**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, 2023or**

**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: 333-226850-04**

**Central Index Key Number of the issuing entity:0001790441**

**BBCMS Mortgage Trust 2019-C5**

**(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: 0001089877**

**KeyBank National Association**

**(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)**

** **

**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: 0001592182**

**LMF Commercial, LLC**

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

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

** **

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

**BSPRT CMBS Finance, LLC**

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

** **

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

**the issuing entity)** | **38-4128798**

**38-4128799**

**38-7235613**

**(I.R.S. Employer**

**Identification Numbers)** |
|------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------|

**c/o Computershare Trust Company, National Association, as agent for**

**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 to Section 12(g) of theAct:  None.

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

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

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

Indicate by check mark whether the registrant has submittedelectronically every Interactive Data File required to be submitted pursuant toRule 405 of Regulation S-T (Section 232.405 of this chapter) during thepreceding 12 months (or for such shorter period that the registrant wasrequired to submit such files).

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                                                                                                       Accelerated filer                                     o

Non-acceleratedfiler          ⌧                                                                                                       Smaller reportingcompany                    o

                                                                                                                                                       Emerging growthcompany                    o

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

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

If securities are registered pursuant to Section 12(b) of theAct, indicate by check mark whether the financial statements of the registrantincluded in the filing reflect the correction of an error to previously issuedfinancial statements. o

Indicate by check mark whether any of those error correctionsare restatements that required a recovery analysis of incentive-basedcompensation received by any of the registrant’s executive officers during therelevant recovery period pursuant to §240.10D-1(b). o

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

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

Not applicable.

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

Not applicable.

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

Not applicable.

**DOCUMENTS INCORPORATED BY REFERENCE**

** **

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

Not applicable.

 

** **

**EXPLANATORY NOTES**

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the NEMA San Francisco Mortgage Loan, whichconstituted approximately 4.0% of the asset pool of the issuing entity as ofits cut-off date.  The NEMA San Francisco Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the NEMA SanFrancisco Mortgage Loan, three other *pari passu* loans and threesubordinate companion loans, which are not assets of the issuing entity. A *paripassu* portion of the loan combination was securitized in the NatixisCommercial Mortgage Securities Trust 2019-NEMA transaction (the “NCMS2019-NEMA Transaction”). This loan combination, including the NEMA SanFrancisco Mortgage Loan, is being serviced and administered pursuant to thetrust and servicing agreement for the NCMS 2019-NEMA 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 10000 Santa Monica Boulevard Mortgage Loan,which constituted approximately 3.5% 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 4.3 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Vanguard Portfolio Mortgage Loan, whichconstituted approximately 0.5% of the asset pool of the issuing entity as ofits cut-off date.  The Vanguard Portfolio Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the VanguardPortfolio Mortgage Loan, five other *pari passu* loans and one subordinatecompanion loan, which are not assets of the issuing entity. A *pari passu*portion of the loan combination was securitized in the BBCMS Mortgage Trust2019-C3 transaction, Commission File Number 333-226850-02 (the “BBCMS2019-C3 Transaction”). This loan combination, including the VanguardPortfolio Mortgage Loan, is being serviced and administered pursuant to thepooling and servicing agreement for the BBCMS 2019-C3 Transaction, which isincorporated by reference as Exhibit 4.4 to this Annual Report on Form 10-K.

The ExhibitIndex describes exhibits provided by certain parties (in their capacitiesindicated on the Exhibit Index) with respect to the Moffett Towers II –Buildings 3 & 4 Mortgage Loan, which constituted approximately 2.5% of theasset pool of the issuing entity as of its cut-off date.  The MoffettTowers II – Buildings 3 & 4 Mortgage Loan is an asset of the issuing entityand is part of a loan combination that includes the Moffett Towers II –Buildings 3 & 4 Mortgage Loan, ten other *pari passu* loans and threesubordinate companion loans, which are not assets of the issuing entity. A *paripassu* portion of the loan combination was securitized in the MFTII2019-B3B4 Mortgage Trust transaction (the “MFTII 2019-B3B4 Transaction”).This loan combination, including the Moffett Towers II – Buildings 3 & 4Mortgage Loan, is being serviced and administered pursuant to the trust andservicing agreement for the MFTII 2019-B3B4 Transaction, which is incorporatedby 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 Uline Arena Mortgage Loan, which constitutedapproximately 3.6% of the asset pool of the issuing entity as of its cut-offdate.  The Uline Arena Mortgage Loan is an asset of the issuing entity andis part of a loan combination that includes the Uline Arena Mortgage Loan andfive other *pari passu* loans, which are not assets of the issuing entity.A *pari passu* portion of the loan combination was securitized in the CD2019-CD8 Mortgage Trust transaction, Commission File Number 333-226943-03 (the“CD 2019-CD8 Transaction”). This loan combination, including the UlineArena Mortgage Loan, is being serviced and administered pursuant to the poolingand servicing agreement for the CD 2019-CD8 Transaction, which is incorporatedby 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 Bison Portfolio Mortgage Loan, whichconstituted approximately 2.0% of the asset pool of the issuing entity as ofits cut-off date.  The Bison Portfolio Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the BisonPortfolio Mortgage Loan and one other *pari passu* loan, which is not anasset of the issuing entity. The other *pari passu* portion of the loancombination was securitized in the CSAIL 2019-C17 Commercial Mortgage Trusttransaction, Commission File Number 333-227081-03 (the “CSAIL 2019-C17Transaction”). This loan combination, including the Bison PortfolioMortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the CSAIL 2019-C17 Transaction, which is incorporatedby reference as Exhibit 4.7 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 Presidential City Mortgage Loan, whichconstituted approximately 4.5% of the asset pool of the issuing entity as ofits cut-off date.  The Presidential City Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the PresidentialCity Mortgage Loan, two other *pari passu* loans and one subordinatecompanion loan, which are not assets of the issuing entity. A *pari passu*portion of the loan combination was securitized in the SG Commercial MortgageSecurities Trust 2019-PREZ transaction (the “SGCMS 2019-PREZ Transaction”).This loan combination, including the Presidential City Mortgage Loan, is beingserviced and administered pursuant to the trust and servicing agreement for theSGCMS 2019-PREZ Transaction, which is incorporated by reference as Exhibit 4.8to 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 GNL Office and Industrial Portfolio MortgageLoan, the Inland Life Storage Portfolio Mortgage Loan and the Ocean Edge Resort& Golf Club Mortgage Loan, which constituted approximately 6.6%, 3.7% and3.0%, respectively, of the asset pool of the issuing entity as of its cut-offdate.  The GNL Office and Industrial Portfolio Mortgage Loan, the InlandLife Storage Portfolio Mortgage Loan and the Ocean Edge Resort & Golf ClubMortgage Loan are each an asset of the issuing entity and are each part of aloan combination that includes (a) with respect to the GNL Office andIndustrial Portfolio Mortgage Loan, five other *pari passu* loans, whichare not assets of the issuing entity, (b) with respect to the Inland LifeStorage Portfolio Mortgage Loan, three other *pari passu* loans, which arenot assets of the issuing entity or (c) with respect to the Ocean Edge Resort& Golf Club Mortgage Loan, one other *pari passu* loan, which is notan asset of the issuing entity. A *pari passu* portion of each loancombination was securitized in the CF 2019-CF2 Mortgage Trust transaction, CommissionFile Number 333-228697-02 (the “CF 2019-CF2 Transaction”). These loancombinations, including the GNL Office and Industrial Portfolio Mortgage Loan,the Inland Life Storage Portfolio Mortgage Loan and the Ocean Edge Resort &Golf Club Mortgage Loan, are being serviced and administered pursuant to thepooling and servicing agreement for the CF 2019-CF2 Transaction, which isincorporated by reference as Exhibit 4.9 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 Ceasar’s Bay Shopping Center Mortgage Loanand the Equinix Data Center Mortgage Loan, which constituted approximately 4.2%and 4.0%, respectively, of the asset pool of the issuing entity as of itscut-off date.  The Ceasar’s Bay Shopping Center Mortgage Loan and theEquinix Data Center Mortgage Loan are each an asset of the issuing entity andare each part of a loan combination that includes (a) with respect to theCeasar’s Bay Shopping Center Mortgage Loan, one other *pari passu* loan,which is not an asset of the issuing entity or (b) with respect to the EquinixData Center Mortgage Loan, two other *pari passu* loans, which are notassets of the issuing entity. A *pari passu* portion of each loancombination was securitized in the Wells Fargo Commercial Mortgage Trust2019-C53 transaction, Commission File Number 333-226486-09 (the “WFCM2019-C53 Transaction”). These loan combinations, including the Ceasar’s BayShopping Center Mortgage Loan and the Equinix Data Center Mortgage Loan, arebeing serviced and administered pursuant to the pooling and servicing agreementfor the WFCM 2019-C53 Transaction, which is incorporated by reference asExhibit 4.10 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 NMR Pharmacy Portfolio Mortgage Loan, whichconstituted approximately 1.4% of the asset pool of the issuing entity as ofits cut-off date.  The NMR Pharmacy Portfolio Mortgage Loan is an asset ofthe issuing entity and is part of a loan combination that includes the NMRPharmacy Portfolio Mortgage Loan and one other *pari passu* loan, which isnot an asset of the issuing entity. This loan combination, including the NMRPharmacy Portfolio Mortgage Loan, was serviced under the Pooling and ServicingAgreement for the issuing entity prior to the closing of the securitization ofthe other *pari passu* portion of the NMR Pharmacy Portfolio loancombination in the Wells Fargo Commercial Mortgage Trust 2019-C54 transaction,Commission File Number 333-226486-11 (the “WFCM 2019-C54 Transaction”). After the closing of the WFCM 2019-C54 Transaction on December 3, 2019, thisloan combination, including the NMR Pharmacy Portfolio Mortgage Loan was, andwill continue to be, serviced and administered pursuant to the pooling andservicing agreement with respect to the WFCM 2019-C54 Transaction, which isincorporated by reference as Exhibit 4.11 to this Annual Report on Form 10-K.

The master servicer of a poolingand servicing agreement or trust and servicing agreement also functions as theprimary servicer of the related mortgage loans serviced and administeredpursuant to such agreement unless a separate primary servicer is identifiedherein.  If this report does not identify a separate primary servicer, theservicer compliance statement provided by the master servicer under any suchagreement also encompasses its responsibilities as primary servicer of therelated mortgage loan or mortgage loans.

KeyBank National Association isthe master servicer and special servicer of the mortgage loans serviced underthe Pooling and Servicing Agreement, the primary servicer of the GNL Office andIndustrial Portfolio Mortgage Loan, the Presidential City Mortgage Loan, theNEMA San Francisco Mortgage Loan, the Inland Life Storage Portfolio MortgageLoan, the Ocean Edge Resort & Golf Club Mortgage Loan and the MoffettTowers II – Buildings 3 & 4 Mortgage Loan and the primary servicer andspecial servicer of the 10000 Santa Monica Boulevard Mortgage Loan. As aresult, KeyBank National Association is a “servicer” as defined in Item1108(a)(2)(iii) of Regulation AB, in the capacities described above, because itis servicing mortgage loans that constituted 10% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria, accountants’ attestation reports and servicercompliance statements delivered by KeyBank National Association in thecapacities described above are listed in the Exhibit Index.

Wells Fargo Bank, NationalAssociation is the certificate administrator of the mortgage loans servicedunder the Pooling and Servicing Agreement and the primary servicer of theCeasar’s Bay Shopping Center Mortgage Loan, the Equinix Data Center MortgageLoan and the NMR Pharmacy Portfolio Mortgage Loan. As a result, Wells FargoBank, National Association is a “servicer” as defined in Item 1108(a)(2)(iii)of Regulation 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 Wells Fargo Bank, National Association in the capacities describedabove are listed in the Exhibit Index.

Wells Fargo Bank, NationalAssociation is the custodian of the mortgage loans serviced under the Poolingand Servicing Agreement, the Presidential City Mortgage Loan, the Ceasar’s BayShopping Center Mortgage Loan, the Equinix Data Center Mortgage Loan, the NEMASan Francisco Mortgage Loan, the Uline Arena Mortgage Loan, the 10000 SantaMonica Boulevard Mortgage Loan, the Moffett Towers II – Buildings 3 & 4Mortgage Loan, the Bison Portfolio Mortgage Loan, the NMR Pharmacy PortfolioMortgage Loan and the Vanguard Portfolio Mortgage Loan.  As a result,Wells Fargo Bank, National Association is a servicing function participant inthe capacities described above, because it is servicing mortgage loans thatconstituted 5% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria andaccountants’ attestation reports delivered by Wells Fargo Bank, NationalAssociation in the capacities described above are listed in the Exhibit Index.

Pentalpha Surveillance LLC is theoperating advisor of the mortgage loans serviced under the Pooling andServicing Agreement and the Vanguard 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.

Situs Holdings, LLC is the specialservicer of the Presidential City Mortgage Loan, the NEMA San FranciscoMortgage Loan and the Moffett Towers II – Buildings 3 & 4 Mortgage Loan. Asa result, Situs Holdings, LLC is a “servicer” as defined in Item1108(a)(2)(iii) of Regulation AB, in the capacities described above, because itis servicing mortgage loans that constituted 10% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria, accountants’ attestation reports and servicercompliance statements delivered by Situs Holdings, LLC in the capacitiesdescribed above are listed in the Exhibit Index.

Midland Loan Services, a Divisionof PNC Bank, National Association is the special servicer of the Ceasar’s BayShopping Center Mortgage Loan and the Equinix Data Center Mortgage Loan, theprimary servicer of the Uline Arena Mortgage Loan and the Bison PortfolioMortgage Loan and the primary servicer and special servicer of the VanguardPortfolio Mortgage Loan, which constituted approximately 4.2%, 4.0%, 3.6%, 2.0%and 0.5%, respectively, of the asset pool of the issuing entity as of itscut-off date. In accordance with the Compliance and Disclosure Interpretations,Section 200.03 (Rules 13a-18 and 15d-18, Servicer’s Assessment of Compliance),this percentage must be reduced *pro rata*because it was only acting asspecial servicer of the Ceasar’s Bay Shopping Center Mortgage Loan and theEquinix Data Center Mortgage Loan from January 1, 2023 to April 23, 2023. As aresult, Midland Loan Services, a Division of PNC Bank, National Association isan unaffiliated party that, as a result of such *pro rata* reduction ofsuch percentage, is not a “servicer” that meets the criteria in Item1108(a)(2)(i) through (iii) of Regulation AB and so no servicer compliancestatement is required.

LNR Partners, LLC is the specialservicer of the GNL Office and Industrial Portfolio Mortgage Loan, the InlandLife Storage Portfolio Mortgage Loan, the Uline Arena Mortgage Loan and theOcean Edge Resort & Golf Club Mortgage Loan. As a result, LNR Partners, LLCis a “servicer” as defined in Item 1108(a)(2)(iii) of Regulation AB, in thecapacities described above, because it is servicing mortgage loans that constituted10% or more of the assets of the issuing entity as of its cut-off date. Theassessments of compliance with applicable servicing criteria, accountants’attestation reports and servicer compliance statements delivered by LNRPartners, LLC in the capacities described above are listed in the ExhibitIndex.

Park Bridge Lender Services LLC isthe operating advisor of the GNL Office and Industrial Portfolio Mortgage Loan,the Ceasar’s Bay Shopping Center Mortgage Loan, the Equinix Data CenterMortgage Loan, the Inland Life Storage Portfolio Mortgage Loan, the Uline ArenaMortgage Loan, the Ocean Edge Resort & Golf Club Mortgage Loan, the BisonPortfolio Mortgage Loan and the NMR Pharmacy Portfolio Mortgage Loan.  Asa result, Park Bridge Lender Services LLC is a servicing function participantin the capacities described above, because it is servicing mortgage loans thatconstituted 5% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria andaccountants’ attestation reports delivered by Park Bridge Lender Services LLCin the capacities described above are listed in the Exhibit Index.

Citibank, N.A. is the custodian ofthe GNL Office and Industrial Portfolio Mortgage Loan, the Inland Life StoragePortfolio Mortgage Loan and the Ocean Edge Resort & Golf Club MortgageLoan.  As a result, Citibank, N.A. is a servicing function participant inthe capacities described above, because it is servicing mortgage loans thatconstituted 5% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria andaccountants’ attestation reports delivered by Citibank, N.A. in the capacitiesdescribed above are listed in the Exhibit Index, and exclude the servicingcriteria set forth in Items 1122(d)(4)(i) and 1122(d)(4)(ii) of RegulationAB,  relating to the maintenance of collateral or security on pool assetsas required by the pooling and servicing agreement for the CF 2019-CF2 Transactionand the safeguarding of pool assets and related documents as required by thepooling and servicing agreement for the CF 2019-CF2 Transaction which servicingcriteria have been assessed by U.S. Bank National Association, as a servicingfunction participant, as described below in these Explanatory Notes.

K-Star Asset Management LLC is thespecial servicer of the Ceasar’s Bay Shopping Center Mortgage Loan on and afterApril 24, 2023 and the Equinix Data Center Mortgage Loan onand after April 24, 2023.  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 K-Star AssetManagement LLC and an accountants’ attestation report pursuant to Item 1122 ofRegulation AB because K-Star Asset Management LLC is servicing more than 5% ofthe pool assets.  However, the Depositor is not required to include inthis Annual Report on Form 10-K a servicer compliance statement pursuant toItem 1123 of Regulation AB of K-Star Asset Management LLC because K-Star AssetManagement LLC is an unaffiliated servicer servicing less than 10% of poolassets.

Wells Fargo Bank, NationalAssociation acts as trustee of the mortgage loans serviced under the Poolingand Servicing Agreement, the NEMA San Francisco Mortgage Loan, the 10000 SantaMonica Boulevard Mortgage Loan, the Vanguard Portfolio Mortgage Loan, theMoffett Towers II – Buildings 3 & 4 Mortgage Loan, the Uline Arena MortgageLoan, the Bison Portfolio Mortgage Loan and the Presidential City MortgageLoan.  Pursuant to the Pooling and Servicing Agreement, the trust andservicing agreement for the NCMS 2019-NEMA 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, the pooling and servicing agreement forthe CD 2019-CD8 Transaction, the pooling and servicing agreement for the CSAIL2019-C17 Transaction and the trust and servicing agreement for the SGCMS2019-PREZ Transaction, the trustee is required to provide an assessment ofcompliance with applicable servicing criteria solely with respect to Item1122(d)(2)(iii) of Regulation AB (regarding advances of funds or guaranteesregarding collections, cash flows or distributions, and any interest or otherfees charged for such advances, are made, reviewed and approved as specified inthe transaction agreements). However, during the reporting period, the trusteedid not perform any servicing function with respect to the servicing 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 mortgage loans serviced under the Pooling and Servicing Agreement, the NEMASan Francisco Mortgage Loan, the 10000 Santa Monica Boulevard Mortgage Loan,the Vanguard Portfolio Mortgage Loan, the Moffett Towers II – Buildings 3 &4 Mortgage Loan, the Uline Arena Mortgage Loan, the Bison Portfolio MortgageLoan and the Presidential City Mortgage Loan have delivered one or moreassessments of compliance with respect to Item 1122(d)(2)(iii) of RegulationAB.

Citibank, N.A. acts as trustee ofthe GNL Office and Industrial Portfolio Mortgage Loan, the Inland Life StoragePortfolio Mortgage Loan and the Ocean Edge Resort & Golf Club MortgageLoan.  Pursuant to the pooling and servicing agreement for the CF 2019-CF2Transaction, the trustee is required to provide an assessment of compliancewith applicable servicing criteria solely with respect to Item 1122(d)(2)(iii)of Regulation AB (regarding advances of funds or guarantees regardingcollections, cash flows or distributions, and any interest or other feescharged for such advances, are made, reviewed and approved as specified in thetransaction agreements). However, during the reporting period, the trustee didnot 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 the assessmentof compliance with applicable servicing criteria and accountant’s attestationreport for the subject transaction.  As a result, this Annual Report onForm 10-K does not include an assessment of compliance with applicableservicing criteria of the trustee. One or more other servicers of the GNLOffice and Industrial Portfolio Mortgage Loan, the Inland Life StoragePortfolio Mortgage Loan and the Ocean Edge Resort & Golf Club Mortgage Loanhave delivered one or more assessments of compliance with respect to Item1122(d)(2)(iii) of Regulation AB.

Wilmington Trust, NationalAssociation acts as trustee of the Ceasar’s Bay Shopping Center Mortgage Loan,the Equinix Data Center Mortgage Loan and the NMR Pharmacy Portfolio MortgageLoan.  Pursuant to the pooling and servicing agreement for the WFCM2019-C53 Transaction and the pooling and servicing agreement for the WFCM2019-C54 Transaction, the trustee is required to provide an assessment ofcompliance with applicable servicing criteria solely with respect to Item1122(d)(2)(iii) of Regulation AB (regarding advances of funds or guaranteesregarding collections, cash flows or distributions, and any interest or otherfees charged for such advances, are made, reviewed and approved as specified inthe transaction agreements). However, during the reporting period, the trusteedid not perform any servicing function with respect to the servicing 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’s attestationreport for the subject transaction.  As a result, this Annual Report onForm 10-K does not include an assessment of compliance with applicableservicing criteria of the trustee. One or more other servicers of the Ceasar’sBay Shopping Center Mortgage Loan, the Equinix Data Center Mortgage Loan andthe NMR Pharmacy Portfolio Mortgage Loan have delivered one or more assessmentsof compliance with respect to Item 1122(d)(2)(iii) of Regulation AB.

This Annual Report on Form 10-Kincludes an assessment of compliance with applicable servicing criteria and anaccountant’s attestation report from U.S. Bank National Association. Thisentity was engaged by Citibank, N.A., as trustee and custodian of the GNLOffice and Industrial Portfolio Mortgage Loan, the Inland Life StoragePortfolio Mortgage Loan and the Ocean Edge Resort & Golf Club MortgageLoan, to perform certain custodial services. These custodial services areservicing functions included within the servicing criteria set forth in Items1122(d)(4)(i) and 1122(d)(4)(ii) of Regulation AB. Therefore, under theprinciples-based definition of “servicer” set forth in Item 1101(j) orRegulation 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 assessments of compliance with applicable servicing criteria andaccountants’ attestation reports from CoreLogic Solutions, LLC.  Thisentity was engaged by the primary servicer of the Ceasar’s Bay Shopping CenterMortgage Loan, the Equinix Data Center Mortgage Loan and the NMR PharmacyPortfolio 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-K includes an assessment ofcompliance with applicable servicing criteria, accountants’ attestation reportand servicer compliance statement from Computershare Trust Company, NationalAssociation (“CTCNA”).  CTCNA was engaged by Wells Fargo Bank,National Association (“Wells Fargo”), in its capacity as certificateadministrator and custodian, to perform certain specified servicing functionsidentified in the assessment of compliance with applicable servicing criteriaand accountants’ attestation reports.  Wells Fargo engaged CTCNA in connectionwith the sale of Wells Fargo’s corporate trust services business to CTCNA andits affiliates.  Further, under the principles-based definition of“servicer” set forth in Item 1101(j) of Regulation AB that looks to thefunctions that an entity performs, this party is a “servicer” for the purposesof Item 1123 of Regulation AB.  *See* Compliance and DisclosureInterpretations, Section 301.01 (Item 1101(j)).

The assessments of compliance withapplicable servicing criteria, accountants’ attestation reports and servicercompliance statements of the certificate administrator of the NEMA SanFrancisco Mortgage Loan, the 10000 Santa Monica Boulevard Mortgage Loan, theVanguard Portfolio Mortgage Loan, the Moffett Towers II – Buildings 3 & 4Mortgage Loan, the Uline Arena Mortgage Loan, the Bison Portfolio MortgageLoan, the Presidential City Mortgage Loan, the Ceasar’s Bay Shopping CenterMortgage Loan, the Equinix Data Center Mortgage Loan, the NMR PharmacyPortfolio Mortgage Loan, the GNL Office and Industrial Portfolio Mortgage Loan,the Inland Life Storage Portfolio Mortgage Loan and the Ocean Edge Resort &Golf Club Mortgage Loan are omitted from this Annual Report on Form 10-K as thecertificate administrator pursuant to the related pooling and servicing agreementor trust and servicing agreement does not perform any activities that addressservicing criteria with respect to the issuing entity and because they are eachnot a “servicer” that meets the criteria in Item 1108(a)(2)(i) through (iii) ofRegulation AB.

With respect to the *pari passu*loan combinations that include the Vanguard Portfolio Mortgage Loan, the UlineArena Mortgage Loan, the Bison Portfolio Mortgage Loan, the Ceasar’s BayShopping Center Mortgage Loan, the Equinix Data Center Mortgage Loan and theNMR Pharmacy Portfolio Mortgage Loan, (i) the reports on assessment ofcompliance with servicing criteria and attestation reports on assessment ofcompliance with servicing criteria of 3650 REIT Loan Servicing LLC as specialservicer of the Bison Portfolio Mortgage Loan and Argentic Services Company LPas special servicer of the NMR Pharmacy Portfolio Mortgage Loan, listed on theExhibit Index are omitted from this Annual Report on Form 10-K as they are notrequired to be included on this Annual Report on Form 10-K per Instruction 3 toItem 1122 of Regulation AB because they are parties performing activities thataddress servicing criteria relating to 5% or less of the assets of the issuingentity; and (ii) the servicer compliance statements of 3650 REIT Loan ServicingLLC as special servicer of the Bison Portfolio Mortgage Loan, K-Star AssetManagement LLC as special servicer of the Ceasar’s Bay Shopping Center MortgageLoan on and after April 24, 2023 and the Equinix Data Center Mortgage Loan onand after April 24, 2023 and Argentic Services Company LP as special servicerof the NMR Pharmacy Portfolio Mortgage Loan, listed on the Exhibit Index areomitted from this Annual Report on Form 10-K as they are not required by Item1123 of Regulation AB to be included on this Annual Report on Form 10-K becausethey are each an unaffiliated party that is not a “servicer” that meets thecriteria in Item 1108(a)(2)(i) through (iii) of Regulation AB, and the servicercompliance statement of Midland Loan Services, a Division of PNC Bank, NationalAssociation as special servicer of the Ceasar’s Bay Shopping Center MortgageLoan and the Equinix Data Center Mortgage Loan prior to April 24, 2023, primaryservicer of the Uline Arena Mortgage Loan and the Bison Portfolio Mortgage Loanand primary servicer and special servicer of the Vanguard Portfolio MortgageLoan listed on the Exhibit Index is omitted from this Annual Report on Form10-K for the reasons set forth in the Explanatory Notes above.

**PART I**

**Item 1.  Business.**

Omitted.

**Item 1A.  Risk Factors.**

Omitted.

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

None.

**Item 1C.  Cybersecurity.**

Omitted.

**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.  [Reserved]**

**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 With Accountantson Accounting and Financial Disclosure.**

Omitted.

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

Omitted.

**Item 9B.  Other Information.**

None.

**Item 9C.  Disclosure Regarding Foreign Jurisdictionsthat Prevent Inspections.**

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 Related Transactions,and Director Independence.**

Omitted.

**Item 14.  Principal Accountant 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, ascertificate administrator, as trustee and as custodian. 

In December 2014, Phoenix Light SF Limited (Phoenix Light)and certain related entities filed a complaint in the United States DistrictCourt for the Southern District of New York alleging claims against Wells FargoBank, N.A., in its capacity as trustee for a number of residentialmortgage-backed securities (RMBS) trusts. Complaints raising similarallegations have been filed by Commerzbank AG in the Southern District of New York,IKB International and IKB Deutsche Industriebank (together, IKB) in New Yorkstate court, and Park Royal I LLC and Park Royal II LLC in New York statecourt. In each case, the plaintiffs allege that Wells Fargo Bank, N.A., astrustee, caused losses to investors, and plaintiffs assert causes of actionbased upon, among other things, the trustee’s alleged failure to notify andenforce repurchase obligations of mortgage loan sellers for purported breachesof representations and warranties, notify investors of alleged events ofdefault, and abide by appropriate standards of care following alleged events ofdefault. In July 2022, the district court dismissed Phoenix Light’s claims andcertain of the claims asserted by Commerzbank AG, and subsequently entered judgmentin each case in favor of Wells Fargo Bank, N.A. In August 2022, Phoenix Lightand Commerzbank AG each appealed the district court’s decision to the UnitedStates Court of Appeals for the Second Circuit. Phoenix Light dismissed itsappeal in May 2023, terminating its case. In November 2023, Wells Fargo Bank,N.A. entered into an agreement with IKB to resolve IKB’s claims. Wells FargoBank, N.A. previously settled two class actions filed by institutionalinvestors and an action filed by the National Credit Union Administration withsimilar allegations.

**Item 1119 of Regulation AB, Affiliations and CertainRelationships and Related Transactions.**

The information regarding this Item has been previouslyprovided in the prospectus of the Registrant relating to the issuing entityfiled on November 26, 2019 pursuant to Rule 424(b)(2).

**Item 1122 of Regulation AB, Compliance with ApplicableServicing Criteria.**

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the mortgage loans are attachedhereto under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit AAto the Pooling and Servicing Agreement incorporated by reference as Exhibit 4.1to this Annual Report on Form 10-K is a chart identifying the entitiesparticipating in a servicing function for the transaction responsible for eachapplicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the NEMA San Francisco Mortgage Loan,which is being serviced and administered pursuant to the trust and servicing agreementfor the NCMS 2019-NEMA Transaction, are attached hereto under Item 15 to thisAnnual Report on Form 10-K. Attached as Exhibit K to the trust and servicingagreement for the NCMS 2019-NEMA Transaction incorporated by reference asExhibit 4.2 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the NCMS 2019-NEMATransaction 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 4.3 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 Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the BBCMS 2019-C3 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 BBCMS 2019-C3 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 BBCMS 2019-C3Transaction 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 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 4.5 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 Uline Arena Mortgage Loan, whichis being serviced and administered pursuant to the pooling and servicingagreement for the CD 2019-CD8 Transaction, are attached hereto under Item 15 tothis Annual Report on Form 10-K. Attached as Schedule II to the pooling andservicing agreement for the CD 2019-CD8 Transaction incorporated by reference asExhibit 4.6 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the CD 2019-CD8 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 Bison Portfolio Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the CSAIL 2019-C17 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 CSAIL 2019-C17 Transaction incorporated byreference as Exhibit 4.7 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the CSAIL2019-C17 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Presidential City Mortgage Loan,which is being serviced and administered pursuant to the trust and servicingagreement for the SGCMS 2019-PREZ Transaction, are attached hereto under Item15 to this Annual Report on Form 10-K. Attached as Exhibit L to the trust andservicing agreement for the SGCMS 2019-PREZ Transaction incorporated byreference as Exhibit 4.8 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the SGCMS2019-PREZ 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 GNL Office and IndustrialPortfolio Mortgage Loan, the Inland Life Storage Portfolio Mortgage Loan andthe Ocean Edge Resort & Golf Club Mortgage Loan, which are being servicedand administered pursuant to the pooling and servicing agreement for the CF2019-CF2 Transaction, are attached hereto under Item 15 to this Annual Reporton Form 10-K. Attached as Schedule II to the pooling and servicing agreementfor the CF 2019-CF2 Transaction incorporated by reference as Exhibit 4.9 tothis Annual Report on Form 10-K is a chart identifying the entitiesparticipating in a servicing function for the CF 2019-CF2 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 Ceasar’s Bay Shopping CenterMortgage Loan and the Equinix Data Center Mortgage Loan, which are beingserviced and administered pursuant to the pooling and servicing agreement forthe WFCM 2019-C53 Transaction, are attached hereto under Item 15 to this AnnualReport on Form 10-K. Attached as Exhibit AA to the pooling and servicingagreement for the WFCM 2019-C53 Transaction incorporated by reference asExhibit 4.10 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the WFCM 2019-C53Transaction 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 NMR Pharmacy Portfolio MortgageLoan, which is being serviced and administered pursuant to the pooling andservicing agreement for the WFCM 2019-C54 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit AA to thepooling and servicing agreement for the WFCM 2019-C54 Transaction incorporatedby reference as Exhibit 4.11 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the WFCM2019-C54 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. Exhibit and Financial Statement Schedules**

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

(1) Not applicable

(2) Not applicable

(3) See below

4.1          Pooling and Servicing Agreement, dated as of November 1,2019, by and among Barclays Commercial Mortgage Securities LLC, as Depositor,KeyBank National Association, as Master Servicer and as Special Servicer, WellsFargo Bank, National Association, as Certificate Administrator and as Trustee,and Pentalpha Surveillance LLC, as Operating Advisor and as Asset RepresentationsReviewer (filed as Exhibit 4.1 to the registrant’s Current Report on Form 8-Kfiled on November 26, 2019 under Commission File No. 333-226850-04 andincorporated by reference herein). 

4.2          Trust and Servicing Agreement, dated as of March 29,2019, by and among Natixis Commercial Mortgage Securities LLC, as Depositor,KeyBank National Association, as Servicer, Situs Holdings, LLC, as SpecialServicer, and Wells Fargo Bank, National Association, as Trustee, CertificateAdministrator and Custodian (filed as Exhibit 4.5 to the registrant’s CurrentReport on Form 8-K filed on November 26, 2019 under Commission File No.333-226850-04 and incorporated by reference herein).

4.3          Trust and Servicing Agreement, dated as of June 4, 2019,by and among Natixis Commercial Mortgage Securities LLC, as Depositor, KeyBankNational Association, as Servicer, KeyBank National Association, as SpecialServicer, and Wells Fargo Bank, National Association, as Trustee andCertificate Administrator (filed as Exhibit 4.7 to the registrant’s CurrentReport on Form 8-K filed on November 26, 2019 under Commission File No.333-226850-04 and incorporated by reference herein).

4.4          Pooling and Servicing Agreement, dated as of June 1,2019, by and among Barclays Commercial Mortgage Securities LLC, as Depositor,Midland Loan Services, a Division of PNC Bank, National Association, as MasterServicer, Midland Loan Services, a Division of PNC Bank, National Association,as Special Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator, Wells Fargo Bank, National Association, as Trustee, andPentalpha Surveillance LLC, as Operating Advisor and as Asset RepresentationsReviewer (filed as Exhibit 4.10 to the registrant’s Current Report on Form 8-Kfiled on November 26, 2019 under Commission File No. 333-226850-04 andincorporated by reference herein).

4.5          Trust and Servicing Agreement, dated as of July 11, 2019,by and among Barclays Commercial Mortgage Securities LLC, as Depositor, KeyBankNational Association, as Servicer, Situs Holdings, LLC, as Special Servicer,and Wells Fargo Bank, National Association, as Certificate Administrator andTrustee (filed as Exhibit 4.8 to the registrant’s Current Report on Form 8-Kfiled on November 26, 2019 under Commission File No. 333-226850-04 andincorporated by reference herein).

4.6          Pooling and Servicing Agreement, dated as of August 1,2019, by and among Deutsche Mortgage & Asset Receiving Corporation, asDepositor, Midland Loan Services, a Division of PNC Bank, National Association,as Master Servicer, Midland Loan Services, a Division of PNC Bank, NationalAssociation, as Special Servicer, Wells Fargo Bank, National Association, asTrustee, Wells Fargo Bank, National Association, Certificate Administrator,Paying Agent and Custodian, and Park Bridge Lender Services LLC, as OperatingAdvisor and Asset Representations Reviewer (filed as Exhibit 4.6 to theregistrant’s Current Report on Form 8-K filed on November 26, 2019 underCommission File No. 333-226850-04 and incorporated by reference herein).

4.7          Pooling and Servicing Agreement, dated as of September 1,2019, by and among Credit Suisse Commercial Mortgage Securities Corp., asDepositor, Midland Loan Services, a Division of PNC Bank, National Association,as Master Servicer and as Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator and as Trustee, and Park BridgeLender Services LLC, as Operating Advisor and Asset Representations Reviewer(filed as Exhibit 4.9 to the registrant’s Current Report on Form 8-K filed onNovember 26, 2019 under Commission File No. 333-226850-04 and incorporated byreference herein).

4.8          Trust and Servicing Agreement, dated as of September 6,2019, by and among SG Commercial Mortgage Securities, LLC, as Depositor,KeyBank National Association, as Servicer, AEGON USA Realty Advisors, LLC, asSpecial Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator, Wells Fargo Bank, National Association, as Trustee (filed asExhibit 4.3 to the registrant’s Current Report on Form 8-K filed on November26, 2019 under Commission File No. 333-226850-04 and incorporated by referenceherein).

4.9          Pooling and Servicing Agreement, dated as of October 1,2019, by and among CCRE Commercial Mortgage Securities, L.P., as Depositor,KeyBank National Association, as Master Servicer, LNR Partners, LLC and KeyBankNational Association, each as a Special Servicer, Citibank, N.A., as Trustee,Citibank, N.A., as Certificate Administrator, Paying Agent and Custodian, ParkBridge Lender Services LLC, as Operating Advisor, and Park Bridge LenderServices LLC, as Asset Representations Reviewer (filed as Exhibit 4.2 to theregistrant’s Current Report on Form 8-K filed on November 26, 2019 underCommission File No. 333-226850-04 and incorporated by reference herein).

4.10        Pooling and Servicing Agreement, dated as of November 1,2019, by and among Wells Fargo Commercial Mortgage Securities, Inc., asDepositor, Wells Fargo Bank, National Association, as Master Servicer, MidlandLoan Services, a Division of PNC Bank, National Association, 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 Asset Representations Reviewer (filed asExhibit 4.4 to the registrant’s Current Report on Form 8-K filed on November26, 2019 under Commission File No. 333-226850-04 and incorporated by referenceherein).

4.11        Pooling and Servicing Agreement, dated as of December 1,2019, by and among Wells Fargo Commercial Mortgage Securities, Inc., asDepositor, Wells Fargo Bank, National Association, as Master Servicer, LNRPartners, LLC, as Special Servicer, Wells Fargo Bank, National Association, asCertificate Administrator, Wilmington Trust, National Association, as Trustee,and Park Bridge Lender Services LLC, as Operating Advisor and as Asset RepresentationsReviewer (filed as Exhibit 4.1 to the registrant’s Current Report on Form 8-Kfiled on December 4, 2019 under Commission File No. 333-226850-04 andincorporated by reference herein).

4.12        Agreement Between Noteholders, dated as of September 12,2019, by and among KeyBank National Association, as Initial Note A-1 Holder andKeyBank National Association, as Initial Note A-2, A-3, A-4, A-5, A-6, A-7 andA-8 Holder (filed as Exhibit 4.11 to the registrant’s Current Report on Form8-K filed on November 26, 2019 under Commission File No. 333-226850-04 andincorporated by reference herein).

4.13        Agreement Between Noteholders, dated as of September 6,2019, by and between Societe Generale Financial Corporation, as Initial NoteA-1A Holder, Societe Generale Financial Corporation, as Initial Note A-1BHolder, Societe Generale Financial Corporation, as Initial Note A-1C Holder,Societe Generale Financial Corporation, as Initial Note A-1D Holder, SocieteGenerale Financial Corporation, as Initial Note A-1E Holder, Societe GeneraleFinancial Corporation, as Initial Note A-1F Holder and Societe GeneraleFinancial Corporation, as Initial Note B Holder (filed as Exhibit 4.12 to theregistrant’s Current Report on Form 8-K filed on November 26, 2019 underCommission File No. 333-226850-04 and incorporated by reference herein).

4.14        Agreement Between Note Holders, dated as of October 15,2019, by and between Barclays Capital Real Estate Inc., as Initial Note A-1Holder and Barclays Capital Real Estate Inc., as Initial Note A-2 Holder (filedas Exhibit 4.13 to the registrant’s Current Report on Form 8-K filed onNovember 26, 2019 under Commission File No. 333-226850-04 and incorporated byreference herein).

4.15        Co-Lender Agreement, dated as of March 27, 2019, by andamong Natixis 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-4 Holder, Natixis RealEstate Capital LLC, as Note A-5 Holder, Natixis Real Estate Capital LLC, asNote A-B Holder, Natixis Real Estate Capital LLC, as Note B-1 Holder andNatixis Real Estate Capital LLC, as Note B-2 Holder (filed as Exhibit 4.14 tothe registrant’s Current Report on Form 8-K filed on November 26, 2019 underCommission File No. 333-226850-04 and incorporated by reference herein).

4.16        Co-Lender Agreement, dated as of September 20, 2019,between Rialto Mortgage Finance, LLC, as Note A-1 Holder, Rialto MortgageFinance, LLC, as Note A-2 Holder, Rialto Mortgage Finance, LLC, as Note A-3Holder and Rialto Mortgage Finance, LLC, as Note A-4 Holder (filed as Exhibit4.15 to the registrant’s Current Report on Form 8-K filed on November 26, 2019under Commission File No. 333-226850-04 and incorporated by reference herein).

4.17        Agreement Between Note Holders, dated as of July 2, 2019,by and between KeyBank National Association, as Initial Note A-1-A Holder,Initial Note A-1-B Holder and Initial Note A-1-C Holder and Barclays CapitalReal Estate Inc., as Initial Note A-2-A Holder and Initial Note A-2-B Holder(filed as Exhibit 4.16 to the registrant’s Current Report on Form 8-K filed onNovember 26, 2019 under Commission File No. 333-226850-04 and incorporated byreference herein).

4.18        Agreement Between Noteholders, dated as of July 29, 2019,by and among Cantor Commercial Real Estate Lending, L.P., as Initial Note A-1Holder, Initial Note A-2 Holder, Initial Note A-3 Holder, Initial Note A-4Holder and Initial Note A-5 Holder and Natixis Real Estate Capital LLC, asInitial Note A-6 Holder and Initial Note A-7 Holder (filed as Exhibit 4.17 tothe registrant’s Current Report on Form 8-K filed on November 26, 2019 underCommission File No. 333-226850-04 and incorporated by reference herein).

4.19        Co-Lender Agreement, dated as of June 4, 2019, by andamong Natixis 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-4 Holder, Natixis RealEstate Capital LLC, as Note A-5 Holder, Natixis Real Estate Capital LLC, asNote A-6 Holder, Natixis Real Estate Capital LLC, as Note A-7 Holder andNatixis Real Estate Capital LLC, as Note A-B Holder (filed as Exhibit 4.18 tothe registrant’s Current Report on Form 8-K filed on November 26, 2019 underCommission File No. 333-226850-04 and incorporated by reference herein).

4.20        Agreement Between Noteholders, dated as of September 6,2019, by and among KeyBank National Association, as Initial Note A-1 Holder andKeyBank National Association, as Initial Note A-2 Holder (filed as Exhibit 4.19to the registrant’s Current Report on Form 8-K filed on November 26, 2019 underCommission File No. 333-226850-04 and incorporated by reference herein).

4.21        Co-Lender Agreement, dated as of July 11, 2019, by andamong Barclays Bank PLC, as Note A-1-A Holder and Note B-1 Holder, BarclaysCapital Real Estate Inc., as Initial Note A-1-B Holder, Initial Note A-1-D Holderand Initial Note A-1-E Holder, Bank of America, N.A., as Note A-1-C Holder,Deutsche Bank AG, New York Branch, as Initial Note A-2-A Holder, Initial NoteA-2-B Holder, Initial Note A-2-C Holder and Initial Note B-2 Holder and GoldmanSachs Bank USA, as Initial Note A-3-A Holder, Initial Note A-3-B Holder,Initial Note A-3-C Holder and Initial Note B-3 Holder (filed as Exhibit 4.20 tothe registrant’s Current Report on Form 8-K filed on November 26, 2019 underCommission File No. 333-226850-04 and incorporated by reference herein).

4.22        Agreement Between Note Holders, dated as of September 25,2019, by and among Societe Generale Financial Corporation, as Initial Note A-1Holder and Societe Generale Financial Corporation, as Initial Note A-2 Holder(filed as Exhibit 4.21 to the registrant’s Current Report on Form 8-K filed onNovember 26, 2019 under Commission File No. 333-226850-04 and incorporated byreference herein).

4.23        Co-Lender Agreement, dated as of November 26, 2019, byand between BSPRT CMBS Finance, LLC, as Note A-1 Holder and BSPRT CMBS Finance,LLC, as Note A-2 Holder (filed as Exhibit 4.22 to the registrant’s CurrentReport on Form 8-K filed on November 26, 2019 under Commission File No.333-226850-04 and incorporated by reference herein).

4.24        Amended and Restated Co-Lender Agreement, dated as ofJune 11, 2019, by and among Natixis Real Estate Capital LLC, as Note A-1Holder, Natixis Real Estate Capital LLC, as Note A-2 Holder, Natixis RealEstate Capital LLC, as Note A-3 Holder, Natixis Real Estate Capital LLC, asNote A-4 Holder, Natixis Real Estate Capital LLC, as Note A-5 Holder, NatixisReal Estate Capital LLC, as Note A-6 Holder and TCM CRE REIT LLC, as Note BHolder (filed as Exhibit 4.23 to the registrant’s Current Report on Form 8-Kfiled on November 26, 2019 under Commission File No. 333-226850-04 and incorporatedby reference herein).

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

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

33.1        KeyBank National Association, as Master Servicer

33.2        KeyBank National Association, as Special Servicer(see Exhibit 33.1)

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

33.4        Wells Fargo Bank, National Association, asCustodian

33.5        Pentalpha Surveillance LLC, as Operating Advisor

33.6        Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator

33.7        Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian

33.8        KeyBank National Association, as Primary Servicerof the NEMA San Francisco Mortgage Loan (see Exhibit 33.1)

33.9        Situs Holdings, LLC, as Special Servicer of theNEMA San Francisco Mortgage Loan

33.10      Wells Fargo Bank, National Association, as Trustee of the NEMA San FranciscoMortgage Loan (Omitted. See Explanatory Notes.)

33.11      Wells Fargo Bank, National Association, asCustodian of the NEMA San Francisco Mortgage Loan (see Exhibit 33.4)

33.12      Computershare Trust Company, National Association, asServicing Function Participant for the Custodian (see Exhibit 33.7)

33.13      KeyBank National Association, as Primary Servicerof the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 33.1)

33.14      KeyBank National Association, as Special Servicerof the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 33.1)

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

33.16      Wells Fargo Bank, National Association, asCustodian of the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 33.4)

33.17      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.7)

33.18      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Vanguard Portfolio MortgageLoan

33.19      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Vanguard Portfolio MortgageLoan (see Exhibit 33.18)

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

33.21      Wells Fargo Bank, National Association, asCustodian of the Vanguard Portfolio Mortgage Loan (see Exhibit 33.4)

33.22      Pentalpha Surveillance LLC, as Operating Advisor ofthe Vanguard Portfolio Mortgage Loan (see Exhibit 33.5)

33.23      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.7)

33.24      KeyBank National Association, as Primary Servicerof the Moffett Towers II – Buildings 3 & 4 Mortgage Loan (see Exhibit 33.1)

33.25      Situs Holdings, LLC, as Special Servicer of theMoffett Towers II – Buildings 3 & 4 Mortgage Loan (see Exhibit 33.9)

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

33.27      Wells Fargo Bank, National Association, asCustodian of the Moffett Towers II – Buildings 3 & 4 Mortgage Loan (seeExhibit 33.4)

33.28      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.7)

33.29      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Uline Arena Mortgage Loan (seeExhibit 33.18)

33.30      LNR Partners, LLC, as Special Servicer of theUline Arena Mortgage Loan

33.31      Wells Fargo Bank, National Association, as Trustee of the Uline Arena MortgageLoan (Omitted. See Explanatory Notes.)

33.32      Wells Fargo Bank, National Association, asCustodian of the Uline Arena Mortgage Loan (see Exhibit 33.4)

33.33      Park Bridge Lender Services LLC, as OperatingAdvisor of the Uline Arena Mortgage Loan

33.34      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.7)

33.35      Midland Loan Services, a Division of PNC Bank, NationalAssociation, as Primary Servicer of the Bison Portfolio Mortgage Loan (seeExhibit 33.18)

33.36      3650 REIT Loan Servicing LLC, as Special Servicer of the Bison PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

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

33.38      Wells Fargo Bank, National Association, asCustodian of the Bison Portfolio Mortgage Loan (see Exhibit 33.4)

33.39      Park Bridge Lender Services LLC, as OperatingAdvisor of the Bison Portfolio Mortgage Loan (see Exhibit 33.33)

33.40      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.7)

33.41      KeyBank National Association, as Primary Servicerof the Presidential City Mortgage Loan (see Exhibit 33.1)

33.42      Situs Holdings, LLC, as Special Servicer of thePresidential City Mortgage Loan (see Exhibit 33.9)

33.43      Wells Fargo Bank, National Association, as Trustee of the Presidential CityMortgage Loan (Omitted. See Explanatory Notes.)

33.44      Wells Fargo Bank, National Association, asCustodian of the Presidential City Mortgage Loan (see Exhibit 33.4)

33.45      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.7)

33.46      KeyBank National Association, as Primary Servicerof the GNL Office and Industrial Portfolio Mortgage Loan (see Exhibit 33.1)

33.47      LNR Partners, LLC, as Special Servicer of the GNLOffice and Industrial Portfolio Mortgage Loan (see Exhibit 33.30)

33.48      Citibank, N.A., as Trustee and Custodian of theGNL Office and Industrial Portfolio Mortgage Loan

33.49      Park Bridge Lender Services LLC, as OperatingAdvisor of the GNL Office and Industrial Portfolio Mortgage Loan (see Exhibit33.33)

33.50      U.S. Bank National Association, as ServicingFunction Participant of the GNL Office and Industrial Portfolio Mortgage Loan

33.51      KeyBank National Association, as Primary Servicerof the Inland Life Storage Portfolio Mortgage Loan (see Exhibit 33.1)

33.52      LNR Partners, LLC, as Special Servicer of theInland Life Storage Portfolio Mortgage Loan (see Exhibit 33.30)

33.53      Citibank, N.A., as Trustee and Custodian of theInland Life Storage Portfolio Mortgage Loan (see Exhibit 33.48)

33.54      Park Bridge Lender Services LLC, as OperatingAdvisor of the Inland Life Storage Portfolio Mortgage Loan (see Exhibit 33.33)

33.55      U.S. Bank National Association, as ServicingFunction Participant of the Inland Life Storage Portfolio Mortgage Loan (seeExhibit 33.50)

33.56      KeyBank National Association, as Primary Servicerof the Ocean Edge Resort & Golf Club Mortgage Loan (see Exhibit 33.1)

33.57      LNR Partners, LLC, as Special Servicer of theOcean Edge Resort & Golf Club Mortgage Loan (see Exhibit 33.30)

33.58      Citibank, N.A., as Trustee and Custodian of theOcean Edge Resort & Golf Club Mortgage Loan (see Exhibit 33.48)

33.59      Park Bridge Lender Services LLC, as OperatingAdvisor of the Ocean Edge Resort & Golf Club Mortgage Loan (see Exhibit33.33)

33.60      U.S. Bank National Association, as ServicingFunction Participant of the Ocean Edge Resort & Golf Club Mortgage Loan(see Exhibit 33.50)

33.61      Wells Fargo Bank, National Association, as PrimaryServicer of the Ceasar’s Bay Shopping Center Mortgage Loan

33.62      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Ceasar’s Bay Shopping CenterMortgage Loan prior to April 24, 2023 (see Exhibit 33.18)

33.63      K-Star Asset Management LLC, as Special Servicerof the Ceasar’s Bay Shopping Center Mortgage Loan on and after April 24, 2023

33.64      Wilmington Trust, National Association, as Trustee of the Ceasar’s Bay ShoppingCenter Mortgage Loan (Omitted. See Explanatory Notes.)

33.65      Wells Fargo Bank, National Association, asCustodian of the Ceasar’s Bay Shopping Center Mortgage Loan (see Exhibit 33.4)

33.66      Park Bridge Lender Services LLC, as OperatingAdvisor of the Ceasar’s Bay Shopping Center Mortgage Loan (see Exhibit 33.33)

33.67      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Ceasar’s Bay Shopping Center Mortgage Loan

33.68      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.7)

33.69      Wells Fargo Bank, National Association, as PrimaryServicer of the Equinix Data Center Mortgage Loan (see Exhibit 33.61)

33.70      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Equinix Data Center MortgageLoan prior to April 24, 2023 (see Exhibit 33.18)

33.71      K-Star Asset Management LLC, as Special Servicerof the Equinix Data Center Mortgage Loan on and after April 24, 2023 (seeExhibit 33.63)

33.72      Wilmington Trust, National Association, as Trustee of the Equinix Data CenterMortgage Loan (Omitted. See Explanatory Notes.)

33.73      Wells Fargo Bank, National Association, asCustodian of the Equinix Data Center Mortgage Loan (see Exhibit 33.4)

33.74      Park Bridge Lender Services LLC, as OperatingAdvisor of the Equinix Data Center Mortgage Loan (see Exhibit 33.33)

33.75      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Equinix Data Center Mortgage Loan (see Exhibit 33.67)

33.76      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.7)

33.77      Wells Fargo Bank, National Association, as PrimaryServicer of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 33.61)

33.78      Argentic Services Company LP, as Special Servicer of the NMR Pharmacy PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

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

33.80      Wells Fargo Bank, National Association, as Custodianof the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 33.4)

33.81      Park Bridge Lender Services LLC, as OperatingAdvisor of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 33.33)

33.82      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 33.67)

33.83      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.7)

34           Attestation reports on assessment of compliance with servicing criteria forasset-backed securities.

34.1        KeyBank National Association, as Master Servicer

34.2        KeyBank National Association, as Special Servicer(see Exhibit 34.1)

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

34.4        Wells Fargo Bank, National Association, asCustodian

34.5        Pentalpha Surveillance LLC, as Operating Advisor

34.6         Computershare Trust Company, National Association, asServicing Function Participant for the Certificate Administrator

34.7        Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian

34.8        KeyBank National Association, as Primary Servicerof the NEMA San Francisco Mortgage Loan (see Exhibit 34.1)

34.9        Situs Holdings, LLC, as Special Servicer of theNEMA San Francisco Mortgage Loan

34.10      Wells Fargo Bank, National Association, as Trustee of the NEMA San FranciscoMortgage Loan (Omitted. See Explanatory Notes.)

34.11      Wells Fargo Bank, National Association, asCustodian of the NEMA San Francisco Mortgage Loan (see Exhibit 34.4)

34.12      Computershare Trust Company, National Association, asServicing Function Participant for the Custodian (see Exhibit 34.7)

34.13      KeyBank National Association, as Primary Servicerof the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 34.1)

34.14      KeyBank National Association, as Special Servicer ofthe 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 34.1)

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

34.16      Wells Fargo Bank, National Association, asCustodian of the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 34.4)

34.17      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.7)

34.18      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Vanguard Portfolio MortgageLoan

34.19      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Vanguard Portfolio MortgageLoan (see Exhibit 34.18)

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

34.21      Wells Fargo Bank, National Association, asCustodian of the Vanguard Portfolio Mortgage Loan (see Exhibit 34.4)

34.22      Pentalpha Surveillance LLC, as Operating Advisor ofthe Vanguard Portfolio Mortgage Loan (see Exhibit 34.5)

34.23      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.7)

34.24      KeyBank National Association, as Primary Servicerof the Moffett Towers II – Buildings 3 & 4 Mortgage Loan (see Exhibit 34.1)

34.25      Situs Holdings, LLC, as Special Servicer of theMoffett Towers II – Buildings 3 & 4 Mortgage Loan (see Exhibit 34.9)

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

34.27      Wells Fargo Bank, National Association, asCustodian of the Moffett Towers II – Buildings 3 & 4 Mortgage Loan (seeExhibit 34.4)

34.28      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.7)

34.29      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Uline Arena Mortgage Loan (seeExhibit 34.18)

34.30      LNR Partners, LLC, as Special Servicer of theUline Arena Mortgage Loan

34.31      Wells Fargo Bank, National Association, as Trustee of the Uline Arena MortgageLoan (Omitted. See Explanatory Notes.)

34.32      Wells Fargo Bank, National Association, asCustodian of the Uline Arena Mortgage Loan (see Exhibit 34.4)

34.33      Park Bridge Lender Services LLC, as OperatingAdvisor of the Uline Arena Mortgage Loan

34.34      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.7)

34.35      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Bison Portfolio Mortgage Loan(see Exhibit 34.18)

34.36      3650 REIT Loan Servicing LLC, as Special Servicer of the Bison PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.37      Wells Fargo Bank, National Association, as Trustee of the Bison Portfolio MortgageLoan (Omitted. See Explanatory Notes.)

34.38      Wells Fargo Bank, National Association, asCustodian of the Bison Portfolio Mortgage Loan (see Exhibit 34.4)

34.39      Park Bridge Lender Services LLC, as OperatingAdvisor of the Bison Portfolio Mortgage Loan (see Exhibit 34.33)

34.40      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.7)

34.41      KeyBank National Association, as Primary Servicerof the Presidential City Mortgage Loan (see Exhibit 34.1)

34.42      Situs Holdings, LLC, as Special Servicer of thePresidential City Mortgage Loan (see Exhibit 34.9)

34.43      Wells Fargo Bank, National Association, as Trustee of the Presidential CityMortgage Loan (Omitted. See Explanatory Notes.)

34.44      Wells Fargo Bank, National Association, asCustodian of the Presidential City Mortgage Loan (see Exhibit 34.4)

34.45      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.7)

34.46      KeyBank National Association, as Primary Servicerof the GNL Office and Industrial Portfolio Mortgage Loan (see Exhibit 34.1)

34.47      LNR Partners, LLC, as Special Servicer of the GNLOffice and Industrial Portfolio Mortgage Loan (see Exhibit 34.30)

34.48      Citibank, N.A., as Trustee and Custodian of theGNL Office and Industrial Portfolio Mortgage Loan

34.49      Park Bridge Lender Services LLC, as OperatingAdvisor of the GNL Office and Industrial Portfolio Mortgage Loan (see Exhibit34.33)

34.50      U.S. Bank National Association, as ServicingFunction Participant of the GNL Office and Industrial Portfolio Mortgage Loan

34.51      KeyBank National Association, as Primary Servicerof the Inland Life Storage Portfolio Mortgage Loan (see Exhibit 34.1)

34.52      LNR Partners, LLC, as Special Servicer of theInland Life Storage Portfolio Mortgage Loan (see Exhibit 34.30)

34.53      Citibank, N.A., as Trustee and Custodian of theInland Life Storage Portfolio Mortgage Loan (see Exhibit 34.48)

34.54      Park Bridge Lender Services LLC, as OperatingAdvisor of the Inland Life Storage Portfolio Mortgage Loan (see Exhibit 34.33)

34.55      U.S. Bank National Association, as ServicingFunction Participant of the Inland Life Storage Portfolio Mortgage Loan (seeExhibit 34.50)

34.56      KeyBank National Association, as Primary Servicerof the Ocean Edge Resort & Golf Club Mortgage Loan (see Exhibit 34.1)

34.57      LNR Partners, LLC, as Special Servicer of theOcean Edge Resort & Golf Club Mortgage Loan (see Exhibit 34.30)

34.58      Citibank, N.A., as Trustee and Custodian of theOcean Edge Resort & Golf Club Mortgage Loan (see Exhibit 34.48)

34.59      Park Bridge Lender Services LLC, as OperatingAdvisor of the Ocean Edge Resort & Golf Club Mortgage Loan (see Exhibit34.33)

34.60      U.S. Bank National Association, as ServicingFunction Participant of the Ocean Edge Resort & Golf Club Mortgage Loan(see Exhibit 34.50)

34.61      Wells Fargo Bank, National Association, as PrimaryServicer of the Ceasar’s Bay Shopping Center Mortgage Loan

34.62      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Ceasar’s Bay Shopping CenterMortgage Loan prior to April 24, 2023 (see Exhibit 34.18)

34.63      K-Star Asset Management LLC, as Special Servicerof the Ceasar’s Bay Shopping Center Mortgage Loan on and after April 24, 2023

34.64      Wilmington Trust, National Association, as Trustee of the Ceasar’s Bay ShoppingCenter Mortgage Loan (Omitted. See Explanatory Notes.)

34.65      Wells Fargo Bank, National Association, asCustodian of the Ceasar’s Bay Shopping Center Mortgage Loan (see Exhibit 34.4)

34.66      Park Bridge Lender Services LLC, as OperatingAdvisor of the Ceasar’s Bay Shopping Center Mortgage Loan (see Exhibit 34.33)

34.67      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Ceasar’s Bay Shopping Center Mortgage Loan

34.68      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.7)

34.69      Wells Fargo Bank, National Association, as PrimaryServicer of the Equinix Data Center Mortgage Loan (see Exhibit 34.61)

34.70      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Equinix Data Center MortgageLoan prior to April 24, 2023 (see Exhibit 34.18)

34.71      K-Star Asset Management LLC, as Special Servicerof the Equinix Data Center Mortgage Loan on and after April 24, 2023 (seeExhibit 34.63)

34.72      Wilmington Trust, National Association, as Trustee of the Equinix Data CenterMortgage Loan (Omitted. See Explanatory Notes.)

34.73      Wells Fargo Bank, National Association, asCustodian of the Equinix Data Center Mortgage Loan (see Exhibit 34.4)

34.74      Park Bridge Lender Services LLC, as OperatingAdvisor of the Equinix Data Center Mortgage Loan (see Exhibit 34.33)

34.75      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Equinix Data Center Mortgage Loan (see Exhibit 34.67)

34.76      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.7)

34.77      Wells Fargo Bank, National Association, as PrimaryServicer of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 34.61)

34.78      Argentic Services Company LP, as Special Servicer of the NMR Pharmacy PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

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

34.80      Wells Fargo Bank, National Association, asCustodian of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 34.4)

34.81      Park Bridge Lender Services LLC, as OperatingAdvisor of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 34.33)

34.82      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 34.67)

34.83      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.7)

35           Servicer compliance statements.

35.1        KeyBank National Association, as Master Servicer

35.2        KeyBank National Association, as Special Servicer(see Exhibit 35.1)

35.3        Wells Fargo Bank, National Association, asCertificate Administrator

35.4        Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator

35.5        KeyBank National Association, as Primary Servicerof the NEMA San Francisco Mortgage Loan (see Exhibit 35.1)

35.6        Situs Holdings, LLC, as Special Servicer of theNEMA San Francisco Mortgage Loan

35.7        KeyBank National Association, as Primary Servicerof the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 35.1)

35.8        KeyBank National Association, as Special Servicerof the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 35.1)

35.9        Midland Loan Services, a Division of PNC Bank, National Association, as PrimaryServicer of the Vanguard Portfolio Mortgage Loan (Omitted. See ExplanatoryNotes.)  

35.10      Midland Loan Services, a Division of PNC Bank, National Association, as SpecialServicer of the Vanguard Portfolio Mortgage Loan (Omitted. See ExplanatoryNotes.)

35.11      KeyBank National Association, as Primary Servicerof the Moffett Towers II – Buildings 3 & 4 Mortgage Loan (see Exhibit 35.1)

35.12      Situs Holdings, LLC, as Special Servicer of theMoffett Towers II – Buildings 3 & 4 Mortgage Loan (see Exhibit 35.6)

35.13      Midland Loan Services, a Division of PNC Bank, National Association, as PrimaryServicer of the Uline Arena Mortgage Loan (Omitted. See ExplanatoryNotes.)  

35.14      LNR Partners, LLC, as Special Servicer of theUline Arena Mortgage Loan

35.15      Midland Loan Services, a Division of PNC Bank, National Association, as PrimaryServicer of the Bison Portfolio Mortgage Loan (Omitted. See ExplanatoryNotes.)  

35.16      3650 REIT Loan Servicing LLC, as Special Servicer of the Bison Portfolio MortgageLoan (Omitted. See Explanatory Notes.)

35.17      KeyBank National Association, as Primary Servicerof the Presidential City Mortgage Loan (see Exhibit 35.1)

35.18      Situs Holdings, LLC, as Special Servicer of thePresidential City Mortgage Loan (see Exhibit 35.6)

35.19      KeyBank National Association, as Primary Servicerof the GNL Office and Industrial Portfolio Mortgage Loan (see Exhibit 35.1)

35.20      LNR Partners, LLC, as Special Servicer of the GNLOffice and Industrial Portfolio Mortgage Loan (see Exhibit 35.14)

35.21      KeyBank National Association, as Primary Servicerof the Inland Life Storage Portfolio Mortgage Loan (see Exhibit 35.1)

35.22      LNR Partners, LLC, as Special Servicer of theInland Life Storage Portfolio Mortgage Loan (see Exhibit 35.14)

35.23      KeyBank National Association, as Primary Servicerof the Ocean Edge Resort & Golf Club Mortgage Loan (see Exhibit 35.1)

35.24      LNR Partners, LLC, as Special Servicer of the OceanEdge Resort & Golf Club Mortgage Loan (see Exhibit 35.14)

35.25      Wells Fargo Bank, National Association, as PrimaryServicer of the Ceasar’s Bay Shopping Center Mortgage Loan

35.26      Midland Loan Services, a Division of PNC Bank, National Association, as SpecialServicer of the Ceasar’s Bay Shopping Center Mortgage Loan prior to April 24,2023 (Omitted. See Explanatory Notes.)

35.27      K-Star Asset Management LLC, as Special Servicer of the Ceasar’s Bay ShoppingCenter Mortgage Loan on and after April 24, 2023 (Omitted. See ExplanatoryNotes.)

35.28      Wells Fargo Bank, National Association, as PrimaryServicer of the Equinix Data Center Mortgage Loan (see Exhibit 35.25)

35.29      Midland Loan Services, a Division of PNC Bank, National Association, as SpecialServicer of the Equinix Data Center Mortgage Loan prior to April 24, 2023(Omitted. See Explanatory Notes.)

35.30      K-Star Asset Management LLC, as Special Servicer of the Equinix Data CenterMortgage Loan on and after April 24, 2023 (Omitted. See Explanatory Notes.)

35.31      Wells Fargo Bank, National Association, as PrimaryServicer of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 35.25)

35.32      Argentic Services Company LP, as Special Servicer of the NMR Pharmacy PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

99.1        Mortgage Loan Purchase Agreement, dated as of November 5,2019, among Barclays Capital Real Estate Inc., Barclays Capital Holdings Inc. andBarclays Commercial Mortgage Securities LLC (filed as Exhibit 99.1 to theregistrant’s Current Report on Form 8-K filed on November 26, 2019 underCommission File No. 333-226850-04 and incorporated by reference herein).

99.2        Mortgage Loan Purchase Agreement, dated as of November 5,2019, between KeyBank National Association and Barclays Commercial MortgageSecurities LLC (filed as Exhibit 99.2 to the registrant’s Current Report onForm 8-K filed on November 26, 2019 under Commission File No. 333-226850-04 andincorporated by reference herein).

99.3        Mortgage Loan Purchase Agreement, dated as of November 5,2019, between Natixis Real Estate Capital LLC and Barclays Commercial MortgageSecurities LLC (filed as Exhibit 99.3 to the registrant’s Current Report onForm 8-K filed on November 26, 2019 under Commission File No. 333-226850-04 andincorporated by reference herein).

99.4        Mortgage Loan Purchase Agreement, dated as of November 5,2019, among Societe Generale Financial Corporation, Société Générale andBarclays Commercial Mortgage Securities LLC (filed as Exhibit 99.4 to theregistrant’s Current Report on Form 8-K filed on November 26, 2019 underCommission File No. 333-226850-04 and incorporated by reference herein).

99.5        Mortgage Loan Purchase Agreement, dated as of November 5,2019, between Rialto Mortgage Finance, LLC and Barclays Commercial MortgageSecurities LLC (filed as Exhibit 99.5 to the registrant’s Current Report onForm 8-K filed on November 26, 2019 under Commission File No. 333-226850-04 andincorporated by reference herein).

99.6        Mortgage Loan Purchase Agreement, dated as of November 5,2019, among BSPRT CMBS Finance, LLC, Benefit Street Partners Realty Trust, Inc.and Barclays Commercial Mortgage Securities LLC (filed as Exhibit 99.6 to theregistrant’s Current Report on Form 8-K filed on November 26, 2019 underCommission File No. 333-226850-04 and incorporated by reference herein).

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

(c)    Not Applicable.

 

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 15, 2024