.  These entities were engagedby the primary servicer of the Midtown Center Mortgage Loan and the CenturyPlaza Towers Mortgage Loan to remit tax payments received from the escrowaccounts of borrowers to local taxing authorities, to report tax amounts due,to verify tax parcel information, and to verify non-escrow tax payments. Theseservicing functions are included within the servicing criteria set forth inItems 1122(d)(4)(xi) and 1122(d)(4)(xii) of Regulation AB.  Therefore,under the principles-based definition of “servicer” set forth in Item 1101(j)of Regulation AB that looks to the functions that an entity performs, thesevendors are “servicers” for the purposes of Item 1122 of Regulation AB.  *See*Compliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

Theassessments of compliance with applicable servicing criteria, accountants’attestation reports and servicer compliance statements of the certificateadministrator of the Wind Creek Leased Fee Mortgage Loan, the Midtown CenterMortgage Loan, the Century Plaza Towers Mortgage Loan, the 225 Bush MortgageLoan, the USAA Office Portfolio Mortgage Loan, the Millennium Park PlazaMortgage Loan, the Legends at Village West Mortgage Loan and The Essex Site 2Mortgage Loan listed on the Exhibit Index are omitted from this Annual Reporton Form 10-K as the certificate administrator pursuant to the related poolingand servicing agreement or trust and servicing agreement does not perform anyactivities that address servicing criteria with respect to the issuing entityand because they are each not a “servicer” that meets the criteria in Item1108(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, RelatedStockholder Matters and Issuer Purchases of Equity Securities.**

Omitted.

**Item 6.  Selected Financial Data.**

Omitted.

**Item 7.  Management’s Discussion and Analysis ofFinancial Condition and Results of Operations.**

Omitted.

**Item 7A.  Quantitative and Qualitative DisclosuresAbout Market Risk.**

Omitted.

**Item 8.  Financial Statements and Supplementary Data.**

Omitted.

**Item 9.  Changes in and Disagreements WithAccountants on Accounting and Financial Disclosure.**

Omitted.

**Item 9A.  Controls and Procedures.**

Omitted.

**Item 9B.  Other Information.**

None.

**PART III**

**Item 10.  Directors, Executive Officers and CorporateGovernance.**

Omitted.

**Item 11.  Executive Compensation.**

Omitted.

**Item 12.  Security Ownership of Certain BeneficialOwners and Management and Related Stockholder Matters.**

Omitted.

**Item 13.  Certain Relationships and RelatedTransactions, and Director Independence.**

Omitted.

**Item 14.  Principal Accounting Fees and Services.**

Omitted.

**ADDITIONAL DISCLOSURE ITEMS FOR REGULATION AB**

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

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

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

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

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

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

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

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

In the ordinary course of business, Citibank is involved in anumber of legal proceedings, including in connection with its role as trusteeof certain RMBS transactions.  Certain of these Citibank astrustee-related matters are disclosed herein. 

On June 18, 2014, a civil action was filed against Citibankin the Supreme Court of the State of New York by a group of investors in 48private-label RMBS trusts for which Citibank allegedly serves or did serve astrustee, asserting claims for purported violations of the Trust Indenture Actof 1939 (the “Trust Indenture Act”), breach of contract, breach offiduciary duty and negligence based on Citibank’s alleged failure to performits duties as trustee for the 48 RMBS trusts.  On November 24, 2014,plaintiffs sought leave to withdraw this action.  On the same day, asmaller subset of similar plaintiff investors in 27 private-label RMBS trustsfor which Citibank allegedly serves or did serve as trustee, filed a new civilaction against Citibank in the United States District Court for the SouthernDistrict of New York asserting similar claims as the prior action filed instate court.  In January 2015, the court closed plaintiffs’ original statecourt action.  On September 8, 2015, the federal court dismissed allclaims as to 24 of the 27 trusts and allowed certain of the claims to proceedas to the other three trusts. Subsequently, plaintiffs voluntarily dismissed allclaims with respect to two of the three trusts. On April 7, 2017, Citibankfiled a motion for summary judgment. Plaintiffs filed its consolidatedopposition brief and cross motion for partial summary judgment on May 22,2017.  Briefing on those motions was completed on August 4, 2017. On March22, 2018, the court granted Citibank’s motion for summary judgment in itsentirety, denied Plaintiffs’ motion for summary judgment and ordered the clerkto close the case. On April 20, 2018, plaintiffs filed a notice of appeal.Plaintiffs’ opening brief was filed on August 3, 2018. Citibank filed itsopposition on November 2, 2018.  Plaintiffs’ filed their reply on November16, 2018.  On June 7, 2019, the Second Circuit dismissed plaintiffs’appeal following the parties’ filing of a stipulation withdrawing the case withprejudice pursuant to Federal Rule of Appellate Procedure 42.

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

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

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

Beginning on June 18, 2014, a group of institutionalinvestors filed civil complaints in the Supreme Court of the State of New York,New York County, and later the U.S. District Court for the Southern District ofNew York, against Wells Fargo Bank, N.A., (“Wells Fargo Bank”) in itscapacity as trustee for certain residential mortgage backed securities (“RMBS”)trusts.  The complaints against Wells Fargo Bank alleged that the trusteecaused losses to investors and asserted causes of action based upon, amongother things, the trustee's alleged failure to: (i) notify and enforcerepurchase obligations of mortgage loan sellers for purported breaches ofrepresentations and warranties, (ii) notify investors of alleged events ofdefault, and (iii) abide by appropriate standards of care following allegedevents of default. Relief sought included money damages in an unspecifiedamount, reimbursement of expenses, and equitable relief. In November 2018,Wells Fargo Bank reached an agreement, in which it denied any wrongdoing, toresolve such claims on a classwide basis for the 271 RMBS trusts atissue.  On May 6, 2019, the court entered an order approving thesettlement agreement.  Separate lawsuits against Wells Fargo Bank makingsimilar allegations filed by certain other institutional investors concerningseveral RMBS trusts in New York federal and state court are not covered by theagreement.  With respect to such litigations, Wells Fargo Bank believesplaintiffs' claims are without merit and intends to contest the claimsvigorously, but there can be no assurances as to the outcome of the litigationsor the possible impact of the litigations on Wells Fargo Bank or the 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 December 12, 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 ScheduleII to the Pooling and Servicing Agreement incorporated by reference as Exhibit4.1 to 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 USAA Office Portfolio MortgageLoan and the Millennium Park Plaza Mortgage Loan, which are being serviced andadministered pursuant to the pooling and servicing agreement for the CGCMT2019-GC41 Transaction, are attached hereto under Item 15 to this Annual Reporton Form 10-K. Attached as Exhibit O to the pooling and servicing agreement forthe CGCMT 2019-GC41 Transaction incorporated by reference as Exhibit 4.2 tothis Annual Report on Form 10-K is a chart identifying the entitiesparticipating in a servicing function for the CGCMT 2019-GC41 Transactionresponsible for each applicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Wind Creek Leased Fee MortgageLoan, which is being serviced and administered pursuant to the pooling andservicing agreement for the Benchmark 2019-B13 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Schedule II tothe pooling and servicing agreement for the Benchmark 2019-B13 Transactionincorporated by reference as Exhibit 4.3 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theBenchmark 2019-B13 Transaction responsible for each applicable servicingcriteria 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 Midtown Center Mortgage Loan,which is being serviced and administered pursuant to the trust and servicingagreement for the DCOT 2019-MTC 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 DCOT 2019-MTC Transaction incorporated by referenceas Exhibit 4.4 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the DCOT 2019-MTCTransaction responsible for each applicable servicing criteria set forth inItem 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Century Plaza Towers MortgageLoan, which is being serviced and administered pursuant to the trust andservicing agreement for the CPTS 2019-CPT Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Schedule I to thetrust and servicing agreement for the CPTS 2019-CPT 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 the CPTS2019-CPT 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 225 Bush Mortgage Loan, theLegends at Village West Mortgage Loan and The Essex Site 2 Mortgage Loan, whichare being serviced and administered pursuant to the pooling and servicingagreement for the Benchmark 2019-B14 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 Benchmark 2019-B14 Transactionincorporated by reference as Exhibit 4.6 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theBenchmark 2019-B14 Transaction responsible for each applicable servicingcriteria set forth in Item 1122(d).

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

Material Instance of Noncompliance

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

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

Steps Taken to Remedy the Material Instance of Noncompliance

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

Midland is currently remediating the Schedule AL reportingfor certain of the CMBS transactions found to be incorrect.

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

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

**PART IV**

**Item 15. Exhibits, Financial Statement Schedules**

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

(1) Not applicable

(2) Not applicable

(3) See below

 

4.1          Pooling and Servicing Agreement, dated as of December 1,2019, between Deutsche Mortgage & Asset Receiving Corporation, asDepositor, Midland Loan Services, a Division of PNC Bank, National Association,as Master Servicer, Rialto Capital Advisors, LLC, as Special Servicer, WellsFargo Bank, National Association, as Trustee, Wells Fargo Bank, NationalAssociation, as Certificate Administrator, Paying Agent and Custodian, and ParkBridge Lender Services LLC, as Operating Advisor and Asset RepresentationsReviewer (filed as Exhibit 4.1 to the registrant’s Current Report on Form 8-K/Afiled on January 31, 2020 under Commission File No. 333-226943-05 andincorporated by reference herein).

4.2          Pooling and Servicing Agreement, dated as of August 1, 2019,among Citigroup Commercial Mortgage Securities Inc., as Depositor, Midland LoanServices, a Division of PNC Bank, National Association, as Master Servicer,Rialto Capital Advisors, LLC, as Special Servicer, Park Bridge Lender ServicesLLC, as Operating Advisor and Asset Representations Reviewer, Citibank, N.A.,as Certificate Administrator, and Wilmington Trust, National Association, asTrustee (filed as Exhibit 4.4 to the registrant’s Current Report on Form 8-Kfiled on December 12, 2019 under Commission File No. 333-226943-05 andincorporated by reference herein).

4.3          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, Paying Agent and Custodian, and ParkBridge Lender Services LLC, as Operating Advisor and Asset RepresentationsReviewer (filed as Exhibit 4.6 to the registrant’s Current Report on Form 8-Kfiled on December 12, 2019 under Commission File No. 333-226943-05 andincorporated by reference herein).

4.4          Trust and Servicing Agreement, dated as of October 30, 2019,among Wells Fargo Commercial Mortgage Securities, Inc., as Depositor, WellsFargo Bank, National Association, as Servicer, CWCapital Asset Management LLC,as Special Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator and Wilmington Trust, National Association, as Trustee (filed asExhibit 4.5 to the registrant’s Current Report on Form 8-K filed on December12, 2019 under Commission File No. 333-226943-05 and incorporated by referenceherein).

4.5          Trust and Servicing Agreement, dated as of November 9, 2019,between Deutsche Mortgage & Asset Receiving Corporation, as Depositor,Wells Fargo Bank, National Association, as Master Servicer, CWCapital AssetManagement LLC, as Special Servicer, Wilmington Trust, National Association, asTrustee, and Wells Fargo Bank, National Association, as CertificateAdministrator, Paying Agent and Custodian (filed as Exhibit 4.2 to theregistrant’s Current Report on Form 8-K filed on December 12, 2019 underCommission File No. 333-226943-05 and incorporated by reference herein).

4.6          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, Midland Loan Services, a Division of PNC Bank, NationalAssociation, as Special Servicer, Wells Fargo Bank, National Association, asCertificate Administrator, Wells Fargo Bank, National Association, as Trustee,and Pentalpha Surveillance LLC, as Operating Advisor and as AssetRepresentations Reviewer (filed as Exhibit 4.3 to the registrant’s Current Reporton Form 8-K filed on December 12, 2019 under Commission File No. 333-226943-05and incorporated by reference herein).

4.7          Co-Lender Agreement, dated as of October 21, 2019, by andbetween Deutsche Bank AG, New York Branch, as an Initial Note A Holder, WellsFargo Bank, National Association, as an Initial Note A Holder, Morgan StanleyBank, National Association, as an Initial Note A Holder, Deutsche Bank AG, NewYork Branch, as Initial Note B-1 Holder, Morgan Stanley Bank, NationalAssociation, as Initial Note B-2 Holder and Wells Fargo Bank, NationalAssociation,  as Initial Note B-3 Holder (filed as Exhibit 4.12 to theregistrant’s Current Report on Form 8-K filed on December 12, 2019 underCommission File No. 333-226943-05 and incorporated by reference herein).

4.8          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 4.8 tothe registrant’s Current Report on Form 8-K filed on December 12, 2019 underCommission File No. 333-226943-05 and incorporated by reference herein).

4.9          Agreement Between Noteholders, dated as of November 12,2019, by and among Goldman Sachs Bank USA, as Initial Note A-1 Holder, InitialNote A-2 Holder, Initial Note A-3 Holder, Initial Note A-4 Holder, Initial NoteA-5 Holder, Initial A-6 Holder, Initial Note A-7 Holder, Initial Note A-8Holder and Initial Note A-9 Holder (filed as Exhibit 4.9 to the registrant’sCurrent Report on Form 8-K filed on December 12, 2019 under Commission File No.333-226943-05 and incorporated by reference herein).

4.10        Agreement Between Noteholders, dated as of November 18,2019, by and between DBR Investments Co. Limited, as Initial Note A-1Holder,  DBR Investments Co. Limited, as Initial Note A-2 Holder, UBS AG,by and through its branch office at 1285 Avenue of the Americas, New York, NewYork, as Initial Note A-3 Holder, UBS AG, by and through its branch office at1285 Avenue of the Americas, New York, New York, as Initial Note A-4 Holder,DBR Investments Co. Limited, as Initial Note A-5 Holder, DBR Investments Co.Limited, as Initial Note A-6 Holder and DBR Investments Co. Limited, as InitialNote B Holder (filed as Exhibit 4.10 to the registrant’s Current Report on Form8-K filed on December 12, 2019 under Commission File No. 333-226943-05 andincorporated by reference herein).

4.11        Amended and Restated Agreement Between Noteholders, dated asof November 8, 2019, by and among Wilmington Trust, National Association, asTrustee, for the benefit of the registered holders of Citigroup CommercialMortgage Trust 2019-GC41, Commercial Mortgage Pass-Through Certificates, Series2019-GC41, as Note A-1 Holder, Wells Fargo Bank, National Association, asTrustee, for the benefit of the Registered Holders of GS Mortgage SecuritiesTrust 2019-GC42, Commercial Mortgage Pass-Through Certificates, Series2019-GC42, as Note A-2 Holder and Goldman Sachs Bank USA, as Initial Note A-3Holder, Initial Note A-4 Holder, Initial Note A-5 Holder, Initial Note A-6Holder, Initial Note A-7 Holder and Initial Note A-8 Holder (filed as Exhibit4.11 to the registrant’s Current Report on Form 8-K filed on December 12, 2019under Commission File No. 333-226943-05 and incorporated by reference herein).

4.12        Agreement Between Noteholders, dated as of November 12,2019, by and among Goldman Sachs Bank USA, as Initial Note A-1 Holder, InitialNote A-2 Holder, Initial Note A-3 Holder, Initial Note A-4 Holder, Initial NoteA-5 Holder, Initial A-6 Holder and Initial Note A-7 Holder (filed as Exhibit4.12 to the registrant’s Current Report on Form 8-K filed on December 12, 2019under Commission File No. 333-226943-05 and incorporated by reference herein).

4.13        Co-Lender Agreement, dated as of October 31, 2019, by andbetween Citi Real Estate Funding Inc., as Initial Note A-1 Holder and Citi RealEstate Funding Inc., as Initial Note A-2 Holder (filed as Exhibit 4.13 to theregistrant’s Current Report on Form 8-K filed on December 12, 2019 underCommission File No. 333-226943-05 and incorporated by reference herein).

4.14        Agreement Between Noteholders, dated as of November 1, 2019,by and among JPMorgan Chase Bank, National Association, as Initial Note A-1-1Holder, Initial Note A-1-2 Holder, Initial Note A-1-3 and Initial Note B-1-1Holder, and Goldman Sachs Bank USA, as Initial Note A-1-4 Holder and InitialNote B-1-2 Holder (filed as Exhibit 4.14 to the registrant’s Current Report onForm 8-K filed on December 12, 2019 under Commission File No. 333-226943-05 andincorporated by reference herein).

4.15        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 4.15 to the registrant’sCurrent Report on Form 8-K filed on December 12, 2019 under Commission File No.333-226943-05 and incorporated by reference herein).

4.16        Co-Lender Agreement, dated as of September 30, 2019, by andamong Wells Fargo Bank, National Association, as Initial Note Holder of NoteA-1-1, Note A-2-1, Note A-2-2, Note A-2-3 and Note B-1-1, Bank of America,N.A., as Initial Note Holder of Note A-1-2, Note A-2-4, Note A-2-5 and NoteB-1-2 and Goldman Sachs Bank USA, as Initial Note Holder of Note A-1-3, NoteA-2-6, Note A-2-7 and Note B-1-3 (filed as Exhibit 4.16 to the registrant’sCurrent Report on Form 8-K filed on December 12, 2019 under Commission File No.333-226943-05 and incorporated by reference herein).

4.17        Co-Lender Agreement, dated as of  November 12, 2019, byand between Citi Real Estate Funding Inc., as Initial Note A-1 Holder and CitiReal Estate Funding Inc., as Initial Note A-2 Holder (filed as Exhibit 4.17 tothe registrant’s Current Report on Form 8-K filed on December 12, 2019 underCommission File No. 333-226943-05 and incorporated by reference herein).

4.18        Agreement Between Noteholder, dated as of November 12, 2019,by and among Goldman Sachs Bank USA, as Initial Note A-1 Holder and InitialNote A-2 Holder (filed as Exhibit 4.18 to the registrant’s Current Report onForm 8-K filed on December 12, 2019 under Commission File No. 333-226943-05 andincorporated by reference herein).

4.19        Co-Lender Agreement, dated as of August 20, 2019, betweenCantor Commercial Real Estate Lending, L.P., as Note A-1 Holder, DBRInvestments Co. Limited, as Note A-2 Holder, DBR Investments Co. Limited, asNote A-3 Holder, DBR Investments Co. Limited, as Note A-4 Holder, DBRInvestments Co. Limited, as Note A-5 Holder and DBR Investments Co. Limited, asNote A-6 Holder (filed as Exhibit 4.19 to the registrant’s Current Report onForm 8-K filed on December 12, 2019 under Commission File No. 333-226943-05 andincorporated by reference herein).

4.20        Amended and Restated Agreement Between Noteholders, dated asof November 8, 2019, by and among Wilmington Trust, National Association, asTrustee, for the benefit of the registered holders of Citigroup CommercialMortgage Trust 2019-GC41, Commercial Mortgage Pass-Through Certificates, Series2019-GC41, as Note A-1 Holder, Wells Fargo Bank, National Association, asTrustee, for the benefit of the Registered Holders of GS Mortgage SecuritiesTrust 2019-GC42, Commercial Mortgage Pass-Through Certificates, Series2019-GC42, as Note A-2 Holder and Goldman Sachs Bank USA, as Initial Note A-3Holder, Initial Note A-4 Holder, Initial Note A-5 Holder, Initial Note A-6Holder and Initial Note A-7 Holder (filed as Exhibit 4.20 to the registrant’sCurrent Report on Form 8-K filed on December 12, 2019 under Commission File No.333-226943-05 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 Divisionof PNC Bank, National Association, as Master Servicer

33.2        Rialto Capital Advisors,LLC, as Special Servicer

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

33.4        Wells Fargo Bank, NationalAssociation, as Custodian

33.5        Park Bridge LenderServices LLC, as Operating Advisor

33.6        Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the 180Water Mortgage Loan (see Exhibit 33.1)

33.7        Rialto Capital Advisors,LLC, as Special Servicer of the 180 Water Mortgage Loan (see Exhibit 33.2)

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

33.9        Wells Fargo Bank, NationalAssociation, as Custodian of the 180 Water Mortgage Loan (see Exhibit 33.4)

33.10      Park Bridge LenderServices LLC, as Operating Advisor of the 180 Water Mortgage Loan (see Exhibit33.5)

33.11      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of The Shoppesat Blackstone Valley Mortgage Loan (see Exhibit 33.1)

33.12      Rialto Capital Advisors,LLC, as Special Servicer of The Shoppes at Blackstone Valley Mortgage Loan (seeExhibit 33.2)

33.13      Wells Fargo Bank, National Association, as Trustee of The Shoppes at BlackstoneValley Mortgage Loan (Omitted. See Explanatory Notes.)

33.14      Wells Fargo Bank, NationalAssociation, as Custodian of The Shoppes at Blackstone Valley Mortgage Loan(see Exhibit 33.4)

33.15      Park Bridge LenderServices LLC, as Operating Advisor of The Shoppes at Blackstone Valley MortgageLoan (see Exhibit 33.5)

33.16      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the ElstonRetail Collection Mortgage Loan (see Exhibit 33.1)

33.17      Rialto Capital Advisors,LLC, as Special Servicer of the Elston Retail Collection Mortgage Loan (seeExhibit 33.2)

33.18      Wells Fargo Bank, National Association, as Trustee of the Elston RetailCollection Mortgage Loan (Omitted. See Explanatory Notes.)

33.19      Wells Fargo Bank, NationalAssociation, as Custodian of the Elston Retail Collection Mortgage Loan (seeExhibit 33.4)

33.20      Park Bridge LenderServices LLC, as Operating Advisor of the Elston Retail Collection MortgageLoan (see Exhibit 33.5)

33.21      Midland Loan Services, a Divisionof PNC Bank, National Association, as Primary Servicer of the PCI PharmaPortfolio Mortgage Loan (see Exhibit 33.1)

33.22      Rialto Capital Advisors,LLC, as Special Servicer of the PCI Pharma Portfolio Mortgage Loan (see Exhibit33.2)

33.23      Wells Fargo Bank, National Association, as Trustee of the PCI Pharma PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.24      Wells Fargo Bank, NationalAssociation, as Custodian of the PCI Pharma Portfolio Mortgage Loan (seeExhibit 33.4)

33.25      Park Bridge LenderServices LLC, as Operating Advisor of the PCI Pharma Portfolio Mortgage Loan(see Exhibit 33.5)

33.26      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of theBroadcasting Square Mortgage Loan (see Exhibit 33.1)

33.27      Rialto Capital Advisors,LLC, as Special Servicer of the Broadcasting Square Mortgage Loan (see Exhibit33.2)

33.28      Wells Fargo Bank, National Association, as Trustee of the Broadcasting SquareMortgage Loan (Omitted. See Explanatory Notes.)

33.29      Wells Fargo Bank, NationalAssociation, as Custodian of the Broadcasting Square Mortgage Loan (see Exhibit33.4)

33.30      Park Bridge LenderServices LLC, as Operating Advisor of the Broadcasting Square Mortgage Loan (seeExhibit 33.5)

33.31      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the CobbPlace Mortgage Loan (see Exhibit 33.1)

33.32      Rialto Capital Advisors,LLC, as Special Servicer of the Cobb Place Mortgage Loan (see Exhibit 33.2)

33.33      Wells Fargo Bank, National Association, as Trustee of the Cobb Place MortgageLoan (Omitted. See Explanatory Notes.)

33.34      Wells Fargo Bank, NationalAssociation, as Custodian of the Cobb Place Mortgage Loan (see Exhibit 33.4)

33.35      Park Bridge LenderServices LLC, as Operating Advisor of the Cobb Place Mortgage Loan (see Exhibit33.5)

33.36      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the USAAOffice Portfolio Mortgage Loan (see Exhibit 33.1)

33.37      Rialto Capital Advisors,LLC, as Special Servicer of the USAA Office Portfolio Mortgage Loan (seeExhibit 33.2)

33.38      Wilmington Trust, National Association, as Trustee of the USAA Office PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.39      Citibank, N.A., asCustodian of the USAA Office Portfolio Mortgage Loan

33.40      Park Bridge LenderServices LLC, as Operating Advisor of the USAA Office Portfolio Mortgage Loan(see Exhibit 33.5)

33.41      U.S. Bank NationalAssociation, as Servicing Function Participant of the USAA Office PortfolioMortgage Loan

33.42      Midland Loan Services, a Divisionof PNC Bank, National Association, as Primary Servicer of the Millennium ParkPlaza Mortgage Loan (see Exhibit 33.1)

33.43      Rialto Capital Advisors,LLC, as Special Servicer of the Millennium Park Plaza Mortgage Loan (seeExhibit 33.2)

33.44      Wilmington Trust, National Association, as Trustee of the Millennium Park PlazaMortgage Loan (Omitted. See Explanatory Notes.)

33.45      Citibank, N.A., asCustodian of the Millennium Park Plaza Mortgage Loan (see Exhibit 33.39)

33.46      Park Bridge LenderServices LLC, as Operating Advisor of the Millennium Park Plaza Mortgage Loan(see Exhibit 33.5)

33.47      U.S. Bank NationalAssociation, as Servicing Function Participant of the Millennium Park PlazaMortgage Loan (see Exhibit 33.41)

33.48      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the WindCreek Leased Fee Mortgage Loan (see Exhibit 33.1)

33.49      CWCapital AssetManagement LLC, as Special Servicer of the Wind Creek Leased Fee Mortgage Loan

33.50      Wells Fargo Bank, National Association, as Trustee of the Wind Creek Leased FeeMortgage Loan (Omitted. See Explanatory Notes.)

33.51      Wells Fargo Bank, NationalAssociation, as Custodian of the Wind Creek Leased Fee Mortgage Loan (seeExhibit 33.4)

33.52      Park Bridge LenderServices LLC, as Operating Advisor of the Wind Creek Leased Fee Mortgage Loan(see Exhibit 33.5)

33.53      Wells Fargo Bank,National Association, as Primary Servicer of the Midtown Center Mortgage Loan

33.54      CWCapital AssetManagement LLC, as Special Servicer of the Midtown Center Mortgage Loan (seeExhibit 33.49)

33.55      Wilmington Trust, National Association, as Trustee of the Midtown CenterMortgage Loan (Omitted. See Explanatory Notes.)

33.56      Wells Fargo Bank, NationalAssociation, as Custodian of the Midtown Center Mortgage Loan (see Exhibit33.4)

33.57      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Midtown CenterMortgage Loan

33.58      National Tax Search, LLC,as Servicing Function Participant of the Midtown Center Mortgage Loan

33.59      Wells Fargo Bank,National Association, as Primary Servicer of the Century Plaza Towers MortgageLoan (see Exhibit 33.53)

33.60      CWCapital AssetManagement LLC, as Special Servicer of the Century Plaza Towers Mortgage Loan(see Exhibit 33.49)

33.61      Wilmington Trust, National Association, as Trustee of the Century Plaza TowersMortgage Loan (Omitted. See Explanatory Notes.)

33.62      Wells Fargo Bank, NationalAssociation, as Custodian of the Century Plaza Towers Mortgage Loan (seeExhibit 33.4)

33.63      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Century PlazaTowers Mortgage Loan (see Exhibit 33.57)

33.64      National Tax Search, LLC,as Servicing Function Participant of the Century Plaza Towers Mortgage Loan(see Exhibit 33.58)

33.65      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the 225 BushMortgage Loan (see Exhibit 33.1)

33.66      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the 225 BushMortgage Loan (see Exhibit 33.1)

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

33.68      Wells Fargo Bank, NationalAssociation, as Custodian of the 225 Bush Mortgage Loan (see Exhibit 33.4)

33.69      Pentalpha SurveillanceLLC, as Operating Advisor of the 225 Bush Mortgage Loan

33.70      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the Legendsat Village West Mortgage Loan (see Exhibit 33.1)

33.71      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the Legendsat Village West Mortgage Loan (see Exhibit 33.1)

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

33.73      Wells Fargo Bank, NationalAssociation, as Custodian of the Legends at Village West Mortgage Loan (seeExhibit 33.4)

33.74      Pentalpha SurveillanceLLC, as Operating Advisor of the Legends at Village West Mortgage Loan (seeExhibit 33.69)

33.75      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of The Essex Site2 Mortgage Loan (see Exhibit 33.1)

33.76      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of The EssexSite 2 Mortgage Loan (see Exhibit 33.1)

33.77      Wells Fargo Bank, National Association, as Trustee of The Essex Site 2 MortgageLoan (Omitted. See Explanatory Notes.)

33.78      Wells Fargo Bank, NationalAssociation, as Custodian of The Essex Site 2 Mortgage Loan (see Exhibit 33.4)

33.79      Pentalpha SurveillanceLLC, as Operating Advisor of The Essex Site 2 Mortgage Loan (see Exhibit 33.69)

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

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

34.2        Rialto Capital Advisors,LLC, as Special Servicer

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

34.4        Wells Fargo Bank, NationalAssociation, as Custodian

34.5        Park Bridge LenderServices LLC, as Operating Advisor

34.6        Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the 180Water Mortgage Loan (see Exhibit 34.1)

34.7        Rialto Capital Advisors,LLC, as Special Servicer of the 180 Water Mortgage Loan (see Exhibit 34.2)

34.8        Wells Fargo Bank, National Association, as Trustee of the 180 Water Mortgage Loan(Omitted. See Explanatory Notes.)

34.9        Wells Fargo Bank, NationalAssociation, as Custodian of the 180 Water Mortgage Loan (see Exhibit 34.4)

34.10      Park Bridge Lender ServicesLLC, as Operating Advisor of the 180 Water Mortgage Loan (see Exhibit 34.5)

34.11      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of The Shoppesat Blackstone Valley Mortgage Loan (see Exhibit 34.1)

34.12      Rialto Capital Advisors,LLC, as Special Servicer of The Shoppes at Blackstone Valley Mortgage Loan (seeExhibit 34.2)

34.13      Wells Fargo Bank, National Association, as Trustee of The Shoppes at BlackstoneValley Mortgage Loan (Omitted. See Explanatory Notes.)

34.14      Wells Fargo Bank, NationalAssociation, as Custodian of The Shoppes at Blackstone Valley Mortgage Loan(see Exhibit 34.4)

34.15      Park Bridge LenderServices LLC, as Operating Advisor of The Shoppes at Blackstone Valley MortgageLoan (see Exhibit 34.5)

34.16      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the ElstonRetail Collection Mortgage Loan (see Exhibit 34.1)

34.17      Rialto Capital Advisors,LLC, as Special Servicer of the Elston Retail Collection Mortgage Loan (seeExhibit 34.2)

34.18      Wells Fargo Bank, National Association, as Trustee of the Elston RetailCollection Mortgage Loan (Omitted. See Explanatory Notes.)

34.19      Wells Fargo Bank, NationalAssociation, as Custodian of the Elston Retail Collection Mortgage Loan (seeExhibit 34.4)

34.20      Park Bridge LenderServices LLC, as Operating Advisor of the Elston Retail Collection MortgageLoan (see Exhibit 34.5)

34.21      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the PCIPharma Portfolio Mortgage Loan (see Exhibit 34.1)

34.22      Rialto Capital Advisors, LLC,as Special Servicer of the PCI Pharma Portfolio Mortgage Loan (see Exhibit34.2)

34.23      Wells Fargo Bank, National Association, as Trustee of the PCI Pharma PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.24      Wells Fargo Bank, NationalAssociation, as Custodian of the PCI Pharma Portfolio Mortgage Loan (seeExhibit 34.4)

34.25      Park Bridge LenderServices LLC, as Operating Advisor of the PCI Pharma Portfolio Mortgage Loan(see Exhibit 34.5)

34.26      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of theBroadcasting Square Mortgage Loan (see Exhibit 34.1)

34.27      Rialto Capital Advisors,LLC, as Special Servicer of the Broadcasting Square Mortgage Loan (see Exhibit34.2)

34.28      Wells Fargo Bank, National Association, as Trustee of the Broadcasting SquareMortgage Loan (Omitted. See Explanatory Notes.)

34.29      Wells Fargo Bank, NationalAssociation, as Custodian of the Broadcasting Square Mortgage Loan (see Exhibit34.4)

34.30      Park Bridge LenderServices LLC, as Operating Advisor of the Broadcasting Square Mortgage Loan(see Exhibit 34.5)

34.31      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the CobbPlace Mortgage Loan (see Exhibit 34.1)

34.32      Rialto Capital Advisors,LLC, as Special Servicer of the Cobb Place Mortgage Loan (see Exhibit 34.2)

34.33      Wells Fargo Bank, National Association, as Trustee of the Cobb Place Mortgage Loan(Omitted. See Explanatory Notes.)

34.34      Wells Fargo Bank, NationalAssociation, as Custodian of the Cobb Place Mortgage Loan (see Exhibit 34.4)

34.35      Park Bridge Lender ServicesLLC, as Operating Advisor of the Cobb Place Mortgage Loan (see Exhibit 34.5)

34.36      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the USAAOffice Portfolio Mortgage Loan (see Exhibit 34.1)

34.37      Rialto Capital Advisors,LLC, as Special Servicer of the USAA Office Portfolio Mortgage Loan (seeExhibit 34.2)

34.38      Wilmington Trust, National Association, as Trustee of the USAA Office PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.39      Citibank, N.A., asCustodian of the USAA Office Portfolio Mortgage Loan

34.40      Park Bridge Lender ServicesLLC, as Operating Advisor of the USAA Office Portfolio Mortgage Loan (seeExhibit 34.5)

34.41      U.S. Bank NationalAssociation, as Servicing Function Participant of the USAA Office PortfolioMortgage Loan

34.42      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of theMillennium Park Plaza Mortgage Loan (see Exhibit 34.1)

34.43      Rialto Capital Advisors,LLC, as Special Servicer of the Millennium Park Plaza Mortgage Loan (seeExhibit 34.2)

34.44      Wilmington Trust, National Association, as Trustee of the Millennium Park PlazaMortgage Loan (Omitted. See Explanatory Notes.)

34.45      Citibank, N.A., asCustodian of the Millennium Park Plaza Mortgage Loan (see Exhibit 34.39)

34.46      Park Bridge LenderServices LLC, as Operating Advisor of the Millennium Park Plaza Mortgage Loan(see Exhibit 34.5)

34.47      U.S. Bank NationalAssociation, as Servicing Function Participant of the Millennium Park PlazaMortgage Loan (see Exhibit 34.41)

34.48      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the WindCreek Leased Fee Mortgage Loan (see Exhibit 34.1)

34.49      CWCapital AssetManagement LLC, as Special Servicer of the Wind Creek Leased Fee Mortgage Loan

34.50      Wells Fargo Bank, National Association, as Trustee of the Wind Creek Leased FeeMortgage Loan (Omitted. See Explanatory Notes.)

34.51      Wells Fargo Bank, NationalAssociation, as Custodian of the Wind Creek Leased Fee Mortgage Loan (seeExhibit 34.4)

34.52      Park Bridge LenderServices LLC, as Operating Advisor of the Wind Creek Leased Fee Mortgage Loan(see Exhibit 34.5)

34.53      Wells Fargo Bank,National Association, as Primary Servicer of the Midtown Center Mortgage Loan

34.54      CWCapital AssetManagement LLC, as Special Servicer of the Midtown Center Mortgage Loan (seeExhibit 34.49)

34.55      Wilmington Trust, National Association, as Trustee of the Midtown CenterMortgage Loan (Omitted. See Explanatory Notes.)

34.56      Wells Fargo Bank, NationalAssociation, as Custodian of the Midtown Center Mortgage Loan (see Exhibit34.4)

34.57      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Midtown CenterMortgage Loan

34.58      National Tax Search, LLC,as Servicing Function Participant of the Midtown Center Mortgage Loan

34.59      Wells Fargo Bank,National Association, as Primary Servicer of the Century Plaza Towers MortgageLoan (see Exhibit 34.53)

34.60      CWCapital AssetManagement LLC, as Special Servicer of the Century Plaza Towers Mortgage Loan(see Exhibit 34.49)

34.61      Wilmington Trust, National Association, as Trustee of the Century Plaza TowersMortgage Loan (Omitted. See Explanatory Notes.)

34.62      Wells Fargo Bank, NationalAssociation, as Custodian of the Century Plaza Towers Mortgage Loan (seeExhibit 34.4)

34.63      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Century PlazaTowers Mortgage Loan (see Exhibit 34.57)

34.64      National Tax Search, LLC,as Servicing Function Participant of the Century Plaza Towers Mortgage Loan(see Exhibit 34.58)

34.65      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the 225 BushMortgage Loan (see Exhibit 34.1)

34.66      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the 225 BushMortgage Loan (see Exhibit 34.1)

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

34.68      Wells Fargo Bank, NationalAssociation, as Custodian of the 225 Bush Mortgage Loan (see Exhibit 34.4)

34.69      Pentalpha SurveillanceLLC, as Operating Advisor of the 225 Bush Mortgage Loan

34.70      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the Legendsat Village West Mortgage Loan (see Exhibit 34.1)

34.71      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the Legendsat Village West Mortgage Loan (see Exhibit 34.1)

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

34.73      Wells Fargo Bank, NationalAssociation, as Custodian of the Legends at Village West Mortgage Loan (seeExhibit 34.4)

34.74      Pentalpha SurveillanceLLC, as Operating Advisor of the Legends at Village West Mortgage Loan (seeExhibit 34.69)

34.75      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of The EssexSite 2 Mortgage Loan (see Exhibit 34.1)

34.76      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of The EssexSite 2 Mortgage Loan (see Exhibit 34.1)

34.77      Wells Fargo Bank, National Association, as Trustee of The Essex Site 2 MortgageLoan (Omitted. See Explanatory Notes.)

34.78      Wells Fargo Bank, NationalAssociation, as Custodian of The Essex Site 2 Mortgage Loan (see Exhibit 34.4)

34.79      Pentalpha SurveillanceLLC, as Operating Advisor of The Essex Site 2 Mortgage Loan (see Exhibit 34.69)

35           Servicer compliance statements.

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

35.2        Rialto Capital Advisors,LLC, as Special Servicer

35.3        Wells Fargo Bank, NationalAssociation, as Certificate Administrator

35.4        Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the 180Water Mortgage Loan (see Exhibit 35.1)

35.5        Rialto Capital Advisors,LLC, as Special Servicer of the 180 Water Mortgage Loan (see Exhibit 35.2)

35.6        Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of The Shoppesat Blackstone Valley Mortgage Loan (see Exhibit 35.1)

35.7        Rialto Capital Advisors,LLC, as Special Servicer of The Shoppes at Blackstone Valley Mortgage Loan (seeExhibit 35.2)

35.8        Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the Elston RetailCollection Mortgage Loan (see Exhibit 35.1)

35.9        Rialto Capital Advisors,LLC, as Special Servicer of the Elston Retail Collection Mortgage Loan (seeExhibit 35.2)

35.10      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the PCIPharma Portfolio Mortgage Loan (see Exhibit 35.1)

35.11      Rialto Capital Advisors,LLC, as Special Servicer of the PCI Pharma Portfolio Mortgage Loan (see Exhibit35.2)

35.12      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of theBroadcasting Square Mortgage Loan (see Exhibit 35.1)

35.13      Rialto Capital Advisors,LLC, as Special Servicer of the Broadcasting Square Mortgage Loan (see Exhibit35.2)

35.14      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the CobbPlace Mortgage Loan (see Exhibit 35.1)

35.15      Rialto Capital Advisors,LLC, as Special Servicer of the Cobb Place Mortgage Loan (see Exhibit 35.2)

35.16      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the USAAOffice Portfolio Mortgage Loan (see Exhibit 35.1)

35.17      Rialto Capital Advisors,LLC, as Special Servicer of the USAA Office Portfolio Mortgage Loan (seeExhibit 35.2)

35.18      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the MillenniumPark Plaza Mortgage Loan (see Exhibit 35.1)

35.19      Rialto Capital Advisors,LLC, as Special Servicer of the Millennium Park Plaza Mortgage Loan (seeExhibit 35.2)

35.20      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the WindCreek Leased Fee Mortgage Loan (see Exhibit 35.1)

35.21      CWCapital AssetManagement LLC, as Special Servicer of the Wind Creek Leased Fee Mortgage Loan

35.22      Wells Fargo Bank,National Association, as Primary Servicer of the Midtown Center Mortgage Loan

35.23      CWCapital AssetManagement LLC, as Special Servicer of the Midtown Center Mortgage Loan (seeExhibit 35.21)

35.24      Wells Fargo Bank,National Association, as Primary Servicer of the Century Plaza Towers MortgageLoan (see Exhibit 35.22)

35.25      CWCapital AssetManagement LLC, as Special Servicer of the Century Plaza Towers Mortgage Loan(see Exhibit 35.21)

35.26      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the 225 BushMortgage Loan (see Exhibit 35.1)

35.27      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the 225 BushMortgage Loan (see Exhibit 35.1)

35.28      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the Legendsat Village West Mortgage Loan (see Exhibit 35.1)

35.29      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the Legendsat Village West Mortgage Loan (see Exhibit 35.1)

35.30      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of The EssexSite 2 Mortgage Loan (see Exhibit 35.1)

35.31      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of The EssexSite 2 Mortgage Loan (see Exhibit 35.1)

99.1        Mortgage Loan Purchase Agreement, dated and effectiveNovember 19, 2019, between Deutsche Mortgage & Asset Receiving Corporationand German American Capital Corporation (filed as Exhibit 99.1 to theregistrant’s Current Report on Form 8-K filed on December 12, 2019 underCommission File No. 333-226943-05 and incorporated by reference herein).

99.2        Mortgage Loan Purchase Agreement, dated and effectiveNovember 19, 2019, between Deutsche Mortgage & Asset Receiving Corporation andGoldman Sachs Mortgage Company (filed as Exhibit 99.2 to the registrant’sCurrent Report on Form 8-K filed on December 12, 2019 under Commission File No.333-226943-05 and incorporated by reference herein).

99.3        Mortgage Loan Purchase Agreement, dated and effectiveNovember 19, 2019, between Deutsche Mortgage & Asset Receiving Corporationand Citi Real Estate Funding Inc. (filed as Exhibit 99.3 to the registrant’sCurrent Report on Form 8-K filed on December 12, 2019 under Commission File No.333-226943-05 and incorporated by reference herein).

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

(c)    Not Applicable.

 

**SIGNATURES**

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

Deutsche Mortgage & AssetReceiving Corporation(Depositor)

/s/ HelaineM. Kaplan

Helaine M.Kaplan, President

(senior officer in charge ofsecuritization of the depositor)

Date: March 16, 2020

/s/ NatalieGrainger

Natalie Grainger, Director

Date: March 16, 2020