**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: 333-226850-03**

**Central Index Key Number of the issuing entity:0001780131**

**BBCMS Mortgage Trust 2019-C4**

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

** **

**Central Index Key Number of the depositor: 0001541480**

**Barclays Commercial MortgageSecurities LLC**

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

** **

**Central Index Key Number of the sponsor: 0001549574**

**Barclays Capital Real Estate Inc.**

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

** **

**Central Index Key Number of the sponsor: 0001755531**

**Societe Generale FinancialCorporation**

**(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)**

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**Central Index Key Number of the sponsor: 0001548405**

**Starwood Mortgage Capital LLC**

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

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**Central Index Key Number of the sponsor: 0001654834**

**Rialto Real Estate Fund III – Debt,LP**

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

** **

**Central Index Key Number of the sponsor: 0001548567**

**CIBC Inc.**

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

** **

**Central Index Key Number of the sponsor: 0001542256**

**Natixis Real Estate Capital LLC**

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

** **

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

**the issuing entity)** | **38-4123641**

**38-4123642**

**38-7221351**

**(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) 412-4000**

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 toSection 12(g) of the Act:  None.

Indicate by check mark if the registrantis a well-known seasoned issuer, as defined in Rule 405 of the SecuritiesAct.  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 by referencein Part III of this Form 10-K or any amendment to this Form 10-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 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 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 by referenceand the Part of the Form 10-K (e.g., Part I, Part II, etc.) into which thedocument is incorporated: (1) Any annual report to security holders; (2) Anyproxy or information statement; and (3) Any prospectus filed pursuant to Rule424(b) or (c) under the Securities Act of 1933. The listed documents should beclearly described for identification purposes (e.g., annual report to securityholders for fiscal year ended December 24, 1980).

Not applicable.

 

** **

**EXPLANATORY**NOTES

The 188 Spear Street Mortgage Loan, theExchangeRight Net Leased Portfolio 28 Mortgage Loan, the Meidinger TowerMortgage Loan, the Maui Portfolio Mortgage Loan and the Marriott SpringHillSuites and Towneplace Suites Mortgage Loan, which constituted approximately6.4%, 4.7%, 2.0%, 1.7% and 1.3%, 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 188 SpearStreet Mortgage Loan, two other *pari passu* loans, which are not assetsof the issuing entity, (b) with respect to the ExchangeRight Net LeasedPortfolio 28 Mortgage Loan, two other *pari passu* loans, which are notassets of the issuing entity, (c) with respect to the Meidinger Tower MortgageLoan, one other *pari passu* loan, which is not an asset of the issuingentity, (d) with respect to the Maui Portfolio Mortgage Loan, one other *paripassu* loan, which is not an asset of the issuing entity and (e) withrespect to the Marriott SpringHill Suites and Towneplace Suites Mortgage Loan,one other *pari passu* loan, which is not an asset of the issuing entity.These loan combinations, including the 188 Spear Street Mortgage Loan, theExchangeRight Net Leased Portfolio 28 Mortgage Loan, the Meidinger TowerMortgage Loan, the Maui Portfolio Mortgage Loan and the Marriott SpringHillSuites and Towneplace Suites Mortgage Loan, are being serviced and administeredpursuant to the Pooling and Servicing Agreement, which is incorporated byreference as Exhibit 4.1 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 ILPT Hawaii Portfolio Mortgage Loan, whichconstituted approximately 2.0% of the asset pool of the issuing entity as ofits cut-off date.  The ILPT Hawaii Portfolio Mortgage Loan is an asset ofthe issuing entity and is part of a loan combination that includes the ILPT HawaiiPortfolio Mortgage Loan and seventeen other *pari passu* loans, which arenot assets of the issuing entity. A *pari passu* portion of the loancombination was securitized in the ILPT Trust 2019-SURF transaction (the “ILPT2019-SURF Transaction”). This loan combination, including the ILPT HawaiiPortfolio Mortgage Loan, is being serviced and administered pursuant to thetrust and servicing agreement for the ILPT 2019-SURF Transaction, which isincorporated by reference as Exhibit 4.2 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the 2 North 6th Place Mortgage Loan, whichconstituted approximately 2.1% of the asset pool of the issuing entity as ofits cut-off date.  The 2 North 6th Place Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the 2 North 6thPlace Mortgage Loan, two other *pari passu* loans and two subordinatecompanion loans, which are not assets of the issuing entity. A *pari passu*portion of the loan combination was securitized in the Natixis CommercialMortgage Securities Trust 2019-LVL transaction (the “NCMS 2019-LVLTransaction”). This loan combination, including the 2 North 6th PlaceMortgage Loan, is being serviced and administered pursuant to the trust andservicing agreement for the NCMS 2019-LVL Transaction, which is incorporated byreference as Exhibit 4.3 to this Annual Report on Form 10-K.

The Exhibit Index describes exhibitsprovided by certain parties (in their capacities indicated on the ExhibitIndex) with respect to the Town Square Mortgage Loan, which constitutedapproximately 1.1% of the asset pool of the issuing entity as of its cut-offdate.  The Town Square Mortgage Loan is an asset of the issuing entity andis part of a loan combination that includes the Town Square Mortgage Loan andone other *pari passu* loan, which is not an asset of the issuing entity.The other *pari passu* portion of the loan combination was securitized inthe Wells Fargo Commercial Mortgage Trust 2019-C50 transaction, Commission FileNumber 333-226486-05 (the “WFCM 2019-C50 Transaction”). This loancombination, including the Town Square Mortgage Loan, is being serviced andadministered pursuant to the pooling and servicing agreement for the WFCM2019-C50 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 10000 Santa Monica Boulevard Mortgage Loan,which constituted approximately 1.1% of the asset pool of the issuing entity asof its cut-off date.  The 10000 Santa Monica Boulevard Mortgage Loan is anasset of the issuing entity and is part of a loan combination that includes the10000 Santa Monica Boulevard Mortgage Loan, seven other *pari passu* loansand one subordinate companion loan, which are not assets of the issuing entity.A *pari passu* portion of the loan combination was securitized in theNatixis Commercial Mortgage Securities Trust 2019-10K transaction (the “NCMS2019-10K Transaction”). This loan combination, including the 10000 SantaMonica Boulevard Mortgage Loan, is being serviced and administered pursuant tothe trust and servicing agreement for the NCMS 2019-10K 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 Vanguard Portfolio Mortgage Loan and theSWVP Portfolio Mortgage Loan, which constituted approximately 6.1% and 1.6%,respectively, of the asset pool of the issuing entity as of its cut-offdate.  The Vanguard Portfolio Mortgage Loan and the SWVP PortfolioMortgage Loan are each an asset of the issuing entity and are each part of aloan combination that includes (a) with respect to the Vanguard PortfolioMortgage Loan, three other *pari passu* loans and one subordinatecompanion loan, which are not assets of the issuing entity or (b) with respectto the SWVP Portfolio Mortgage Loan, eight other *pari passu* loans, whichare not assets of the issuing entity. A *pari passu* portion of each loancombination was securitized in the BBCMS Mortgage Trust 2019-C3 transaction,Commission File Number 333-226850-02 (the “BBCMS 2019-C3 Transaction”).These loan combinations, including the Vanguard Portfolio Mortgage Loan and theSWVP Portfolio Mortgage Loan, are being serviced and administered pursuant tothe pooling and servicing agreement for the BBCMS 2019-C3 Transaction, which isincorporated by reference as Exhibit 4.6 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 Moffett Towers II - Buildings 3 & 4Mortgage Loan, which constituted approximately 6.9% of the asset pool of theissuing entity as of its cut-off date.  The Moffett Towers II - Buildings3 & 4 Mortgage Loan is an asset of the issuing entity and is part of a loancombination that includes the Moffett Towers II - Buildings 3 & 4 MortgageLoan, ten other *pari passu* loans and three subordinate companion loans,which are not assets of the issuing entity. A *pari passu* portion of theloan combination was securitized in the MFTII 2019-B3B4 Mortgage Trusttransaction (the “MFTII 2019-B3B4 Transaction”). This loan combination,including the Moffett Towers II - Buildings 3 & 4 Mortgage Loan, is beingserviced and administered pursuant to the trust and servicing agreement for theMFTII 2019-B3B4 Transaction, which is incorporated by reference as Exhibit 4.7to 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 ExchangeRight Net Leased Portfolio #27Mortgage Loan, which constituted approximately 1.1% of the asset pool of theissuing entity as of its cut-off date.  The ExchangeRight Net Leased Portfolio#27 Mortgage Loan is an asset of the issuing entity and is part of a loancombination that includes the ExchangeRight Net Leased Portfolio #27 MortgageLoan and one other *pari passu* loan, which is not an asset of the issuingentity. The other *pari passu* portion of the loan combination wassecuritized in the Wells Fargo Commercial Mortgage Trust 2019-C51 transaction,Commission File Number 333-226486-06 (the “WFCM 2019-C51 Transaction”).This loan combination, including the ExchangeRight Net Leased Portfolio #27Mortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the WFCM 2019-C51 Transaction, which is incorporated byreference as Exhibit 4.8 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 Visions Hotel Portfolio II Mortgage Loan andthe 125 Borinquen Place Mortgage Loan, which constituted approximately 1.8% and1.8%, respectively, of the asset pool of the issuing entity as of its cut-offdate.  The Visions Hotel Portfolio II Mortgage Loan and the 125 BorinquenPlace Mortgage Loan are each an asset of the issuing entity and are each partof a loan combination that includes (a) with respect to the Visions HotelPortfolio II Mortgage Loan, two other *pari passu* loans, which are notassets of the issuing entity or (b) with respect to the 125 Borinquen PlaceMortgage Loan, one other *pari passu* loan, which is not an asset of theissuing entity. The other *pari passu* portion of each loan combinationwas securitized in the Morgan Stanley Capital I Trust 2019-H7 transaction,Commission File Number 333-227446-05 (the “MSC 2019-H7 Transaction”).These loan combinations, including the Visions Hotel Portfolio II Mortgage Loanand the 125 Borinquen Place Mortgage Loan, are being serviced and administeredpursuant to the pooling and servicing agreement for the MSC 2019-H7Transaction, which is incorporated by reference as Exhibit 4.9 to this Annual Reporton 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 1.0% 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 six other *pari passu* loans, whichare not assets of the issuing entity. A *pari passu* portion of the loancombination 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 4.10 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 Mount Kemble Mortgage Loan and theRenaissance Center VI Mortgage Loan, which constituted approximately 1.5% and1.3%, respectively, of the asset pool of the issuing entity as of its cut-offdate.  The Mount Kemble Mortgage Loan and the Renaissance Center VIMortgage Loan are each an asset of the issuing entity and are each part of aloan combination that includes the Mount Kemble Mortgage Loan or theRenaissance Center VI Mortgage Loan and one other *pari passu* loan, eachof which is not an asset of the issuing entity. The other *pari passu*portion of each loan combination was securitized in the Wells Fargo CommercialMortgage Trust 2019-C52 transaction, Commission File Number 333-226486-08 (the“WFCM 2019-C52 Transaction”). These loan combinations, including theMount Kemble Mortgage Loan and the Renaissance Center VI Mortgage Loan, arebeing serviced and administered pursuant to the pooling and servicing agreementfor the WFCM 2019-C52 Transaction, which is incorporated by reference asExhibit 4.11 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 Ambler Yards Mortgage Loan, whichconstituted approximately 1.1% of the asset pool of the issuing entity as ofits cut-off date.  The Ambler Yards Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the Ambler YardsMortgage Loan and one other *pari passu* loan, which is not an asset ofthe issuing entity.  This loan combination, including the Ambler YardsMortgage Loan, was serviced under the Pooling and Servicing Agreement for theissuing entity prior to the closing of the securitization of the other *paripassu* portion of the Ambler Yards loan combination in the UBS CommercialMortgage Trust 2019-C17 transaction, Commission File Number 333-227784-04 (the“UBS 2019-C17 Transaction”).  After the closing of the UBS 2019-C17Transaction on October 15, 2019, this loan combination, including the AmblerYards Mortgage Loan was, and will continue to be, serviced and administeredpursuant to the pooling and servicing agreement with respect to the UBS2019-C17 Transaction, which is incorporated by reference as Exhibit 4.12 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 Inland Life Storage Portfolio Mortgage Loan,which constituted approximately 3.3% of the asset pool of the issuing entity asof its cut-off date.  The Inland Life Storage Portfolio Mortgage Loan isan asset of the issuing entity and is part of a loan combination that includesthe Inland Life Storage Portfolio Mortgage Loan and four other *pari passu*loans, which are not assets of the issuing entity.  This loan combination,including the Inland Life Storage Portfolio Mortgage Loan, was serviced underthe pooling and servicing agreement for the WFCM 2019-C52 Transaction prior tothe closing of the securitization of a *pari passu* portion of the InlandLife Storage Portfolio loan combination in the CF 2019-CF2 Mortgage Trusttransaction, Commission File Number 333-228697-02 (the “CF 2019-CF2Transaction”).  After the closing of the CF 2019-CF2 Transaction onOctober 17, 2019, this loan combination, including the Inland Life Storage PortfolioMortgage Loan was, and will continue to be, serviced and administered pursuantto the pooling and servicing agreement with respect to the CF 2019-CF2Transaction, which is incorporated by reference as Exhibit 4.13 to this AnnualReport 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 Mount Kemble Mortgage Loan, the Renaissance Center VIMortgage Loan, the ExchangeRight Net Leased Portfolio #27 Mortgage Loan and theTown Square Mortgage Loan. As a result, Wells Fargo Bank, National Associationis 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 Wells Fargo Bank, National Association in the capacities described above arelisted in the Exhibit Index.

Wells Fargo Bank, National Association is the custodian ofthe mortgage loans serviced under the Pooling and Servicing Agreement, theMoffett Towers II - Buildings 3 & 4 Mortgage Loan, the Vanguard PortfolioMortgage Loan, the 2 North 6th Place Mortgage Loan, the ILPT Hawaii PortfolioMortgage Loan, the Visions Hotel Portfolio II Mortgage Loan, the 125 BorinquenPlace Mortgage Loan, the SWVP Portfolio Mortgage Loan, the Mount KembleMortgage Loan, the Renaissance Center VI Mortgage Loan, the 10000 Santa MonicaBoulevard Mortgage Loan, the Town Square Mortgage Loan, the ExchangeRight NetLeased Portfolio #27 Mortgage Loan and the Ambler Yards Mortgage Loan.  Asa result, Wells Fargo Bank, National Association is a servicing functionparticipant in the capacities described above, because it is servicing mortgageloans that constituted 5% or more of the assets of the issuing entity as of itscut-off date. The assessments of compliance with applicable servicing criteriaand accountants’ attestation reports delivered by Wells Fargo Bank, NationalAssociation in the capacities described above are listed in the Exhibit Index.

Rialto Capital Advisors, LLC isthe special servicer of the mortgage loans serviced under the Pooling andServicing Agreement, the ILPT Hawaii Portfolio Mortgage Loan, the Ambler YardsMortgage Loan and the Town Square Mortgage Loan. As a result, Rialto CapitalAdvisors, LLC is a “servicer” as defined in Item 1108(a)(2)(iii) of RegulationAB, in the capacities described above, because it is servicing mortgage loansthat constituted 10% or more of the assets of the issuing entity as of itscut-off date. The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby Rialto Capital Advisors, LLC in the capacities described above are listed inthe Exhibit Index.

Park Bridge Lender Services LLC is the operating advisor ofthe mortgage loans serviced under the Pooling and Servicing Agreement, theInland Life Storage Portfolio Mortgage Loan, the ILPT Hawaii Portfolio MortgageLoan and the Town Square 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.

Midland Loan Services, a Divisionof PNC Bank, National Association is the primary servicer of the Ambler YardsMortgage Loan, the Meidinger Tower Mortgage Loan, the Maui Portfolio MortgageLoan, the ILPT Hawaii Portfolio Mortgage Loan, the 125 Borinquen Place MortgageLoan and the Visions Hotel Portfolio II Mortgage Loan and the primary servicerand special servicer of the Vanguard Portfolio Mortgage Loan, the SWVPPortfolio Mortgage Loan and the CIRE Equity Retail & Industrial PortfolioMortgage Loan. As a result, Midland Loan Services, a Division of PNC Bank,National Association is a “servicer” as defined in Item 1108(a)(2)(iii) ofRegulation AB, in the capacities described above, because it is servicingmortgage loans that constituted 10% or more of the assets of the issuing entityas of its cut-off date. The assessments of compliance with applicable servicingcriteria, accountants’ attestation reports and servicer compliance statementsdelivered by Midland Loan Services, a Division of PNC Bank, NationalAssociation in the capacities described above are listed in the Exhibit Index.

KeyBank National Association isthe primary servicer of the Moffett Towers II - Buildings 3 & 4 MortgageLoan, the Inland Life Storage Portfolio Mortgage Loan and the 2 North 6th PlaceMortgage Loan and the primary servicer and special servicer of the 10000 SantaMonica Boulevard Mortgage Loan. As a result, KeyBank National Association 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 KeyBank National Association in the capacities described above are listed inthe Exhibit Index.

Situs Holdings, LLC is the specialservicer of the 2 North 6th Place Mortgage Loan and the Moffett Towers II -Buildings 3 & 4 Mortgage Loan. These mortgage loans constitute more than5%, but less than 10%, of the pool assets of the issuing entity. Therefore, the Depositor included in this Annual Report on Form 10-K anassessment of compliance with applicable servicing criteria for Situs Holdings,LLC and an accountants’ attestation report pursuant to Item 1122 of RegulationAB because Situs Holdings, LLC is servicing more than 5% of the poolassets.  Situs Holdings, LLC is an affiliate of Rialto Real Estate FundIII – Debt, LP, one of the sponsors. Therefore, the Depositor included in thisAnnual Report on Form 10-K a servicer compliance statement for Situs Holdings,LLC pursuant to Item 1123 of Regulation AB.

Argentic Services Company LP isthe special servicer of the Visions Hotel Portfolio II Mortgage Loan, the 125Borinquen Place Mortgage Loan, the Mount Kemble Mortgage Loan and theRenaissance Center VI Mortgage Loan.  These mortgage loans constitute morethan 5%, but less than 10%, of the pool assets of the issuing entity. Therefore, the Depositor included in this Annual Report on Form 10-K an assessmentof compliance with applicable servicing criteria for Argentic Services CompanyLP and an accountants’ attestation report pursuant to Item 1122 of RegulationAB because Argentic Services Company LP is servicing more than 5% of the poolassets.  However, the Depositor is not required to include in this AnnualReport on Form 10-K a servicer compliance statement pursuant to Item 1123 ofRegulation AB of Argentic Services Company LP because Argentic Services CompanyLP is an unaffiliated servicer servicing less than 10% of pool assets.

Pentalpha Surveillance LLC is the operating advisor of theVanguard Portfolio Mortgage Loan, the 125 Borinquen Place Mortgage Loan, theVisions Hotel Portfolio II Mortgage Loan, the SWVP Portfolio Mortgage Loan, theMount Kemble Mortgage Loan, the Renaissance Center VI Mortgage Loan, the AmblerYards Mortgage Loan, the ExchangeRight Net Leased Portfolio #27 Mortgage Loanand the CIRE Equity Retail & Industrial Portfolio Mortgage Loan.  As aresult, Pentalpha Surveillance 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 Pentalpha Surveillance LLC in thecapacities described above are listed in the Exhibit Index.

LNR Partners, LLC is an affiliateof Starwood Mortgage Capital LLC, one of the sponsors. Therefore, the Depositorincluded in this Annual Report on Form 10-K a servicer compliance statement forLNR Partners, LLC pursuant to Item 1123.  Because LNR Partners, LLC isservicing less than 5% of the pool assets, an assessment of compliance withapplicable servicing criteria and an accountants’ attestation report pursuantto Item 1122 of Regulation AB are not required by Regulation AB. As theattestation made in the servicer compliance statement required by Item 1123relates to a review of the servicing activities of LNR Partners, LLC under theapplicable servicing agreement, and that review was conducted in conjunctionwith the servicer’s preparation of its assessment of compliance with applicableservicing criteria, that assessment of compliance with applicable servicingcriteria and the accompanying accountants’ attestation report are included inthis Annual Report on Form 10-K for the sake of completeness.

Wells Fargo Bank, NationalAssociation acts as trustee of the ILPT Hawaii Portfolio Mortgage Loan, the 2 North6th Place Mortgage Loan, the 10000 Santa Monica Boulevard Mortgage Loan, theVanguard Portfolio Mortgage Loan, the SWVP Portfolio Mortgage Loan, the MoffettTowers II - Buildings 3 & 4 Mortgage Loan, the 125 Borinquen Place MortgageLoan and the Visions Hotel Portfolio II Mortgage Loan.  Pursuant to thetrust and servicing agreement for the ILPT 2019-SURF Transaction, the trust andservicing agreement for the NCMS 2019-LVL Transaction, the trust and servicingagreement for the NCMS 2019-10K Transaction, the pooling and servicingagreement for the BBCMS 2019-C3 Transaction, the trust and servicing agreementfor the MFTII 2019-B3B4 Transaction and the pooling and servicing agreement forthe MSC 2019-H7 Transaction, the trustee is required to provide an assessmentof compliance 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 criteriaspecified in Item 1122(d)(2)(iii) of Regulation AB.  The master serviceror the special servicer, to the extent required, performed the servicingfunction identified with respect to Item 1122(d)(2)(iii) of Regulation AB, andeach such party included Item 1122(d)(2)(iii) of Regulation AB in theassessment of compliance with applicable servicing criteria and accountant’sattestation report for the subject transaction.  As a result, this AnnualReport on Form 10-K does not include an assessment of compliance withapplicable servicing criteria of the trustee. One or more other servicers ofthe ILPT Hawaii Portfolio Mortgage Loan, the 2 North 6th Place Mortgage Loan,the 10000 Santa Monica Boulevard Mortgage Loan, the Vanguard Portfolio MortgageLoan, the SWVP Portfolio Mortgage Loan, the Moffett Towers II - Buildings 3& 4 Mortgage Loan, the 125 Borinquen Place Mortgage Loan and the VisionsHotel Portfolio II 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 mortgage loans serviced under thePooling and Servicing Agreement, the Town Square Mortgage Loan, theExchangeRight Net Leased Portfolio #27 Mortgage Loan, the CIRE Equity Retail& Industrial Portfolio Mortgage Loan, the Mount Kemble Mortgage Loan, theRenaissance Center VI Mortgage Loan and the Ambler Yards Mortgage Loan. Pursuant to the Pooling and Servicing Agreement, the pooling and servicingagreement for the WFCM 2019-C50 Transaction, the pooling and servicingagreement for the WFCM 2019-C51 Transaction, the pooling and servicingagreement for the Benchmark 2019-B12 Transaction, the pooling and servicingagreement for the WFCM 2019-C52 Transaction and the pooling and servicingagreement for the UBS 2019-C17 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 withrespect to the servicing criteria specified in Item 1122(d)(2)(iii) ofRegulation AB.  The master servicer or the special servicer, to the extentrequired, performed the servicing function identified with respect to Item1122(d)(2)(iii) of Regulation AB, and each such party included Item1122(d)(2)(iii) of Regulation AB in the assessment of compliance withapplicable servicing criteria and accountant’s attestation report for thesubject transaction.  As a result, this Annual Report on Form 10-K doesnot include an assessment of compliance with applicable servicing criteria ofthe trustee. One or more other servicers of  the mortgage loans servicedunder the Pooling and Servicing Agreement, the Town Square Mortgage Loan, theExchangeRight Net Leased Portfolio #27 Mortgage Loan, the CIRE Equity Retail& Industrial Portfolio Mortgage Loan, the Mount Kemble Mortgage Loan, theRenaissance Center VI Mortgage Loan and the Ambler Yards Mortgage Loan havedelivered one or more assessments of compliance with respect to Item 1122(d)(2)(iii)of Regulation AB.

Citibank, N.A. acts as trustee ofthe Inland Life Storage Portfolio Mortgage Loan.  Pursuant to the poolingand servicing agreement for the CF 2019-CF2 Transaction, the trustee isrequired to provide an assessment of compliance with applicable servicingcriteria solely with respect to Item 1122(d)(2)(iii) of Regulation AB(regarding advances 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 Inland Life Storage PortfolioMortgage Loan have delivered one or more assessments of compliance with respectto 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 (except with respect to those mortgage loans for which Midland Loan Services,a Division of PNC Bank, National Association is the primary servicer) and theprimary servicer of the Town Square Mortgage Loan, the ExchangeRight Net LeasedPortfolio #27 Mortgage Loan, the Mount Kemble Mortgage Loan and the RenaissanceCenter VI 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 ILPT Hawaii Portfolio Mortgage Loan, the 2 North 6th PlaceMortgage Loan, the Town Square Mortgage Loan, the 10000 Santa Monica BoulevardMortgage Loan, the Vanguard Portfolio Mortgage Loan, the SWVP PortfolioMortgage Loan, the ExchangeRight Net Leased Portfolio #27 Mortgage Loan, theMoffett Towers II - Buildings 3 & 4 Mortgage Loan, the 125 Borinquen PlaceMortgage Loan, the Visions Hotel Portfolio II Mortgage Loan, the Mount KembleMortgage Loan, the Renaissance Center VI Mortgage Loan, the Ambler YardsMortgage Loan, the CIRE Equity Retail & Industrial Portfolio Mortgage Loanand the Inland Life Storage Portfolio Mortgage Loan are omitted from thisAnnual Report on Form 10-K as the certificate administrator pursuant to therelated pooling and servicing agreement or trust and servicing agreement doesnot perform any activities that address servicing criteria with respect to theissuing entity and because they are each not a “servicer” that meets thecriteria in Item 1108(a)(2)(i) through (iii) of Regulation AB.

With respect to the *pari passu*loan combinations that include the Visions Hotel Portfolio II Mortgage Loan,the 125 Borinquen Place Mortgage Loan, the Mount Kemble Mortgage Loan, theRenaissance Center VI Mortgage Loan, the Inland Life Storage Portfolio MortgageLoan, the ExchangeRight Net Leased Portfolio #27 Mortgage Loan and the CIREEquity Retail & Industrial Portfolio Mortgage Loan, (i) the reports onassessment of compliance with servicing criteria and attestation reports onassessment of compliance with servicing criteria of Greystone Servicing CompanyLLC (as successor to C-III Asset Management LLC) as special servicer of theExchangeRight Net Leased Portfolio #27 Mortgage Loan, and Citibank, N.A. ascustodian of the CIRE Equity Retail & Industrial Portfolio Mortgage Loanand the Inland Life Storage Portfolio Mortgage Loan, listed on the ExhibitIndex are omitted from this Annual Report on Form 10-K as they are not requiredto be included on this Annual Report on Form 10-K per Instruction 3 to Item1122 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 Greystone ServicingCompany LLC (as successor to C-III Asset Management LLC) as special servicer ofthe ExchangeRight Net Leased Portfolio #27 Mortgage Loan and Argentic ServicesCompany LP as special servicer of the Visions Hotel Portfolio II Mortgage Loan,the 125 Borinquen Place Mortgage Loan, the Mount Kemble Mortgage Loan and theRenaissance Center VI Mortgage Loan, listed on the Exhibit Index are omittedfrom this Annual Report on Form 10-K as they are not required by Item 1123 ofRegulation AB to be included on this Annual Report on Form 10-K because theyare each an unaffiliated party that is not a “servicer” that meets the criteriain Item 1108(a)(2)(i) through (iii) of Regulation AB.

**PART I**

**Item 1.  Business.**

Omitted.

**Item 1A.  Risk Factors.**

Omitted.

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

None.

**Item 2.  Properties.**

Omitted.

**Item 3.  Legal Proceedings.**

Omitted.

**Item 4.  Mine Safety Disclosures.**

Not applicable.

**PART II**

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

Omitted.

**Item 6.  Selected Financial Data.**

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**Item 9B.  Other Information.**

None.

**PART III**

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

Omitted.

**Item 11.  Executive Compensation.**

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**ADDITIONAL DISCLOSURE ITEMS FOR REGULATION AB**

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

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

 

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

No entity or group of affiliated entities provides any 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 Certain Relationshipsand Related Transactions.**

The information regarding this Item has been previouslyprovided in the prospectus of the Registrant relating to the issuing entityfiled on August 28, 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 attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit AA to thePooling and Servicing Agreement incorporated by reference as Exhibit 4.1 tothis 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 ILPT Hawaii Portfolio MortgageLoan, which is being serviced and administered pursuant to the trust andservicing agreement for the ILPT 2019-SURF Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit L to thetrust and servicing agreement for the ILPT 2019-SURF Transaction incorporatedby reference as Exhibit 4.2 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the ILPT2019-SURF 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 2 North 6th Place Mortgage Loan,which is being serviced and administered pursuant to the trust and servicingagreement for the NCMS 2019-LVL Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit K to the trust andservicing agreement for the NCMS 2019-LVL Transaction incorporated by referenceas Exhibit 4.3 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the NCMS 2019-LVLTransaction 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 Town Square Mortgage Loan, whichis being serviced and administered pursuant to the pooling and servicingagreement for the WFCM 2019-C50 Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit AA to the pooling andservicing agreement for the WFCM 2019-C50 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 WFCM 2019-C50Transaction 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 10000 Santa Monica BoulevardMortgage Loan, which is being serviced and administered pursuant to the trustand servicing agreement for the NCMS 2019-10K Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit K to thetrust and servicing agreement for the NCMS 2019-10K 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 NCMS2019-10K 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 Vanguard Portfolio Mortgage Loanand the SWVP Portfolio Mortgage Loan, which are being serviced and administeredpursuant to the pooling and servicing agreement for the BBCMS 2019-C3Transaction, are attached hereto under Item 15 to this Annual Report on Form10-K. Attached as Exhibit AA to the pooling and servicing agreement for theBBCMS 2019-C3 Transaction incorporated by reference as Exhibit 4.6 to thisAnnual Report on Form 10-K is a chart identifying the entities participating ina servicing function for the BBCMS 2019-C3 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 Moffett Towers II - Buildings 3& 4 Mortgage Loan, which is being serviced and administered pursuant to thetrust and servicing agreement for the MFTII 2019-B3B4 Transaction, are attachedhereto under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit Lto the trust and servicing agreement for the MFTII 2019-B3B4 Transactionincorporated by reference as Exhibit 4.7 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theMFTII 2019-B3B4 Transaction responsible for each applicable servicing criteriaset forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the ExchangeRight Net LeasedPortfolio #27 Mortgage Loan, which is being serviced and administered pursuantto the pooling and servicing agreement for the WFCM 2019-C51 Transaction, areattached hereto under Item 15 to this Annual Report on Form 10-K. Attached asExhibit AA to the pooling and servicing agreement for the WFCM 2019-C51Transaction incorporated by reference as Exhibit 4.8 to this Annual Report onForm 10-K is a chart identifying the entities participating in a servicingfunction for the WFCM 2019-C51 Transaction responsible for each applicableservicing 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 125 Borinquen Place Mortgage Loanand the Visions Hotel Portfolio II Mortgage Loan, which are being serviced andadministered pursuant to the pooling and servicing agreement for the MSC2019-H7 Transaction, are attached hereto under Item 15 to this Annual Report onForm 10-K. Attached as Exhibit AA to the pooling and servicing agreement forthe MSC 2019-H7 Transaction incorporated by reference as Exhibit 4.9 to thisAnnual Report on Form 10-K is a chart identifying the entities participating ina servicing function for the MSC 2019-H7 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 administered pursuantto the pooling and servicing agreement for the Benchmark 2019-B12 Transaction,are attached hereto under Item 15 to this Annual Report on Form 10-K. Attachedas Exhibit O to the pooling and servicing agreement for the Benchmark 2019-B12Transaction incorporated by reference as Exhibit 4.10 to this Annual Report onForm 10-K is a chart identifying the entities participating in a servicingfunction for the Benchmark 2019-B12 Transaction responsible for each applicableservicing 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 Mount Kemble Mortgage Loan andthe Renaissance Center VI Mortgage Loan, which are being serviced andadministered pursuant to the pooling and servicing agreement for the WFCM2019-C52 Transaction, are attached hereto under Item 15 to this Annual Reporton Form 10-K. Attached as Exhibit AA to the pooling and servicing agreement forthe WFCM 2019-C52 Transaction incorporated by reference as Exhibit 4.11 to thisAnnual Report on Form 10-K is a chart identifying the entities participating ina servicing function for the WFCM 2019-C52 Transaction responsible for each applicableservicing 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 Ambler Yards Mortgage Loan, whichis being serviced and administered pursuant to the pooling and servicingagreement for the UBS 2019-C17 Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit Z to the pooling andservicing agreement for the UBS 2019-C17 Transaction incorporated by referenceas Exhibit 4.12 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the UBS 2019-C17 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 Inland Life Storage PortfolioMortgage Loan, which is being serviced and administered pursuant to the poolingand servicing agreement for the CF 2019-CF2 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 CF 2019-CF2 Transactionincorporated by reference as Exhibit 4.13 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theCF 2019-CF2 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 ofthis Annual Report on Form 10-K:

(1) Not applicable

(2) Not applicable

(3) See below

4.1          Poolingand Servicing Agreement, dated as of August 1, 2019, among Barclays CommercialMortgage Securities LLC, as Depositor, Wells Fargo Bank, National Association,as Master Servicer, Rialto Capital Advisors, LLC, as Special Servicer, WellsFargo Bank, National Association, as Certificate Administrator, WilmingtonTrust, National Association, as Trustee and Park Bridge Lender Services LLC, asOperating Advisor and as Asset Representations Reviewer (filed as Exhibit 4.1to the registrant’s Current Report on Form 8-K filed on August 28, 2019 underCommission File No. 333-226850-03 and incorporated by reference herein).

4.2          Trustand Servicing Agreement, dated as of March 7, 2019, among Morgan StanleyCapital I Inc., as Depositor, Midland Loan Services, a Division of PNC Bank,National Association, as Servicer, Rialto Capital Advisors, LLC, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administrator,as Custodian and as Trustee, and Park Bridge Lender Services LLC, as OperatingAdvisor (filed as Exhibit 4.6 to the registrant’s Current Report on Form 8-Kfiled on August 28, 2019 under Commission File No. 333-226850-03 andincorporated by reference herein).

4.3          Trustand Servicing Agreement, dated as of April 23, 2019, among Natixis CommercialMortgage Securities LLC, as Depositor, KeyBank National Association, asServicer, Situs Holdings, LLC, as Special Servicer, and Wells Fargo Bank,National Association, as Trustee and Certificate Administrator (filed asExhibit 4.5 to the registrant’s Current Report on Form 8-K filed on August 28,2019 under Commission File No. 333-226850-03 and incorporated by referenceherein).

4.4          Poolingand Servicing Agreement, dated as of May 1, 2019, among Wells Fargo CommercialMortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, Rialto Capital Advisors, LLC, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Park Bridge LenderServices LLC, as Operating Advisor and as Asset Representations Reviewer (filedas Exhibit 4.10 to the registrant’s Current Report on Form 8-K filed on August28, 2019 under Commission File No. 333-226850-03 and incorporated by referenceherein).

4.5          Trustand Servicing Agreement, dated as of June 4, 2019, among Natixis CommercialMortgage Securities LLC, as Depositor, KeyBank National Association, asServicer, KeyBank National Association, as Special Servicer, and Wells FargoBank, National Association, as Trustee and as Certificate Administrator (filedas Exhibit 4.9 to the registrant’s Current Report on Form 8-K filed on August28, 2019 under Commission File No. 333-226850-03 and incorporated by referenceherein).

4.6          Poolingand Servicing Agreement, dated as of June 1, 2019, among Barclays CommercialMortgage Securities LLC, as Depositor, Midland Loan Services, a Division of PNCBank, National Association, as Master Servicer, Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer, Wells FargoBank, National Association, as Certificate Administrator, Wells Fargo Bank,National Association, as Trustee, and Pentalpha Surveillance LLC, as OperatingAdvisor and as Asset Representations Reviewer (filed as Exhibit 4.3 to theregistrant’s Current Report on Form 8-K filed on August 28, 2019 underCommission File No. 333-226850-03 and incorporated by reference herein).

4.7          Trustand Servicing Agreement, dated as of July 11, 2019, among Barclays CommercialMortgage Securities LLC, as Depositor, KeyBank National Association, asServicer, Situs Holdings, LLC, as Special Servicer, and Wells Fargo Bank,National Association, as Certificate Administrator and Trustee (filed asExhibit 4.2 to the registrant’s Current Report on Form 8-K filed on August 28,2019 under Commission File No. 333-226850-03 and incorporated by referenceherein).

4.8          Poolingand Servicing Agreement, dated as of July 1, 2019, among Wells Fargo CommercialMortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, C-III Asset Management 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 4.8 to the registrant’s Current Report on Form 8-K filed on August 28,2019 under Commission File No. 333-226850-03 and incorporated by referenceherein).

4.9          Poolingand Servicing Agreement, dated as of July 1, 2019, among Morgan Stanley CapitalI Inc., as Depositor, Midland Loan Services, a Division of PNC Bank, NationalAssociation, as Master Servicer, LNR Partners, LLC, as Special Servicer, WellsFargo Bank, National Association, as Certificate Administrator and Trustee, andPentalpha Surveillance LLC, as Operating Advisor and Asset RepresentationsReviewer (filed as Exhibit 4.7 to the registrant’s Current Report on Form 8-Kfiled on August 28, 2019 under Commission File No. 333-226850-03 and incorporatedby reference herein).

4.10        Poolingand Servicing Agreement, dated as of August 1, 2019, among Citigroup CommercialMortgage Securities Inc., as Depositor, Midland Loan Services, a Division ofPNC Bank, National Association, as Master Servicer, Midland Loan Services, aDivision of PNC Bank, National Association, Pacific Life Insurance Company andTrimont Real Estate Advisors, LLC, each as 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 4.11 to the registrant’s CurrentReport on Form 8-K filed on August 28, 2019 under Commission File No.333-226850-03 and incorporated by reference herein).

4.11        Poolingand Servicing Agreement, dated as of August 1, 2019, 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 Pentalpha Surveillance LLC, asOperating Advisor and as Asset Representations Reviewer (filed as Exhibit 4.4to the registrant’s Current Report on Form 8-K filed on August 28, 2019 under CommissionFile No. 333-226850-03 and incorporated by reference herein).

4.12        Poolingand Servicing Agreement, dated as of October 1, 2019, among UBS CommercialMortgage Securitization Corp., as Depositor, Wells Fargo Bank, NationalAssociation, 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 4.1 to the registrant’s Current Report on Form 8-K filed on October 18,2019 under Commission File No. 333-226850-03 and incorporated by referenceherein).

4.13        Poolingand Servicing Agreement, dated as of October 1, 2019, among CCRE CommercialMortgage Securities, L.P., as Depositor, KeyBank National Association, asMaster Servicer, KeyBank National Association and LNR Partners, LLC, each as aSpecial Servicer, Citibank, N.A., as Trustee, Citibank, N.A., as CertificateAdministrator, Paying Agent and Custodian, and Park Bridge Lender Services LLC,as Operating Advisor and as Asset Representations Reviewer (filed as Exhibit4.2 to the registrant’s Current Report on Form 8-K filed on October 18, 2019under Commission File No. 333-226850-03 and incorporated by reference herein).

4.14        PrimaryServicing Agreement, dated as of August 1, 2019, between Wells Fargo Bank,National Association, as Master Servicer, and Midland Loan Services, a Divisionof PNC Bank, National Association, as Primary Servicer (filed as Exhibit 4.32to the registrant’s Current Report on Form 8-K filed on October 18, 2019 underCommission File No. 333-226850-03 and incorporated by reference herein).

4.15        Co-LenderAgreement, dated as of July 11, 2019, by and among Barclays Bank PLC, as NoteA-1-A and Note B-1 Holder, Barclays Capital Real Estate Inc., as Initial NoteA-1-B Holder, Initial Note A-1-D Holder and Initial Note A-1-E Holder, Bank ofAmerica, N.A., as Note A-1-C Holder, Deutsche Bank AG, New York Branch, asInitial Note A-2-A Holder, Initial Note A-2-B Holder, Initial Note A-2-C Holderand Initial Note B-2 Holder, and Goldman Sachs Bank USA, as Initial Note A-3-AHolder, Initial Note A-3-B Holder, Initial Note A-3-C Holder and Initial NoteB-3 Holder (filed as Exhibit 4.12 to the registrant’s Current Report on Form8-K filed on August 28, 2019 under Commission File No. 333-226850-03 andincorporated by reference herein).

4.16        AgreementBetween Note Holders, dated as of June 14, 2019, by and between BarclaysCapital Real Estate Inc., as Initial Note A-1 Holder, Barclays Capital RealEstate Inc., as Initial Note A-2 Holder and Barclays Capital Real Estate Inc.,as Initial Note A-3 Holder (filed as Exhibit 4.13 to the registrant’s CurrentReport on Form 8-K filed on October 18, 2019 under Commission File No.333-226850-03 and incorporated by reference herein).

4.17        Amendedand Restated Co-Lender Agreement, dated as of June 11, 2019, by and amongNatixis Real Estate Capital LLC, as Note A-1 Holder, Natixis Real Estate CapitalLLC, as Note A-2 Holder, Natixis Real Estate Capital LLC, as Note A-3 Holder,Natixis Real Estate Capital LLC, as Note A-4 Holder, Natixis Real EstateCapital LLC, as Note A-5 Holder, Natixis Real Estate Capital LLC, as Note A-6Holder, and TCM CRE REIT LLC, as Note B Holder (filed as Exhibit 4.14 to theregistrant’s Current Report on Form 8-K filed on August 28, 2019 underCommission File No. 333-226850-03 and incorporated by reference herein).

4.18        AgreementBetween Note Holders, dated as of August 28, 2019 by and among, SocieteGenerale Financial Corporation, as Initial Note A-1 Holder, Societe GeneraleFinancial Corporation, as Initial Note A-2 Holder, and Societe GeneraleFinancial Corporation, as Initial Note A-3 Holder (filed as Exhibit 4.15 to theregistrant’s Current Report on Form 8-K filed on August 28, 2019 underCommission File No. 333-226850-03 and incorporated by reference herein).

4.19        AgreementBetween Note Holders, dated as of July 2, 2019 by and between, KeyBank NationalAssociation, as Initial Note A-1-A Holder, Initial Note A-1-B Holder andInitial Note A-1-C Holder, and Barclays Capital Real Estate Inc., as InitialNote A-2-A Holder and Initial Note A-2-B Holder (filed as Exhibit 4.16 to theregistrant’s Current Report on Form 8-K filed on August 28, 2019 underCommission File No. 333-226850-03 and incorporated by reference herein).

4.20        Amendedand Restated Co-Lender Agreement, dated as of February 11, 2019, by and amongNatixis Real Estate Capital LLC, as Note A-1 Holder, Natixis Real EstateCapital LLC, as Note A-2 Holder, Natixis Real Estate Capital LLC, as Note A-3Holder, Natixis Real Estate Capital LLC, as Note A-B Holder and John HancockLife Insurance Company (U.S.A.), as Note B Holder (filed as Exhibit 4.17 to theregistrant’s Current Report on Form 8-K filed on August 28, 2019 underCommission File No. 333-226850-03 and incorporated by reference herein).

4.21        AgreementBetween Note Holders, dated as of March 7, 2019, by and between Morgan StanleyBank, N.A., as Initial Note A-1 Holder, Initial Note A-5-1 Holder, Initial NoteA-5-2 Holder, Initial Note A-5-3 Holder and Initial Note A-5-4 Holder, CitiReal Estate Funding Inc., as Initial Note A-2 Holder, Initial Note A-6-1Holder, Initial Note A-6-2 Holder and Initial Note A-6-3 Holder, UBS AG, NewYork Branch, as Initial Note A-3 Holder, Initial Note A-7-1 Holder, InitialNote A-7-2 Holder, Initial Note A-9 Holder, Initial Note A-10 Holder andInitial Note A-11 Holder, and JPMorgan Chase Bank, National Association, asInitial Note A-4 Holder, Initial Note A-8-1 Holder and Initial Note A-8-2Holder (filed as Exhibit 4.18 to the registrant’s Current Report on Form 8-Kfiled on August 28, 2019 under Commission File No. 333-226850-03 andincorporated by reference herein).

4.22        AgreementBetween Note Holders, dated as of August 28, 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, and UBS AG, by and through its branch officeat 1285 Avenue of the Americas, New York, New York, as Initial Note A-2 Holder(filed as Exhibit 4.19 to the registrant’s Current Report on Form 8-K filed onAugust 28, 2019 under Commission File No. 333-226850-03 and incorporated byreference herein).

4.23        Co-LenderAgreement, dated as of May 31, 2019, by and between Starwood Mortgage CapitalLLC, as Initial Note A-1 Holder, and Starwood Mortgage Capital LLC, as InitialNote A-2 Holder (filed as Exhibit 4.20 to the registrant’s Current Report onForm 8-K filed on August 28, 2019 under Commission File No. 333-226850-03 andincorporated by reference herein).

4.24        Co-LenderAgreement, dated as of June 11, 2019, by and between Starwood Mortgage Capital LLC,as Initial Note A-1 Holder, Starwood Mortgage Capital LLC, as Initial Note A-2Holder, and Starwood Mortgage Capital LLC, as Initial Note A-3 Holder (filed asExhibit 4.21 to the registrant’s Current Report on Form 8-K filed on August 28,2019 under Commission File No. 333-226850-03 and incorporated by referenceherein).

4.25        AgreementBetween Note Holders, dated as of August 28, 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, and UBS AG, by and through its branch officeat 1285 Avenue of the Americas, New York, New York, as Initial Note A-2 Holder(filed as Exhibit 4.22 to the registrant’s Current Report on Form 8-K filed onAugust 28, 2019 under Commission File No. 333-226850-03 and incorporated byreference herein).

4.26        Co-LenderAgreement, dated as of June 11, 2019, by and between Societe Generale FinancialCorporation and JPMorgan Chase Bank, National Association (filed as Exhibit4.23 to the registrant’s Current Report on Form 8-K filed on August 28, 2019under Commission File No. 333-226850-03 and incorporated by reference herein).

4.27        Co-LenderAgreement, dated as of July 25, 2019, by and between BSPRT Finance Sub-LenderII, LLC, as Note A-1 Holder, and BSPRT Finance Sub-Lender II, LLC, as Note A-2Holder (filed as Exhibit 4.24 to the registrant’s Current Report on Form 8-Kfiled on August 28, 2019 under Commission File No. 333-226850-03 andincorporated by reference herein).

4.28        Co-LenderAgreement, dated as of July 25, 2019, by and between BSPRT Finance Sub-LenderI, LLC, as Note A-1 Holder, and BSPRT Finance Sub-Lender I, LLC, as Note A-2Holder (filed as Exhibit 4.25 to the registrant’s Current Report on Form 8-Kfiled on August 28, 2019 under Commission File No. 333-226850-03 andincorporated by reference herein).

4.29        Co-LenderAgreement, dated as of June 6, 2019, by and between Starwood Mortgage CapitalLLC, as Initial Note A-1 Holder, and Starwood Mortgage Capital LLC, as InitialNote A-2 Holder (filed as Exhibit 4.26 to the registrant’s Current Report onForm 8-K filed on August 28, 2019 under Commission File No. 333-226850-03 andincorporated by reference herein).

4.30        AgreementBetween Note Holders, dated as of June 14, 2019, by and between BarclaysCapital Real Estate Inc., as Initial Note A-1 Holder, and Barclays Capital RealEstate Inc., as Initial Note A-2 Holder (filed as Exhibit 4.27 to theregistrant’s Current Report on Form 8-K filed on August 28, 2019 underCommission File No. 333-226850-03 and incorporated by reference herein).

4.31        Co-LenderAgreement, dated as of June 4, 2019, by and among Natixis Real Estate CapitalLLC, as Note A-1 Holder, Natixis Real Estate Capital LLC, as Note A-2 Holder,Natixis Real Estate Capital LLC, as Note A-3 Holder, Natixis Real EstateCapital LLC, as Note A-4 Holder, Natixis Real Estate Capital LLC, as Note A-5Holder, Natixis Real Estate Capital LC, as Note A-6 Holder, Natixis Real EstateCapital LLC, as Note A-7 Holder, and Natixis Real Estate Capital LLC, as NoteA-B Holder (filed as Exhibit 4.28 to the registrant’s Current Report on Form8-K filed on August 28, 2019 under Commission File No. 333-226850-03 andincorporated by reference herein).

4.32        Co-LenderAgreement, dated as of April 12, 2019, by and between BSPRT Finance Sub-LenderI, LLC, as Note A-1 Holder, and BSPRT Finance Sub-Lender I, LLC, as Note A-2Holder (filed as Exhibit 4.29 to the registrant’s Current Report on Form 8-Kfiled on August 28, 2019 under Commission File No. 333-226850-03 andincorporated by reference herein).

4.33        AgreementBetween Note Holders, dated as of August 28, 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, and UBS AG, by and through its branch officeat 1285 Avenue of the Americas, New York, New York, as Initial Note A-2 Holder(filed as Exhibit 4.30 to the registrant’s Current Report on Form 8-K filed onAugust 28, 2019 under Commission File No. 333-226850-03 and incorporated byreference herein).

4.34        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 4.31 to the registrant’s Current Report on Form 8-K filed onAugust 28, 2019 under Commission File No. 333-226850-03 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        Rialto Capital Advisors, LLC, 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      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer

33.11      Wells Fargo Bank, National Association, as PrimaryServicer of the 188 Spear Street Mortgage Loan (see Exhibit 33.1)

33.12      Rialto Capital Advisors, LLC, as Special Servicerof the 188 Spear Street Mortgage Loan (see Exhibit 33.2)

33.13      Wilmington Trust, National Association, as Trustee of the 188 Spear StreetMortgage Loan (Omitted. See Explanatory Notes.)

33.14      Wells Fargo Bank, National Association, asCustodian of the 188 Spear Street Mortgage Loan (see Exhibit 33.5)

33.15      Park Bridge Lender Services LLC, as OperatingAdvisor of the 188 Spear Street Mortgage Loan (see Exhibit 33.6)

33.16      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 188 Spear Street Mortgage Loan (see Exhibit 33.7)

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

33.18      Wells Fargo Bank, National Association, as PrimaryServicer of the ExchangeRight Net Leased Portfolio 28 Mortgage Loan (seeExhibit 33.1)

33.19      Rialto Capital Advisors, LLC, as Special Servicerof the ExchangeRight Net Leased Portfolio 28 Mortgage Loan (see Exhibit 33.2)

33.20      Wilmington Trust, National Association, as Trustee of the ExchangeRight NetLeased Portfolio 28 Mortgage Loan (Omitted. See Explanatory Notes.)

33.21      Wells Fargo Bank, National Association, asCustodian of the ExchangeRight Net Leased Portfolio 28 Mortgage Loan (seeExhibit 33.5)

33.22      Park Bridge Lender Services LLC, as OperatingAdvisor of the ExchangeRight Net Leased Portfolio 28 Mortgage Loan (see Exhibit33.6)

33.23      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the ExchangeRight Net Leased Portfolio 28 Mortgage Loan (seeExhibit 33.7)

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

33.25      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Meidinger Tower Mortgage Loan(see Exhibit 33.10)

33.26      Rialto Capital Advisors, LLC, as Special Servicerof the Meidinger Tower Mortgage Loan (see Exhibit 33.2)

33.27      Wilmington Trust, National Association, as Trustee of the Meidinger TowerMortgage Loan (Omitted. See Explanatory Notes.)

33.28      Wells Fargo Bank, National Association, asCustodian of the Meidinger Tower Mortgage Loan (see Exhibit 33.5)

33.29      Park Bridge Lender Services LLC, as OperatingAdvisor of the Meidinger Tower Mortgage Loan (see Exhibit 33.6)

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

33.31      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Maui Portfolio Mortgage Loan(see Exhibit 33.10)

33.32      Rialto Capital Advisors, LLC, as Special Servicerof the Maui Portfolio Mortgage Loan (see Exhibit 33.2)

33.33      Wilmington Trust, National Association, as Trustee of the Maui PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.34      Wells Fargo Bank, National Association, asCustodian of the Maui Portfolio Mortgage Loan (see Exhibit 33.5)

33.35      Park Bridge Lender Services LLC, as OperatingAdvisor of the Maui Portfolio Mortgage Loan (see Exhibit 33.6)

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 Marriott SpringHill Suites and Towneplace Suites Mortgage Loan(see Exhibit 33.1)

33.38      Rialto Capital Advisors, LLC, as Special Servicerof the Marriott SpringHill Suites and Towneplace Suites Mortgage Loan (seeExhibit 33.2)

33.39      Wilmington Trust, National Association, as Trustee of the Marriott SpringHillSuites and Towneplace Suites Mortgage Loan (Omitted. See Explanatory Notes.)

33.40      Wells Fargo Bank, National Association, as Custodianof the Marriott SpringHill Suites and Towneplace Suites Mortgage Loan (seeExhibit 33.5)

33.41      Park Bridge Lender Services LLC, as OperatingAdvisor of the Marriott SpringHill Suites and Towneplace Suites Mortgage Loan(see Exhibit 33.6)

33.42      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Marriott SpringHill Suites and Towneplace Suites MortgageLoan (see Exhibit 33.7)

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

33.44      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the ILPT Hawaii Portfolio MortgageLoan (see Exhibit 33.10)

33.45      Rialto Capital Advisors, LLC, as Special Servicerof the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 33.2)

33.46      Wells Fargo Bank, National Association, as Trustee of the ILPT Hawaii PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.47      Wells Fargo Bank, National Association, asCustodian of the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 33.5)

33.48      Park Bridge Lender Services LLC, as OperatingAdvisor of the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 33.6)

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

33.50      KeyBank National Association, as Primary Servicerof the 2 North 6th Place Mortgage Loan

33.51      Situs Holdings, LLC, as Special Servicer of the 2North 6th Place Mortgage Loan

33.52      Wells Fargo Bank, National Association, as Trustee of the 2 North 6th PlaceMortgage Loan (Omitted. See Explanatory Notes.)

33.53      Wells Fargo Bank, National Association, asCustodian of the 2 North 6th Place Mortgage Loan (see Exhibit 33.5)

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

33.55      Wells Fargo Bank, National Association, as PrimaryServicer of the Town Square Mortgage Loan (see Exhibit 33.1)

33.56      Rialto Capital Advisors, LLC, as Special Servicerof the Town Square Mortgage Loan (see Exhibit 33.2)

33.57      Wilmington Trust, National Association, as Trustee of the Town Square MortgageLoan (Omitted. See Explanatory Notes.)

33.58      Wells Fargo Bank, National Association, asCustodian of the Town Square Mortgage Loan (see Exhibit 33.5)

33.59      Park Bridge Lender Services LLC, as OperatingAdvisor of the Town Square Mortgage Loan (see Exhibit 33.6)

33.60      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Town Square Mortgage Loan (see Exhibit 33.7)

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

33.62      KeyBank National Association, as Primary Servicerof the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 33.50)

33.63      KeyBank National Association, as Special Servicerof the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 33.50)

33.64      Wells Fargo Bank, National Association, as Trustee of the 10000 Santa MonicaBoulevard Mortgage Loan (Omitted. See Explanatory Notes.)

33.65      Wells Fargo Bank, National Association, asCustodian of the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 33.5)

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

33.67      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Vanguard Portfolio MortgageLoan (see Exhibit 33.10)

33.68      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Vanguard Portfolio MortgageLoan (see Exhibit 33.10)

33.69      Wells Fargo Bank, National Association, as Trustee of the Vanguard PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.70      Wells Fargo Bank, National Association, asCustodian of the Vanguard Portfolio Mortgage Loan (see Exhibit 33.5)

33.71      Pentalpha Surveillance LLC, as Operating Advisorof the Vanguard Portfolio Mortgage Loan

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

33.73      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the SWVP Portfolio Mortgage Loan(see Exhibit 33.10)

33.74      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the SWVP Portfolio Mortgage Loan(see Exhibit 33.10)

33.75      Wells Fargo Bank, National Association, as Trustee of the SWVP PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.76      Wells Fargo Bank, National Association, asCustodian of the SWVP Portfolio Mortgage Loan (see Exhibit 33.5)

33.77      Pentalpha Surveillance LLC, as Operating Advisorof the SWVP Portfolio Mortgage Loan (see Exhibit 33.71)

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

33.79      KeyBank National Association, as Primary Servicerof the Moffett Towers II - Buildings 3 & 4 Mortgage Loan (see Exhibit33.50)

33.80      Situs Holdings, LLC, as Special Servicer of theMoffett Towers II - Buildings 3 & 4 Mortgage Loan (see Exhibit 33.51)

33.81      Wells Fargo Bank, National Association, as Trustee of the Moffett Towers II -Buildings 3 & 4 Mortgage Loan (Omitted. See Explanatory Notes.)

33.82      Wells Fargo Bank, National Association, asCustodian of the Moffett Towers II - Buildings 3 & 4 Mortgage Loan (seeExhibit 33.5)

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

33.84      Wells Fargo Bank, National Association, as PrimaryServicer of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan (seeExhibit 33.1)

33.85      Greystone Servicing Company LLC (as successor to C-III Asset Management LLC),as Special Servicer of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan(Omitted. See Explanatory Notes.)

33.86      Wilmington Trust, National Association, as Trustee of the ExchangeRight NetLeased Portfolio #27 Mortgage Loan (Omitted. See Explanatory Notes.)

33.87      Wells Fargo Bank, National Association, asCustodian of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan (seeExhibit 33.5)

33.88      Pentalpha Surveillance LLC, as Operating Advisorof the ExchangeRight Net Leased Portfolio #27 Mortgage Loan (see Exhibit 33.71)

33.89      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan (seeExhibit 33.7)

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

33.91      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Visions Hotel Portfolio IIMortgage Loan (see Exhibit 33.10)

33.92      Argentic Services Company LP, as Special Servicerof the Visions Hotel Portfolio II Mortgage Loan

33.93      Wells Fargo Bank, National Association, as Trustee of the Visions HotelPortfolio II Mortgage Loan (Omitted. See Explanatory Notes.)

33.94      Wells Fargo Bank, National Association, asCustodian of the Visions Hotel Portfolio II Mortgage Loan (see Exhibit 33.5)

33.95      Pentalpha Surveillance LLC, as Operating Advisorof the Visions Hotel Portfolio II Mortgage Loan (see Exhibit 33.71)

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

33.97      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 125 Borinquen Place MortgageLoan (see Exhibit 33.10)

33.98      Argentic Services Company LP, as Special Servicer ofthe 125 Borinquen Place Mortgage Loan (see Exhibit 33.92)

33.99      Wells Fargo Bank, National Association, as Trustee of the 125 Borinquen PlaceMortgage Loan (Omitted. See Explanatory Notes.)

33.100    Wells Fargo Bank, National Association, asCustodian of the 125 Borinquen Place Mortgage Loan (see Exhibit 33.5)

33.101    Pentalpha Surveillance LLC, as Operating Advisorof the 125 Borinquen Place Mortgage Loan (see Exhibit 33.71)

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

33.103    Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the CIRE Equity Retail &Industrial Portfolio Mortgage Loan (see Exhibit 33.10)

33.104    Midland Loan Services, a Division of PNC Bank, NationalAssociation, as Special Servicer of the CIRE Equity Retail & IndustrialPortfolio Mortgage Loan (see Exhibit 33.10)

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

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

33.107    Pentalpha Surveillance LLC, as Operating Advisorof the CIRE Equity Retail & Industrial Portfolio Mortgage Loan (see Exhibit33.71)

33.108    Wells Fargo Bank, National Association, as PrimaryServicer of the Mount Kemble Mortgage Loan (see Exhibit 33.1)

33.109    Argentic Services Company LP, as Special Servicerof the Mount Kemble Mortgage Loan (see Exhibit 33.92)

33.110    Wilmington Trust, National Association, as Trustee of the Mount Kemble MortgageLoan (Omitted. See Explanatory Notes.)

33.111    Wells Fargo Bank, National Association, asCustodian of the Mount Kemble Mortgage Loan (see Exhibit 33.5)

33.112    Pentalpha Surveillance LLC, as Operating Advisor ofthe Mount Kemble Mortgage Loan (see Exhibit 33.71)

33.113    CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Mount Kemble Mortgage Loan (see Exhibit 33.7)

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

33.115    Wells Fargo Bank, National Association, as PrimaryServicer of the Renaissance Center VI Mortgage Loan (see Exhibit 33.1)

33.116    Argentic Services Company LP, as Special Servicerof the Renaissance Center VI Mortgage Loan (see Exhibit 33.92)

33.117    Wilmington Trust, National Association, as Trustee of the Renaissance Center VIMortgage Loan (Omitted. See Explanatory Notes.)

33.118    Wells Fargo Bank, National Association, asCustodian of the Renaissance Center VI Mortgage Loan (see Exhibit 33.5)

33.119    Pentalpha Surveillance LLC, as Operating Advisorof the Renaissance Center VI Mortgage Loan (see Exhibit 33.71)

33.120    CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Renaissance Center VI Mortgage Loan (see Exhibit 33.7)

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

33.122    Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Ambler Yards Mortgage Loan(see Exhibit 33.10)

33.123    Rialto Capital Advisors, LLC, as Special Servicerof the Ambler Yards Mortgage Loan (see Exhibit 33.2)

33.124    Wilmington Trust, National Association, as Trustee of the Ambler Yards MortgageLoan (Omitted. See Explanatory Notes.)

33.125    Wells Fargo Bank, National Association, asCustodian of the Ambler Yards Mortgage Loan (see Exhibit 33.5)

33.126    Pentalpha Surveillance LLC, as Operating Advisorof the Ambler Yards Mortgage Loan (see Exhibit 33.71)

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

33.128    KeyBank National Association, as Primary Servicerof the Inland Life Storage Portfolio Mortgage Loan (see Exhibit 33.50)

33.129    LNR Partners, LLC, as Special Servicer of theInland Life Storage Portfolio Mortgage Loan

33.130    Citibank, N.A., as Trustee and Custodian of the Inland Life Storage PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.131    Park Bridge Lender Services LLC, as OperatingAdvisor of the Inland Life Storage Portfolio Mortgage Loan (see Exhibit 33.6)

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

34.1        Wells Fargo Bank, National Association, as MasterServicer

34.2        Rialto Capital Advisors, LLC, 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, as Custodian

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, asServicing Function Participant for the Custodian on and after November 1, 2021

34.10      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer

34.11      Wells Fargo Bank, National Association, as PrimaryServicer of the 188 Spear Street Mortgage Loan (see Exhibit 34.1)

34.12      Rialto Capital Advisors, LLC, as Special Servicer ofthe 188 Spear Street Mortgage Loan (see Exhibit 34.2)

34.13      Wilmington Trust, National Association, as Trustee of the 188 Spear StreetMortgage Loan (Omitted. See Explanatory Notes.)

34.14      Wells Fargo Bank, National Association, asCustodian of the 188 Spear Street Mortgage Loan (see Exhibit 34.5)

34.15      Park Bridge Lender Services LLC, as OperatingAdvisor of the 188 Spear Street Mortgage Loan (see Exhibit 34.6)

34.16      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 188 Spear Street Mortgage Loan (see Exhibit 34.7)

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

34.18      Wells Fargo Bank, National Association, as PrimaryServicer of the ExchangeRight Net Leased Portfolio 28 Mortgage Loan (seeExhibit 34.1)

34.19      Rialto Capital Advisors, LLC, as Special Servicerof the ExchangeRight Net Leased Portfolio 28 Mortgage Loan (see Exhibit 34.2)

34.20      Wilmington Trust, National Association, as Trustee of the ExchangeRight NetLeased Portfolio 28 Mortgage Loan (Omitted. See Explanatory Notes.)

34.21      Wells Fargo Bank, National Association, as Custodianof the ExchangeRight Net Leased Portfolio 28 Mortgage Loan (see Exhibit 34.5)

34.22      Park Bridge Lender Services LLC, as OperatingAdvisor of the ExchangeRight Net Leased Portfolio 28 Mortgage Loan (see Exhibit34.6)

34.23      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the ExchangeRight Net Leased Portfolio 28 Mortgage Loan (seeExhibit 34.7)

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

34.25      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Meidinger Tower Mortgage Loan(see Exhibit 34.10)

34.26      Rialto Capital Advisors, LLC, as Special Servicerof the Meidinger Tower Mortgage Loan (see Exhibit 34.2)

34.27      Wilmington Trust, National Association, as Trustee of the Meidinger TowerMortgage Loan (Omitted. See Explanatory Notes.)

34.28      Wells Fargo Bank, National Association, asCustodian of the Meidinger Tower Mortgage Loan (see Exhibit 34.5)

34.29      Park Bridge Lender Services LLC, as OperatingAdvisor of the Meidinger Tower Mortgage Loan (see Exhibit 34.6)

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

34.31      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Maui Portfolio Mortgage Loan(see Exhibit 34.10)

34.32      Rialto Capital Advisors, LLC, as Special Servicerof the Maui Portfolio Mortgage Loan (see Exhibit 34.2)

34.33      Wilmington Trust, National Association, as Trustee of the Maui PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.34      Wells Fargo Bank, National Association, asCustodian of the Maui Portfolio Mortgage Loan (see Exhibit 34.5)

34.35      Park Bridge Lender Services LLC, as OperatingAdvisor of the Maui Portfolio Mortgage Loan (see Exhibit 34.6)

34.36      Computershare Trust Company, National Association, asServicing 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 Marriott SpringHill Suites and Towneplace Suites Mortgage Loan(see Exhibit 34.1)

34.38      Rialto Capital Advisors, LLC, as Special Servicerof the Marriott SpringHill Suites and Towneplace Suites Mortgage Loan (seeExhibit 34.2)

34.39      Wilmington Trust, National Association, as Trustee of the Marriott SpringHillSuites and Towneplace Suites Mortgage Loan (Omitted. See Explanatory Notes.)

34.40      Wells Fargo Bank, National Association, asCustodian of the Marriott SpringHill Suites and Towneplace Suites Mortgage Loan(see Exhibit 34.5)

34.41      Park Bridge Lender Services LLC, as OperatingAdvisor of the Marriott SpringHill Suites and Towneplace Suites Mortgage Loan(see Exhibit 34.6)

34.42      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Marriott SpringHill Suites and Towneplace Suites MortgageLoan (see Exhibit 34.7)

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      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the ILPT Hawaii Portfolio MortgageLoan (see Exhibit 34.10)

34.45      Rialto Capital Advisors, LLC, as Special Servicerof the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 34.2)

34.46      Wells Fargo Bank, National Association, as Trustee of the ILPT Hawaii PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.47      Wells Fargo Bank, National Association, asCustodian of the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 34.5)

34.48      Park Bridge Lender Services LLC, as OperatingAdvisor of the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 34.6)

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

34.50      KeyBank National Association, as Primary Servicerof the 2 North 6th Place Mortgage Loan

34.51      Situs Holdings, LLC, as Special Servicer of the 2North 6th Place Mortgage Loan

34.52      Wells Fargo Bank, National Association, as Trustee of the 2 North 6th PlaceMortgage Loan (Omitted. See Explanatory Notes.)

34.53      Wells Fargo Bank, National Association, asCustodian of the 2 North 6th Place Mortgage Loan (see Exhibit 34.5)

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

34.55      Wells Fargo Bank, National Association, as PrimaryServicer of the Town Square Mortgage Loan (see Exhibit 34.1)

34.56      Rialto Capital Advisors, LLC, as Special Servicerof the Town Square Mortgage Loan (see Exhibit 34.2)

34.57      Wilmington Trust, National Association, as Trustee of the Town Square MortgageLoan (Omitted. See Explanatory Notes.)

34.58      Wells Fargo Bank, National Association, asCustodian of the Town Square Mortgage Loan (see Exhibit 34.5)

34.59      Park Bridge Lender Services LLC, as OperatingAdvisor of the Town Square Mortgage Loan (see Exhibit 34.6)

34.60      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Town Square Mortgage Loan (see Exhibit 34.7)

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

34.62      KeyBank National Association, as Primary Servicerof the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 34.50)

34.63      KeyBank National Association, as Special Servicerof the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 34.50)

34.64      Wells Fargo Bank, National Association, as Trustee of the 10000 Santa MonicaBoulevard Mortgage Loan (Omitted. See Explanatory Notes.)

34.65      Wells Fargo Bank, National Association, asCustodian of the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 34.5)

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

34.67      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Vanguard Portfolio MortgageLoan (see Exhibit 34.10)

34.68      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Vanguard Portfolio MortgageLoan (see Exhibit 34.10)

34.69      Wells Fargo Bank, National Association, as Trustee of the Vanguard PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.70      Wells Fargo Bank, National Association, asCustodian of the Vanguard Portfolio Mortgage Loan (see Exhibit 34.5)

34.71      Pentalpha Surveillance LLC, as Operating Advisorof the Vanguard Portfolio Mortgage Loan

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

34.73      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the SWVP Portfolio Mortgage Loan(see Exhibit 34.10)

34.74      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the SWVP Portfolio Mortgage Loan(see Exhibit 34.10)

34.75      Wells Fargo Bank, National Association, as Trustee of the SWVP PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.76      Wells Fargo Bank, National Association, asCustodian of the SWVP Portfolio Mortgage Loan (see Exhibit 34.5)

34.77      Pentalpha Surveillance LLC, as Operating Advisorof the SWVP Portfolio Mortgage Loan (see Exhibit 34.71)

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

34.79      KeyBank National Association, as Primary Servicerof the Moffett Towers II - Buildings 3 & 4 Mortgage Loan (see Exhibit34.50)

34.80      Situs Holdings, LLC, as Special Servicer of theMoffett Towers II - Buildings 3 & 4 Mortgage Loan (see Exhibit 34.51)

34.81      Wells Fargo Bank, National Association, as Trustee of the Moffett Towers II - Buildings3 & 4 Mortgage Loan (Omitted. See Explanatory Notes.)

34.82      Wells Fargo Bank, National Association, asCustodian of the Moffett Towers II - Buildings 3 & 4 Mortgage Loan (seeExhibit 34.5)

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

34.84      Wells Fargo Bank, National Association, as PrimaryServicer of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan (seeExhibit 34.1)

34.85      Greystone Servicing Company LLC (as successor to C-III Asset Management LLC),as Special Servicer of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan(Omitted. See Explanatory Notes.)

34.86      Wilmington Trust, National Association, as Trustee of the ExchangeRight NetLeased Portfolio #27 Mortgage Loan (Omitted. See Explanatory Notes.)

34.87      Wells Fargo Bank, National Association, asCustodian of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan (seeExhibit 34.5)

34.88      Pentalpha Surveillance LLC, as Operating Advisorof the ExchangeRight Net Leased Portfolio #27 Mortgage Loan (see Exhibit 34.71)

34.89      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan (seeExhibit 34.7)

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

34.91      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Visions Hotel Portfolio IIMortgage Loan (see Exhibit 34.10)

34.92      Argentic Services Company LP, as Special Servicerof the Visions Hotel Portfolio II Mortgage Loan

34.93      Wells Fargo Bank, National Association, as Trustee of the Visions HotelPortfolio II Mortgage Loan (Omitted. See Explanatory Notes.)

34.94      Wells Fargo Bank, National Association, asCustodian of the Visions Hotel Portfolio II Mortgage Loan (see Exhibit 34.5)

34.95      Pentalpha Surveillance LLC, as Operating Advisorof the Visions Hotel Portfolio II Mortgage Loan (see Exhibit 34.71)

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

34.97      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 125 Borinquen Place MortgageLoan (see Exhibit 34.10)

34.98      Argentic Services Company LP, as Special Servicerof the 125 Borinquen Place Mortgage Loan (see Exhibit 34.92)

34.99      Wells Fargo Bank, National Association, as Trustee of the 125 Borinquen PlaceMortgage Loan (Omitted. See Explanatory Notes.)

34.100    Wells Fargo Bank, National Association, asCustodian of the 125 Borinquen Place Mortgage Loan (see Exhibit 34.5)

34.101    Pentalpha Surveillance LLC, as Operating Advisorof the 125 Borinquen Place Mortgage Loan (see Exhibit 34.71)

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

34.103    Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the CIRE Equity Retail &Industrial Portfolio Mortgage Loan (see Exhibit 34.10)

34.104    Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the CIRE Equity Retail &Industrial Portfolio Mortgage Loan (see Exhibit 34.10)

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

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

34.107    Pentalpha Surveillance LLC, as Operating Advisorof the CIRE Equity Retail & Industrial Portfolio Mortgage Loan (see Exhibit34.71)

34.108    Wells Fargo Bank, National Association, as Primary Servicerof the Mount Kemble Mortgage Loan (see Exhibit 34.1)

34.109    Argentic Services Company LP, as Special Servicerof the Mount Kemble Mortgage Loan (see Exhibit 34.92)

34.110    Wilmington Trust, National Association, as Trustee of the Mount Kemble MortgageLoan (Omitted. See Explanatory Notes.)

34.111    Wells Fargo Bank, National Association, asCustodian of the Mount Kemble Mortgage Loan (see Exhibit 34.5)

34.112    Pentalpha Surveillance LLC, as Operating Advisorof the Mount Kemble Mortgage Loan (see Exhibit 34.71)

34.113    CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Mount Kemble Mortgage Loan (see Exhibit 34.7)

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

34.115    Wells Fargo Bank, National Association, as PrimaryServicer of the Renaissance Center VI Mortgage Loan (see Exhibit 34.1)

34.116    Argentic Services Company LP, as Special Servicerof the Renaissance Center VI Mortgage Loan (see Exhibit 34.92)

34.117    Wilmington Trust, National Association, as Trustee of the Renaissance Center VIMortgage Loan (Omitted. See Explanatory Notes.)

34.118    Wells Fargo Bank, National Association, asCustodian of the Renaissance Center VI Mortgage Loan (see Exhibit 34.5)

34.119    Pentalpha Surveillance LLC, as Operating Advisorof the Renaissance Center VI Mortgage Loan (see Exhibit 34.71)

34.120    CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Renaissance Center VI Mortgage Loan (see Exhibit 34.7)

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

34.122    Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Ambler Yards Mortgage Loan(see Exhibit 34.10)

34.123    Rialto Capital Advisors, LLC, as Special Servicerof the Ambler Yards Mortgage Loan (see Exhibit 34.2)

34.124    Wilmington Trust, National Association, as Trustee of the Ambler Yards MortgageLoan (Omitted. See Explanatory Notes.)

34.125    Wells Fargo Bank, National Association, asCustodian of the Ambler Yards Mortgage Loan (see Exhibit 34.5)

34.126    Pentalpha Surveillance LLC, as Operating Advisorof the Ambler Yards Mortgage Loan (see Exhibit 34.71)

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

34.128    KeyBank National Association, as Primary Servicerof the Inland Life Storage Portfolio Mortgage Loan (see Exhibit 34.50)

34.129    LNR Partners, LLC, as Special Servicer of theInland Life Storage Portfolio Mortgage Loan

34.130    Citibank, N.A., as Trustee and Custodian of the Inland Life Storage PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.131    Park Bridge Lender Services LLC, as OperatingAdvisor of the Inland Life Storage Portfolio Mortgage Loan (see Exhibit 34.6)

35           Servicer compliance statements.

35.1        Wells Fargo Bank, National Association, as MasterServicer

35.2        Rialto Capital Advisors, LLC, as Special Servicer

35.3        Wells Fargo Bank, National Association, asCertificate Administrator

35.4        Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer

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

35.6        Wells Fargo Bank, National Association, as PrimaryServicer of the 188 Spear Street Mortgage Loan (see Exhibit 35.1)

35.7        Rialto Capital Advisors, LLC, as Special Servicerof the 188 Spear Street Mortgage Loan (see Exhibit 35.2)

35.8        Wells Fargo Bank, National Association, as PrimaryServicer of the ExchangeRight Net Leased Portfolio 28 Mortgage Loan (seeExhibit 35.1)

35.9        Rialto Capital Advisors, LLC, as Special Servicerof the ExchangeRight Net Leased Portfolio 28 Mortgage Loan (see Exhibit 35.2)

35.10      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Meidinger Tower Mortgage Loan(see Exhibit 35.4)

35.11      Rialto Capital Advisors, LLC, as Special Servicerof the Meidinger Tower Mortgage Loan (see Exhibit 35.2)

35.12      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Maui Portfolio Mortgage Loan(see Exhibit 35.4)

35.13      Rialto Capital Advisors, LLC, as Special Servicerof the Maui Portfolio Mortgage Loan (see Exhibit 35.2)

35.14      Wells Fargo Bank, National Association, as PrimaryServicer of the Marriott SpringHill Suites and Towneplace Suites Mortgage Loan(see Exhibit 35.1)

35.15      Rialto Capital Advisors, LLC, as Special Servicerof the Marriott SpringHill Suites and Towneplace Suites Mortgage Loan (seeExhibit 35.2)

35.16      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the ILPT Hawaii Portfolio MortgageLoan (see Exhibit 35.4)

35.17      Rialto Capital Advisors, LLC, as Special Servicerof the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 35.2)

35.18      KeyBank National Association, as Primary Servicerof the 2 North 6th Place Mortgage Loan

35.19      Situs Holdings, LLC, as Special Servicer of the 2North 6th Place Mortgage Loan

35.20      Wells Fargo Bank, National Association, as PrimaryServicer of the Town Square Mortgage Loan (see Exhibit 35.1)

35.21      Rialto Capital Advisors, LLC, as Special Servicerof the Town Square Mortgage Loan (see Exhibit 35.2)

35.22      KeyBank National Association, as Primary Servicerof the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 35.18)

35.23      KeyBank National Association, as Special Servicerof the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 35.18)

35.24      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Vanguard Portfolio MortgageLoan (see Exhibit 35.4)

35.25      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Vanguard Portfolio MortgageLoan (see Exhibit 35.4)

35.26      Midland Loan Services, a Division of PNC Bank, NationalAssociation, as Primary Servicer of the SWVP Portfolio Mortgage Loan (seeExhibit 35.4)

35.27      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the SWVP Portfolio Mortgage Loan(see Exhibit 35.4)

35.28      KeyBank National Association, as Primary Servicerof the Moffett Towers II - Buildings 3 & 4 Mortgage Loan (see Exhibit35.18)

35.29      Situs Holdings, LLC, as Special Servicer of theMoffett Towers II - Buildings 3 & 4 Mortgage Loan (see Exhibit 35.19)

35.30      Wells Fargo Bank, National Association, as PrimaryServicer of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan (seeExhibit 35.1)

35.31      Greystone Servicing Company LLC (as successor to C-III Asset Management LLC),as Special Servicer of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan(Omitted. See Explanatory Notes.)

35.32      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Visions Hotel Portfolio IIMortgage Loan (see Exhibit 35.4)

35.33      Argentic Services Company LP, as Special Servicer of the Visions HotelPortfolio II Mortgage Loan (Omitted. See Explanatory Notes.)

35.34      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 125 Borinquen Place Mortgage Loan(see Exhibit 35.4)

35.35      Argentic Services Company LP, as Special Servicer of the 125 Borinquen PlaceMortgage Loan (Omitted. See Explanatory Notes.)

35.36      Midland Loan Services, a Division of PNC Bank, NationalAssociation, as Primary Servicer of the CIRE Equity Retail & IndustrialPortfolio Mortgage Loan (see Exhibit 35.4)

35.37      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the CIRE Equity Retail &Industrial Portfolio Mortgage Loan (see Exhibit 35.4)

35.38      Wells Fargo Bank, National Association, as PrimaryServicer of the Mount Kemble Mortgage Loan (see Exhibit 35.1)

35.39      Argentic Services Company LP, as Special Servicer of the Mount Kemble MortgageLoan (Omitted. See Explanatory Notes.)

35.40      Wells Fargo Bank, National Association, as PrimaryServicer of the Renaissance Center VI Mortgage Loan (see Exhibit 35.1)

35.41      Argentic Services Company LP, as Special Servicer of the Renaissance Center VIMortgage Loan (Omitted. See Explanatory Notes.)

35.42      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Ambler Yards Mortgage Loan(see Exhibit 35.4)

35.43      Rialto Capital Advisors, LLC, as Special Servicerof the Ambler Yards Mortgage Loan (see Exhibit 35.2)

35.44      KeyBank National Association, as Primary Servicerof the Inland Life Storage Portfolio Mortgage Loan (see Exhibit 35.18)

35.45      LNR Partners, LLC, as Special Servicer of theInland Life Storage Portfolio Mortgage Loan

99.1        MortgageLoan Purchase Agreement, dated as of August 9, 2019, among Barclays CapitalReal Estate Inc., Barclays Capital Holdings Inc., and Barclays CommercialMortgage Securities LLC (filed as Exhibit 99.1 to the registrant’s CurrentReport on Form 8-K filed on August 28, 2019 under Commission File No. 333-226850-03and incorporated by reference herein).

99.2        MortgageLoan Purchase Agreement, dated as of August 9, 2019, among Societe GeneraleFinancial Corporation, Societe Generale Financial Corporation, and BarclaysCommercial Mortgage Securities LLC (filed as Exhibit 99.2 to the registrant’sCurrent Report on Form 8-K filed on August 28, 2019 under Commission File No.333-226850-03 and incorporated by reference herein).

99.3        MortgageLoan Purchase Agreement, dated as of August 9, 2019, between UBS AG, by andthrough its branch office at 1285 Avenue of the Americas, New York, New Yorkand Barclays Commercial Mortgage Securities LLC (filed as Exhibit 99.3 to theregistrant’s Current Report on Form 8-K filed on August 28, 2019 underCommission File No. 333-226850-03 and incorporated by reference herein).

99.4        MortgageLoan Purchase Agreement, dated as of August 9, 2019, between Starwood MortgageCapital LLC and Barclays Commercial Mortgage Securities LLC (filed as Exhibit99.4 to the registrant’s Current Report on Form 8-K filed on August 28, 2019under Commission File No. 333-226850-03 and incorporated by reference herein).

99.5        MortgageLoan Purchase Agreement, dated as of August 9, 2019, between Rialto Real EstateFund III – Debt, LP and Barclays Commercial Mortgage Securities LLC (filed asExhibit 99.5 to the registrant’s Current Report on Form 8-K filed on August 28,2019 under Commission File No. 333-226850-03 and incorporated by referenceherein).

99.6        MortgageLoan Purchase Agreement, dated as of August 9, 2019, between CIBC Inc. andBarclays Commercial Mortgage Securities LLC (filed as Exhibit 99.6 to theregistrant’s Current Report on Form 8-K filed on August 28, 2019 underCommission File No. 333-226850-03 and incorporated by reference herein).

99.7        MortgageLoan Purchase Agreement, dated as of August 9, 2019, between Natixis RealEstate Capital LLC and Barclays Commercial Mortgage Securities LLC (filed asExhibit 99.7 to the registrant’s Current Report on Form 8-K filed on August 28,2019 under Commission File No. 333-226850-03 and incorporated by referenceherein).

(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.

Barclays Commercial MortgageSecurities LLC(Depositor)

/s/ DanielVinson

DanielVinson, Chief Executive Officer

(senior officer in charge ofsecuritization of the depositor)

Date: March 14, 2022