**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: 333-226486-11**

**Central Index Key Number of the issuing entity:0001791239**

**Wells Fargo Commercial MortgageTrust 2019-C54**

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

** **

**Central Index Key Number of the depositor: 0000850779**

**Wells Fargo Commercial MortgageSecurities, Inc.**

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

** **

**Central Index Key Number of the sponsor: 0000740906**

**Wells Fargo Bank, NationalAssociation**

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

** **

**Central Index Key Number of the sponsor: 0001624053**

**Argentic Real Estate Finance LLC**

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

** **

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

**LMF Commercial, LLC**

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

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

** **

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

**BSPRT CMBS Finance, LLC**

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

** **

**Central Index Key Number of the sponsor: 0001685185**

**UBS AG, acting through its branchlocated at 1285 Avenue of the Americas, New York, New York**

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

** **

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

**the issuing entity)** | **38-4128804**

**38-4128805**

**38-7235615**

**(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:**

**(704) 374-6161**

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 Interactive DataFile required to be submitted and posted pursuant to Rule 405 of Regulation S-T(Section 232.405 of this chapter) during the preceding 12 months (or for suchshorter period that the registrant was required to submit and post such 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 ifa smaller reporting company)                          Smaller reportingcompany                    o

                                                                                                                                                       Emerging growthcompany                    o

If an emerging growth company, indicate by check mark if theregistrant has elected not to use the extended transition period for complyingwith any new or revised financial accounting standards provided pursuant toSection 13(a) of the Exchange Act.  o

Indicate by check mark whether the registrant 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 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 Global Payments, Inc. Mortgage Loan andthe NMR Pharmacy Portfolio Mortgage Loan, which constituted approximately 2.9%and 2.6%, respectively, of the asset pool of the issuing entity as of itscut-off date, are each an asset of the issuing entity and are each part of aloan combination that includes the Global Payments, Inc. Mortgage Loan or theNMR Pharmacy Portfolio Mortgage Loan and one other *pari passu* loan, eachof which is not an asset of the issuing entity. These loan combinations,including the Global Payments, Inc. Mortgage Loan and the NMR PharmacyPortfolio Mortgage Loan, are being serviced and administered pursuant to thePooling and Servicing Agreement, which is incorporated by reference as Exhibit4.1 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 CIRE Equity Retail & IndustrialPortfolio Mortgage Loan, which constituted approximately 0.7% of the asset poolof the issuing entity as of its cut-off date.  The CIRE Equity Retail& Industrial Portfolio Mortgage Loan is an asset of the issuing entity andis part of a loan combination that includes the CIRE Equity Retail &Industrial Portfolio Mortgage Loan and seven other *pari passu* loans,which are not assets of the issuing entity. A *pari passu* portion of theloan combination was securitized in the Benchmark 2019-B12 Mortgage Trusttransaction, Commission File Number 333-228597-01 (the “Benchmark 2019-B12Transaction”). This loan combination, including the CIRE Equity Retail& Industrial Portfolio Mortgage Loan, is being serviced and administeredpursuant to the pooling and servicing agreement for the Benchmark 2019-B12Transaction, which is incorporated by reference as Exhibit 4.2 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 Tower at Burbank Mortgage Loan, which constitutedapproximately 3.7% of the asset pool of the issuing entity as of its cut-offdate.  The Tower at Burbank Mortgage Loan is an asset of the issuingentity and is part of a loan combination that includes The Tower at BurbankMortgage Loan and two other *pari passu* loans, which are not assets ofthe issuing entity. A *pari passu* portion of the loan combination wassecuritized in the BANK 2019-BNK20 transaction, Commission File Number333-227446-06 (the “BANK 2019-BNK20 Transaction”). This loan combination,including The Tower at Burbank Mortgage Loan, is being serviced andadministered pursuant to the pooling and servicing agreement for the BANK2019-BNK20 Transaction, which is incorporated by reference as Exhibit 4.3 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 Phoenix Industrial Portfolio II MortgageLoan, which constituted approximately 3.0% of the asset pool of the issuingentity as of its cut-off date.  The Phoenix Industrial Portfolio IIMortgage Loan is an asset of the issuing entity and is part of a loancombination that includes the Phoenix Industrial Portfolio II Mortgage Loan andfour other *pari passu* loans, which are not assets of the issuing entity.A *pari passu* portion of the loan combination was securitized in the UBSCommercial Mortgage Trust 2019-C17 transaction, Commission File Number333-227784-04 (the “UBS 2019-C17 Transaction”). This loan combination,including the Phoenix Industrial Portfolio II Mortgage Loan, is being servicedand administered pursuant to the pooling and servicing agreement for the UBS2019-C17 Transaction, which is incorporated by reference as Exhibit 4.4 to thisAnnual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Planet Self Storage Portfolio Mortgage Loan,which constituted approximately 3.7% of the asset pool of the issuing entity asof its cut-off date.  The Planet Self Storage Portfolio Mortgage Loan isan asset of the issuing entity and is part of a loan combination that includesthe Planet Self Storage Portfolio Mortgage Loan and two other *pari passu*loans, which are not assets of the issuing entity. A *pari passu* portionof the loan combination was securitized in the Wells Fargo Commercial MortgageTrust 2019-C53 transaction, Commission File Number 333-226486-09 (the “WFCM2019-C53 Transaction”). This loan combination, including the Planet SelfStorage Portfolio Mortgage Loan, is being serviced and administered pursuant tothe pooling and servicing agreement for the WFCM 2019-C53 Transaction, which isincorporated 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 Washington Avenue Portfolio Mortgage Loan,which constituted approximately 1.9% of the asset pool of the issuing entity asof its cut-off date.  The Washington Avenue Portfolio Mortgage Loan is anasset of the issuing entity and is part of a loan combination that includes theWashington Avenue Portfolio Mortgage Loan and one other *pari passu* loan,which is not an asset of the issuing entity. The other *pari passu*portion of the loan combination was securitized in the GS Mortgage SecuritiesTrust 2019-GSA1 transaction, Commission File Number 333-226082-05 (the “GSMS2019-GSA1 Transaction”). This loan combination, including the WashingtonAvenue Portfolio Mortgage Loan, is being serviced and administered pursuant tothe pooling and servicing agreement for the GSMS 2019-GSA1 Transaction, whichis incorporated by reference as Exhibit 4.6 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 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.

Wells Fargo Bank, NationalAssociation is the master servicer and certificate administrator of themortgage loans serviced under the Pooling and Servicing Agreement and theprimary servicer of the Planet Self Storage Portfolio Mortgage Loan, The Towerat Burbank Mortgage Loan and the Phoenix Industrial Portfolio II Mortgage Loan.As a result, Wells Fargo Bank, National Association is a “servicer” as definedin Item 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, thePlanet Self Storage Portfolio Mortgage Loan, The Tower at Burbank MortgageLoan, the Phoenix Industrial Portfolio II Mortgage Loan and the WashingtonAvenue Portfolio Mortgage Loan.  As a result, Wells Fargo Bank, NationalAssociation is a servicing function participant in the capacities describedabove, because it is servicing mortgage loans that constituted 5% or more ofthe assets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria and accountants’ attestationreports delivered by Wells Fargo Bank, National Association in the capacitiesdescribed above are listed in the Exhibit Index.

Argentic Services Company LP isthe special servicer of the mortgage loans serviced under the Pooling andServicing Agreement and the Washington Avenue Portfolio Mortgage Loan. As aresult, Argentic Services Company LP 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 Argentic Services Company LP in thecapacities 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, thePlanet Self Storage Portfolio Mortgage Loan, The Tower at Burbank Mortgage Loanand the Washington Avenue Portfolio Mortgage Loan.  As a result, ParkBridge Lender Services LLC is a servicing function participant in thecapacities described above, because it is servicing mortgage loans thatconstituted 5% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria andaccountants’ attestation reports delivered by Park Bridge Lender Services LLCin the capacities described above are listed in the Exhibit Index.

Midland Loan Services, a Divisionof PNC Bank, National Association is the special servicer of the Planet SelfStorage Portfolio Mortgage Loan and The Tower at Burbank Mortgage Loan, theprimary servicer of the Washington Avenue Portfolio Mortgage Loan and theprimary servicer and special servicer of the CIRE Equity Retail &Industrial Portfolio Mortgage Loan, which constituted approximately 3.7%, 3.7%,1.9% and 0.7%, respectively, of the asset pool of the issuing entity as of itscut-off date. In accordance with the Compliance and Disclosure Interpretations,Section 200.03 (Rules 13a-18 and 15d-18, Servicer’s Assessment of Compliance),this percentage must be reduced *pro rata*because it was only acting asspecial servicer of The Tower at Burbank Mortgage Loan from January 1, 2021 toJuly 12, 2021. As a result, it is an unaffiliated party that, as a result ofsuch *pro rata* reduction of such percentage, is not a “servicer” thatmeets the criteria in Item 1108(a)(2)(i) through (iii) of Regulation AB and sono servicer compliance statement is required.

Wells Fargo Bank, NationalAssociation acts as trustee of the Washington Avenue Portfolio MortgageLoan.  Pursuant to the pooling and servicing agreement for the GSMS2019-GSA1 Transaction, the trustee is required to provide an assessment ofcompliance with applicable servicing criteria solely with respect to Item1122(d)(2)(iii) of Regulation AB (regarding advances of funds or guaranteesregarding collections, cash flows or distributions, and any interest or otherfees charged for such advances, are made, reviewed and approved as specified inthe transaction agreements). However, during the reporting period, the trusteedid not perform any servicing function with respect to the servicing criteria specifiedin Item 1122(d)(2)(iii) of Regulation AB.  The master servicer or thespecial servicer, to the extent required, performed the servicing functionidentified with respect to Item 1122(d)(2)(iii) of Regulation AB, and each suchparty included Item 1122(d)(2)(iii) of Regulation AB in the assessment ofcompliance with applicable servicing criteria and accountant’s attestationreport for the subject transaction.  As a result, this Annual Report onForm 10-K does not include an assessment of compliance with applicableservicing criteria of the trustee. One or more other servicers of theWashington Avenue Portfolio Mortgage Loan have delivered one or moreassessments of compliance with respect to Item 1122(d)(2)(iii) of RegulationAB.

Wilmington Trust, NationalAssociation acts as trustee of  the mortgage loans serviced under thePooling and Servicing Agreement, the CIRE Equity Retail & IndustrialPortfolio Mortgage Loan, The Tower at Burbank Mortgage Loan, the PhoenixIndustrial Portfolio II Mortgage Loan and the Planet Self Storage PortfolioMortgage Loan.  Pursuant to the Pooling and Servicing Agreement, thepooling and servicing agreement for the Benchmark 2019-B12 Transaction, thepooling and servicing agreement for the BANK 2019-BNK20 Transaction, the poolingand servicing agreement for the UBS 2019-C17 Transaction and the pooling andservicing agreement for the WFCM 2019-C53 Transaction, the trustee is requiredto provide an assessment of compliance with applicable servicing criteriasolely with respect to Item 1122(d)(2)(iii) of Regulation AB (regardingadvances of funds or guarantees regarding collections, cash flows ordistributions, and any interest or other fees charged for such advances, aremade, reviewed and approved as specified in the transaction agreements).However, during the reporting period, the trustee did not perform any servicingfunction 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 mortgage loans servicedunder the Pooling and Servicing Agreement, the CIRE Equity Retail &Industrial Portfolio Mortgage Loan, The Tower at Burbank Mortgage Loan, thePhoenix Industrial Portfolio II Mortgage Loan and the Planet Self StoragePortfolio Mortgage Loan have delivered one or more assessments of compliancewith respect to Item 1122(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 master servicer under the Pooling and ServicingAgreement and the primary servicer of The Tower at Burbank Mortgage Loan, thePhoenix Industrial Portfolio II Mortgage Loan and the Planet Self StoragePortfolio Mortgage Loan to remit tax payments received from the escrow accountsof borrowers to local taxing authorities, to report tax amounts due, to verifytax parcel 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 from Computershare TrustCompany, National Association (“CTCNA”).  CTCNA was engaged byWells Fargo Bank, National Association (“Wells Fargo”), in its capacityas certificate administrator and custodian, to perform certain specifiedservicing functions identified in the assessment of compliance with applicableservicing criteria and accountants’ attestation reports.  Wells Fargoengaged CTCNA in connection with the sale of Wells Fargo’s corporate trustservices 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 Tower at Burbank Mortgage Loan, the Phoenix IndustrialPortfolio II Mortgage Loan, the Planet Self Storage Portfolio Mortgage Loan,the Washington Avenue Portfolio Mortgage Loan and the CIRE Equity Retail &Industrial Portfolio Mortgage Loan are omitted from this Annual Report on Form10-K as the certificate administrator pursuant to the related pooling andservicing 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.

With respect to the *pari passu*loan combinations that include the CIRE Equity Retail & Industrial PortfolioMortgage Loan, the Tower at Burbank Mortgage Loan, the Washington AvenuePortfolio Mortgage Loan, the Planet Self Storage Portfolio Mortgage Loan andthe Phoenix Industrial Portfolio II Mortgage Loan, (i) the reports onassessment of compliance with servicing criteria and attestation reports onassessment of compliance with servicing criteria of Citibank, N.A. as custodianof the CIRE Equity Retail & Industrial Portfolio Mortgage Loan, PentalphaSurveillance LLC as operating advisor of the CIRE Equity Retail &Industrial Portfolio Mortgage Loan and the Phoenix Industrial Portfolio IIMortgage Loan, Rialto Capital Advisors, LLC as special servicer of the PhoenixIndustrial Portfolio II Mortgage Loan and LNR Partners, LLC as special servicerof the Tower at Burbank Mortgage Loan on and after July 13, 2021, listed on theExhibit Index are omitted from this Annual Report on Form 10-K as they are notrequired to be included on this Annual Report on Form 10-K per Instruction 3 toItem 1122 of Regulation AB because they are parties performing activities thataddress servicing criteria relating to 5% or less of the assets of the issuingentity; and (ii) the servicer compliance statements of Rialto Capital Advisors,LLC as special servicer of the Phoenix Industrial Portfolio II Mortgage Loanand LNR Partners, LLC as special servicer of the Tower at Burbank Mortgage Loanon and after July 13, 2021, listed on the Exhibit Index are omitted from thisAnnual Report on Form 10-K as they are not required by Item 1123 of RegulationAB to be included on this Annual Report on Form 10-K because they are each anunaffiliated party that is not a “servicer” that meets the criteria in Item1108(a)(2)(i) through (iii) of Regulation AB, and the servicer compliancestatement of Midland Loan Services, a Division of PNC Bank, NationalAssociation is the special servicer of the Planet Self Storage PortfolioMortgage Loan and The Tower at Burbank Mortgage Loan prior to July 13, 2021,the primary servicer of the Washington Avenue Portfolio Mortgage Loan and theprimary servicer and special servicer of the CIRE Equity Retail &Industrial Portfolio Mortgage Loan listed on the Exhibit Index is omitted fromthis Annual Report on From 10-K for the reasons set forth in the ExplanatoryNotes above.

**PART I**

**Item 1.  Business.**

Omitted.

**Item 1A.  Risk Factors.**

Omitted.

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

None.

**Item 2.  Properties.**

Omitted.

**Item 3.  Legal Proceedings.**

Omitted.

**Item 4.  Mine Safety Disclosures.**

Not applicable.

**PART II**

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

Omitted.

**Item 6.  Selected Financial Data.**

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**Item 9B.  Other Information.**

None.

**PART III**

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

Omitted.

**Item 11.  Executive Compensation.**

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**ADDITIONAL DISCLOSURE ITEMS FOR REGULATION AB**

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

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

 

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

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

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

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

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

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

 

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 December 3, 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 CIRE Equity Retail &Industrial Portfolio Mortgage Loan, which is being serviced and administeredpursuant to the pooling and servicing agreement for the Benchmark 2019-B12Transaction, are attached hereto under Item 15 to this Annual Report on Form10-K. Attached as Exhibit O to the pooling and servicing agreement for theBenchmark 2019-B12 Transaction incorporated by reference as Exhibit 4.2 to thisAnnual Report on Form 10-K is a chart identifying the entities participating ina servicing function for the Benchmark 2019-B12 Transaction responsible foreach applicable servicing criteria set forth 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 Tower at Burbank Mortgage Loan, which isbeing serviced and administered pursuant to the pooling and servicing agreementfor the BANK 2019-BNK20 Transaction, are attached hereto under Item 15 to thisAnnual Report on Form 10-K. Attached as Exhibit Z to the pooling and servicingagreement for the BANK 2019-BNK20 Transaction incorporated by reference asExhibit 4.3 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the BANK 2019-BNK20Transaction 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 Phoenix Industrial Portfolio IIMortgage 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 servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Planet Self Storage PortfolioMortgage Loan, which is being serviced and administered pursuant to the poolingand servicing agreement for the WFCM 2019-C53 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit AA to thepooling and servicing agreement for the WFCM 2019-C53 Transaction incorporatedby reference as Exhibit 4.5 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the WFCM2019-C53 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 Washington Avenue PortfolioMortgage Loan, which is being serviced and administered pursuant to the poolingand servicing agreement for the GSMS 2019-GSA1 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit AA to thepooling and servicing agreement for the GSMS 2019-GSA1 Transaction incorporatedby reference as Exhibit 4.6 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the GSMS2019-GSA1 Transaction responsible for each applicable servicing criteria setforth 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 of thisAnnual Report on Form 10-K:

(1) Not applicable

(2) Not applicable

(3) See below

4.1          Poolingand Servicing Agreement, dated as of December 1, 2019, by and among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, LNR Partners, LLC, as Special Servicer, WellsFargo Bank, National Association, as Certificate Administrator, WilmingtonTrust, National Association, as Trustee, and Park Bridge Lender Services LLC,as Operating Advisor and as Asset Representations Reviewer (filed as Exhibit4.1 to the registrant’s Current Report on Form 8-K filed on December 3, 2019under Commission File No. 333-226486-11 and incorporated by reference herein). 

4.2          Poolingand Servicing Agreement, dated as of August 1, 2019, between the CitigroupCommercial Mortgage Securities Inc., as Depositor, Midland Loan Services, aDivision of PNC Bank, National Association, as Master Servicer, Midland LoanServices, a Division of PNC Bank, National Association, as a Special Servicer,Pacific Life Insurance Company, solely with respect to the Woodlands Mall LoanCombination, as a Special Servicer, Trimont Real Estate Advisors, LLC, solelywith respect to The Centre Loan Combination, as a Special Servicer, PentalphaSurveillance LLC, as Operating Advisor and Asset Representations Reviewer,Citibank, N.A., as Certificate Administrator, and Wilmington Trust, NationalAssociation, as Trustee (filed as Exhibit 4.6 to the registrant’s CurrentReport on Form 8-K filed on December 3, 2019 under Commission File No.333-226486-11 and incorporated by reference herein).

4.3          Poolingand Servicing Agreement, dated as of September 1, 2019, between Morgan StanleyCapital I Inc., as Depositor, Wells Fargo Bank, National Association, asGeneral Master Servicer, Midland Loan Services, a Division of PNC Bank,National Association, as General Special Servicer, National Cooperative Bank,N.A., as NCB Master Servicer and as NCB Special Servicer, Wells Fargo Bank,National Association, as Certificate Administrator, Wilmington Trust, NationalAssociation, as Trustee, and Park Bridge Lender Services LLC, as OperatingAdvisor and as Asset Representations Reviewer (filed as Exhibit 4.2 to theregistrant’s Current Report on Form 8-K filed on December 3, 2019 underCommission File No. 333-226486-11 and incorporated by reference herein).

4.4          Poolingand Servicing Agreement, dated as of October 1, 2019, by and among UBSCommercial Mortgage Securitization Corp., as Depositor, Wells Fargo Bank,National Association, as Master Servicer, Rialto Capital Advisors, LLC, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Pentalpha SurveillanceLLC, as Operating Advisor and as Asset Representations Reviewer (filed asExhibit 4.4 to the registrant’s Current Report on Form 8-K filed on December 3,2019 under Commission File No. 333-226486-11 and incorporated by referenceherein).

4.5          Poolingand Servicing Agreement, dated as of November 1, 2019, among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator, Wilmington Trust, 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 December 3, 2019 underCommission File No. 333-226486-11 and incorporated by reference herein).

4.6          Poolingand Servicing Agreement, dated as of November 1, 2019, by and among GS MortgageSecurities Corporation II, as Depositor, Midland Loan Services, a Division ofPNC Bank, National Association, as Master Servicer, LNR Partners, LLC, asSpecial Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator and as Trustee, and Park Bridge Lender Services LLC, as OperatingAdvisor and as Asset Representations Reviewer (filed as Exhibit 4.5 to theregistrant’s Current Report on Form 8-K filed on December 3, 2019 underCommission File No. 333-226486-11 and incorporated by reference herein).

4.7          AgreementBetween Note Holders, dated as of September 26, 2019, by and between WellsFargo Bank, National Association, as Initial Note A-1 Holder, Wells Fargo Bank,National Association, as Initial Note A-2 Holder and Wells Fargo Bank, NationalAssociation, as Initial Note A-3 Holder (filed as Exhibit 4.7 to theregistrant’s Current Report on Form 8-K filed on December 3, 2019 underCommission File No. 333-226486-11 and incorporated by reference herein).

4.8          Co-LenderAgreement, dated as of September 26, 2019, between Rialto Mortgage Finance,LLC, as Note A-1 Holder, Rialto Mortgage Finance, LLC, as Note A-2 Holder,Rialto Mortgage Finance, LLC, as Note A-3 Holder, and Rialto Mortgage Finance,LLC, as Note A-4 Holder (filed as Exhibit 4.8 to the registrant’s CurrentReport on Form 8-K filed on December 3, 2019 under Commission File No.333-226486-11 and incorporated by reference herein).

4.9          AgreementBetween Note Holders, dated as of October 15, 2019, by and between UBS AG, byand through its branch office at 1285 Avenue of the Americas, New York, NewYork, as Initial Note A-1 Holder, Initial Note A-2 Holder, Initial Note A-3Holder, Initial Note A-4 Holder, Initial Note A-5 Holder and Initial Note A-6Holder (filed as Exhibit 4.9 to the registrant’s Current Report on Form 8-K filedon December 3, 2019 under Commission File No. 333-226486-11 and incorporated byreference herein).

4.10        Co-LenderAgreement, dated as of November 25, 2019, by and between, BSPRT FinanceSub-Lender I, LLC, as Note A-1 Holder and BSPRT Finance Sub-Lender I, LLC, asNote A-2 Holder (filed as Exhibit 4.10 to the registrant’s Current Report onForm 8-K filed on December 3, 2019 under Commission File No. 333-226486-11 andincorporated by reference herein).

4.11        Co-LenderAgreement, dated as of November 26, 2019, by and between, BSPRT CMBS Finance,LLC, as Note A-1 Holder and BSPRT CMBS Finance, LLC, as Note A-2 Holder (filedas Exhibit 4.11 to the registrant’s Current Report on Form 8-K filed onDecember 3, 2019 under Commission File No. 333-226486-11 and incorporated byreference herein).

4.12        Co-LenderAgreement, dated as of October 4, 2019, by and between SPREF WH III LLC, asInitial A-1 Holder and SPREF WH III LLC, as Initial Note A-2 Holder (filed asExhibit 4.12 to the registrant’s Current Report on Form 8-K filed on December3, 2019 under Commission File No. 333-226486-11 and incorporated by referenceherein).

4.13        AgreementBetween Noteholders, dated as of July 11, 2019, by and between Deutsche BankAG, New York Branch, as Initial Note A-1 Holder, Deutsche Bank AG, New YorkBranch, as Initial Note A-2 Holder, Deutsche Bank AG, New York Branch, 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, UBS AG,by and through its branch office at 1285 Avenue of the Americas, New York, NewYork, as Initial Note A-5 Holder, and UBS AG, by and through its branch officeat 1285 Avenue of the Americas, New York, New York, as Initial Note A-6 Holder(filed as Exhibit 4.13 to the registrant’s Current Report on Form 8-K filed onDecember 3, 2019 under Commission File No. 333-226486-11 and incorporated byreference herein).

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

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

33.1        Wells Fargo Bank, National Association, as MasterServicer

33.2        Argentic Services Company LP, as Special Servicer

33.3        Wilmington Trust, National Association, as Trustee (Omitted. See ExplanatoryNotes.)

33.4        Wells Fargo Bank, National Association, asCertificate Administrator

33.5        Wells Fargo Bank, National Association, asCustodian

33.6        Park Bridge Lender Services LLC, as OperatingAdvisor

33.7        CoreLogic Solutions, LLC, as Servicing FunctionParticipant

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

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

33.10      Wells Fargo Bank, National Association, as PrimaryServicer of the Global Payments, Inc. Mortgage Loan (see Exhibit 33.1)

33.11      Argentic Services Company LP, as Special Servicerof the Global Payments, Inc. Mortgage Loan (see Exhibit 33.2)

33.12      Wilmington Trust, National Association, as Trustee of the Global Payments, Inc.Mortgage Loan (Omitted. See Explanatory Notes.)

33.13      Wells Fargo Bank, National Association, asCustodian of the Global Payments, Inc. Mortgage Loan (see Exhibit 33.5)

33.14      Park Bridge Lender Services LLC, as OperatingAdvisor of the Global Payments, Inc. Mortgage Loan (see Exhibit 33.6)

33.15      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Global Payments, Inc. Mortgage Loan (see Exhibit 33.7)

33.16      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.17      Wells Fargo Bank, National Association, as PrimaryServicer of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 33.1)

33.18      Argentic Services Company LP, as Special Servicerof the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 33.2)

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

33.20      Wells Fargo Bank, National Association, asCustodian of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 33.5)

33.21      Park Bridge Lender Services LLC, as OperatingAdvisor of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 33.6)

33.22      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 33.7)

33.23      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.24      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the CIRE Equity Retail &Industrial Portfolio Mortgage Loan

33.25      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the CIRE Equity Retail &Industrial Portfolio Mortgage Loan (see Exhibit 33.24)

33.26      Wilmington Trust, National Association, as Trustee of the CIRE Equity Retail& Industrial Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.27      Citibank, N.A., as Custodian of the CIRE Equity Retail & IndustrialPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.28      Pentalpha Surveillance LLC, as Operating Advisor of the CIRE Equity Retail& Industrial Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.29      Wells Fargo Bank, National Association, as PrimaryServicer of The Tower at Burbank Mortgage Loan (see Exhibit 33.1)

33.30      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of The Tower at Burbank Mortgage Loanprior to July 13, 2021 (see Exhibit 33.24)

33.31      LNR Partners, LLC, as Special Servicer of The Tower at Burbank Mortgage Loan onand after July 13, 2021 (Omitted. See Explanatory Notes.)

33.32      Wilmington Trust, National Association, as Trustee of The Tower at BurbankMortgage Loan (Omitted. See Explanatory Notes.)

33.33      Wells Fargo Bank, National Association, asCustodian of The Tower at Burbank Mortgage Loan (see Exhibit 33.5)

33.34      Park Bridge Lender Services LLC, as OperatingAdvisor of The Tower at Burbank Mortgage Loan (see Exhibit 33.6)

33.35      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of The Tower at Burbank Mortgage Loan (see Exhibit 33.7)

33.36      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.37      Wells Fargo Bank, National Association, as PrimaryServicer of the Phoenix Industrial Portfolio II Mortgage Loan (see Exhibit33.1)

33.38      Rialto Capital Advisors, LLC, as Special Servicer of the Phoenix IndustrialPortfolio II Mortgage Loan (Omitted. See Explanatory Notes.)

33.39      Wilmington Trust, National Association, as Trustee of the Phoenix IndustrialPortfolio II Mortgage Loan (Omitted. See Explanatory Notes.)

33.40      Wells Fargo Bank, National Association, asCustodian of the Phoenix Industrial Portfolio II Mortgage Loan (see Exhibit33.5)

33.41      Pentalpha Surveillance LLC, as Operating Advisor of the Phoenix IndustrialPortfolio II Mortgage Loan (Omitted. See Explanatory Notes.)

33.42      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Phoenix Industrial Portfolio II Mortgage Loan (see Exhibit33.7)

33.43      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.44      Wells Fargo Bank, National Association, as PrimaryServicer of the Planet Self Storage Portfolio Mortgage Loan (see Exhibit 33.1)

33.45      Midland Loan Services, a Division of PNC Bank, NationalAssociation, as Special Servicer of the Planet Self Storage Portfolio MortgageLoan (see Exhibit 33.24)

33.46      Wilmington Trust, National Association, as Trustee of the Planet Self StoragePortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.47      Wells Fargo Bank, National Association, asCustodian of the Planet Self Storage Portfolio Mortgage Loan (see Exhibit 33.5)

33.48      Park Bridge Lender Services LLC, as OperatingAdvisor of the Planet Self Storage Portfolio Mortgage Loan (see Exhibit 33.6)

33.49      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Planet Self Storage Portfolio Mortgage Loan (see Exhibit33.7)

33.50      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.51      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Washington Avenue PortfolioMortgage Loan (see Exhibit 33.24)

33.52      Argentic Services Company LP, as Special Servicerof the Washington Avenue Portfolio Mortgage Loan (see Exhibit 33.2)

33.53      Wells Fargo Bank, National Association, as Trustee of the Washington AvenuePortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.54      Wells Fargo Bank, National Association, asCustodian of the Washington Avenue Portfolio Mortgage Loan (see Exhibit 33.5)

33.55      Park Bridge Lender Services LLC, as OperatingAdvisor of the Washington Avenue Portfolio Mortgage Loan (see Exhibit 33.6)

33.56      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

34           Attestation reportson assessment of compliance with servicing criteria for asset-backedsecurities.

34.1        Wells Fargo Bank, National Association, as MasterServicer

34.2        Argentic Services Company LP, as Special Servicer

34.3        Wilmington Trust, National Association, as Trustee (Omitted. See ExplanatoryNotes.)

34.4        Wells Fargo Bank, National Association, asCertificate Administrator

34.5        Wells Fargo Bank, National Association, asCustodian

34.6        Park Bridge Lender Services LLC, as OperatingAdvisor

34.7        CoreLogic Solutions, LLC, as Servicing FunctionParticipant

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

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

34.10      Wells Fargo Bank, National Association, as PrimaryServicer of the Global Payments, Inc. Mortgage Loan (see Exhibit 34.1)

34.11      Argentic Services Company LP, as Special Servicerof the Global Payments, Inc. Mortgage Loan (see Exhibit 34.2)

34.12      Wilmington Trust, National Association, as Trustee of the Global Payments, Inc.Mortgage Loan (Omitted. See Explanatory Notes.)

34.13      Wells Fargo Bank, National Association, asCustodian of the Global Payments, Inc. Mortgage Loan (see Exhibit 34.5)

34.14      Park Bridge Lender Services LLC, as OperatingAdvisor of the Global Payments, Inc. Mortgage Loan (see Exhibit 34.6)

34.15      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Global Payments, Inc. Mortgage Loan (see Exhibit 34.7)

34.16      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

34.17      Wells Fargo Bank, National Association, as PrimaryServicer of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 34.1)

34.18      Argentic Services Company LP, as Special Servicerof the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 34.2)

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

34.20      Wells Fargo Bank, National Association, asCustodian of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 34.5)

34.21      Park Bridge Lender Services LLC, as OperatingAdvisor of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 34.6)

34.22      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 34.7)

34.23      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

34.24      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the CIRE Equity Retail &Industrial Portfolio Mortgage Loan

34.25      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the CIRE Equity Retail &Industrial Portfolio Mortgage Loan (see Exhibit 34.24)

34.26      Wilmington Trust, National Association, as Trustee of the CIRE Equity Retail& Industrial Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.27      Citibank, N.A., as Custodian of the CIRE Equity Retail & IndustrialPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.28      Pentalpha Surveillance LLC, as Operating Advisor of the CIRE Equity Retail& Industrial Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.29      Wells Fargo Bank, National Association, as PrimaryServicer of The Tower at Burbank Mortgage Loan (see Exhibit 34.1)

34.30      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of The Tower at Burbank Mortgage Loanprior to July 13, 2021 (see Exhibit 34.24)

34.31      LNR Partners, LLC, as Special Servicer of The Tower at Burbank Mortgage Loan onand after July 13, 2021 (Omitted. See Explanatory Notes.)

34.32      Wilmington Trust, National Association, as Trustee of The Tower at BurbankMortgage Loan (Omitted. See Explanatory Notes.)

34.33      Wells Fargo Bank, National Association, asCustodian of The Tower at Burbank Mortgage Loan (see Exhibit 34.5)

34.34      Park Bridge Lender Services LLC, as OperatingAdvisor of The Tower at Burbank Mortgage Loan (see Exhibit 34.6)

34.35      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of The Tower at Burbank Mortgage Loan (see Exhibit 34.7)

34.36      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

34.37      Wells Fargo Bank, National Association, as PrimaryServicer of the Phoenix Industrial Portfolio II Mortgage Loan (see Exhibit34.1)

34.38      Rialto Capital Advisors, LLC, as Special Servicer of the Phoenix IndustrialPortfolio II Mortgage Loan (Omitted. See Explanatory Notes.)

34.39      Wilmington Trust, National Association, as Trustee of the Phoenix IndustrialPortfolio II Mortgage Loan (Omitted. See Explanatory Notes.)

34.40      Wells Fargo Bank, National Association, asCustodian of the Phoenix Industrial Portfolio II Mortgage Loan (see Exhibit34.5)

34.41      Pentalpha Surveillance LLC, as Operating Advisor of the Phoenix IndustrialPortfolio II Mortgage Loan (Omitted. See Explanatory Notes.)

34.42      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Phoenix Industrial Portfolio II Mortgage Loan (see Exhibit34.7)

34.43      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

34.44      Wells Fargo Bank, National Association, as PrimaryServicer of the Planet Self Storage Portfolio Mortgage Loan (see Exhibit 34.1)

34.45      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Planet Self Storage PortfolioMortgage Loan (see Exhibit 34.24)

34.46      Wilmington Trust, National Association, as Trustee of the Planet Self StoragePortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.47      Wells Fargo Bank, National Association, asCustodian of the Planet Self Storage Portfolio Mortgage Loan (see Exhibit 34.5)

34.48      Park Bridge Lender Services LLC, as OperatingAdvisor of the Planet Self Storage Portfolio Mortgage Loan (see Exhibit 34.6)

34.49      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Planet Self Storage Portfolio Mortgage Loan (see Exhibit34.7)

34.50      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

34.51      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Washington Avenue PortfolioMortgage Loan (see Exhibit 34.24)

34.52      Argentic Services Company LP, as Special Servicerof the Washington Avenue Portfolio Mortgage Loan (see Exhibit 34.2)

34.53      Wells Fargo Bank, National Association, as Trustee of the Washington AvenuePortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.54      Wells Fargo Bank, National Association, asCustodian of the Washington Avenue Portfolio Mortgage Loan (see Exhibit 34.5)

34.55      Park Bridge Lender Services LLC, as OperatingAdvisor of the Washington Avenue Portfolio Mortgage Loan (see Exhibit 34.6)

34.56      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

35           Servicer compliance statements.

35.1        Wells Fargo Bank, National Association, as MasterServicer

35.2        Argentic Services Company LP, as Special Servicer

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        Wells Fargo Bank, National Association, as PrimaryServicer of the Global Payments, Inc. Mortgage Loan (see Exhibit 35.1)

35.6        Argentic Services Company LP, as Special Servicerof the Global Payments, Inc. Mortgage Loan (see Exhibit 35.2)

35.7        Wells Fargo Bank, National Association, as Primary Servicerof the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 35.1)

35.8        Argentic Services Company LP, as Special Servicerof the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 35.2)

35.9        Midland Loan Services, a Division of PNC Bank, National Association, as PrimaryServicer of the CIRE Equity Retail & Industrial Portfolio Mortgage Loan(Omitted. See Explanatory Notes.)

35.10      Midland Loan Services, a Division of PNC Bank, National Association, as SpecialServicer of the CIRE Equity Retail & Industrial Portfolio Mortgage Loan(Omitted. See Explanatory Notes.)

35.11      Wells Fargo Bank, National Association, as PrimaryServicer of The Tower at Burbank Mortgage Loan (see Exhibit 35.1)

35.12      Midland Loan Services, a Division of PNC Bank, National Association, as SpecialServicer of The Tower at Burbank Mortgage Loan prior to July 13, 2021 (Omitted.See Explanatory Notes.)

35.13      LNR Partners, LLC, as Special Servicer of The Tower at Burbank Mortgage Loan onand after July 13, 2021 (Omitted. See Explanatory Notes.)

35.14      Wells Fargo Bank, National Association, as PrimaryServicer of the Phoenix Industrial Portfolio II Mortgage Loan (see Exhibit35.1)

35.15      Rialto Capital Advisors, LLC, as Special Servicer of the Phoenix IndustrialPortfolio II Mortgage Loan (Omitted. See Explanatory Notes.)

35.16      Wells Fargo Bank, National Association, as PrimaryServicer of the Planet Self Storage Portfolio Mortgage Loan (see Exhibit 35.1)

35.17      Midland Loan Services, a Division of PNC Bank, National Association, as SpecialServicer of the Planet Self Storage Portfolio Mortgage Loan (Omitted. SeeExplanatory Notes.)

35.18      Midland Loan Services, a Division of PNC Bank, National Association, as PrimaryServicer of the Washington Avenue Portfolio Mortgage Loan  (Omitted. SeeExplanatory Notes.)

35.19      Argentic Services Company LP, as Special Servicerof the Washington Avenue Portfolio Mortgage Loan (see Exhibit 35.2)

99.1        MortgageLoan Purchase Agreement, dated as of November 8, 2019, between Wells FargoCommercial Mortgage Securities, Inc. and Wells Fargo Bank, National Association(filed as Exhibit 99.1 to the registrant’s Current Report on Form 8-K filed onDecember 3, 2019 under Commission File No. 333-226486-11 and incorporated byreference herein)

99.2        MortgageLoan Purchase Agreement, dated as of November 8, 2019, between Wells FargoCommercial Mortgage Securities, Inc. and Argentic Real Estate Finance LLC(filed as Exhibit 99.3 to the registrant’s Current Report on Form 8-K filed onDecember 3, 2019 under Commission File No. 333-226486-11 and incorporated byreference herein)

99.3        MortgageLoan Purchase Agreement, dated as of November 8, 2019, between Wells FargoCommercial Mortgage Securities, Inc. and Rialto Mortgage Finance, LLC (filed asExhibit 99.2 to the registrant’s Current Report on Form 8-K filed on December3, 2019 under Commission File No. 333-226486-11 and incorporated by referenceherein)

99.4        MortgageLoan Purchase Agreement, dated as of November 8, 2019, between Wells FargoCommercial Mortgage Securities, Inc., BSPRT CMBS Finance, LLC and BenefitStreet Partners Realty Trust, Inc. (filed as Exhibit 99.4 to the registrant’sCurrent Report on Form 8-K filed on December 3, 2019 under Commission File No.333-226486-11 and incorporated by reference herein)

99.5        MortgageLoan Purchase Agreement, dated as of November 8, 2019, between Wells FargoCommercial Mortgage Securities, Inc. and UBS AG, acting through its branchlocated at 1285 Avenue of the Americas, New York, New York (filed as Exhibit99.5 to the registrant’s Current Report on Form 8-K filed on December 3, 2019under Commission File No. 333-226486-11 and incorporated by reference herein)

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

(c)    Not Applicable.

 

**SIGNATURES**

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

Wells Fargo Commercial MortgageSecurities, Inc.(Depositor)

/s/ AnthonySfarra

AnthonySfarra, President

(senior officer in charge ofsecuritization of the depositor)

Date: March 14, 2022