**UNITED STATESSECURITIES AND EXCHANGE COMMISSION**

**Washington, D.C. 20549**

**FORM 10-K**

(Mark One)

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

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

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

**For the transition period from _____ to _____Commission file number of the issuing entity: 333-226486-11**

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

**Wells Fargo Commercial MortgageTrust 2019-C54**

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

** **

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

**Wells Fargo Commercial MortgageSecurities, Inc.**

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

** **

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

**Wells Fargo Bank, NationalAssociation**

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

** **

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

**Argentic Real Estate Finance LLC**

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

** **

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

**LMF Commerical, LLC**

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

**(formerly known as Rialto MortgageFinance, LLC)**

** **

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

**BSPRT CMBS Finance, LLC**

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

** **

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

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

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

** **

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

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

**38-4128805**

**56-1643598**

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

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

**c/o Wells Fargo Bank, National Association **

**as Certificate Administrator**

**9062 Old Annapolis Road**

**Columbia, MD**

**(Address of principalexecutive offices of the issuing entity)**

**21045**

**(Zip Code)**

**Registrant’s telephone number,including area code:**

**(704) 374-6161**

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

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

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

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

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

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

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

Not applicable.

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

Not applicable.

Indicate by check mark whether the registrant is a largeaccelerated filer, an accelerated filer, a non-accelerated filer, a smaller reportingcompany, or an emerging growth company. See the definitions of “largeaccelerated filer,” “accelerated filer,” “smaller reporting company,” and“emerging growth company” in Rule 12b-2 of the Exchange Act.

Large acceleratedfiler        o                                                                                                       Acceleratedfiler                                     o

Non-acceleratedfiler          ⌧  (Do not check ifa smaller reporting company)                          Smaller reportingcompany                    o

                                                                                                                                                       Emerging growthcompany                    o

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

Indicate by check mark whether the registrant 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 all documentsand reports required to be filed by Section 12, 13 or 15(d) of the SecuritiesExchange Act of 1934 subsequent to the distribution of securities under a planconfirmed by a court.  o Yes 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 documents shouldbe clearly described for identification purposes (e.g., annual report tosecurity holders for fiscal year ended December 24, 1980).

Not applicable.

 

** **

**EXPLANATORY NOTES**

The Global Payments, Inc. Mortgage Loan andthe NMR Pharmacy Portfolio Mortgage Loan, which constituted approximately 2.9%and 2.6%, respectively, of the asset pool of the issuing entity as of itscut-off date, are each an asset of the issuing entity and are each part of aloan combination that includes the Global Payments, Inc. Mortgage Loan or theNMR Pharmacy Portfolio Mortgage Loan which are assets of the issuing entity andone other *pari passu* loan, which is not an asset of the issuing entity.These loan combinations, including the Global Payments, Inc. Mortgage Loan andthe NMR Pharmacy Portfolio Mortgage Loan, are being serviced and administeredpursuant to the Pooling and Servicing Agreement, which is incorporated byreference as Exhibit 4.1 to this Annual Report on Form 10-K. 

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the CIRE Equity Retail & IndustrialPortfolio Mortgage Loan, which constituted approximately 0.7% of the asset poolof the issuing entity as of its cut-off date.  The CIRE Equity Retail& Industrial Portfolio Mortgage Loan is an asset of the issuing entity andis part of a loan combination that includes the CIRE Equity Retail &Industrial Portfolio Mortgage Loan and seven other *pari passu* loans,which are not assets of the issuing entity. A *pari passu* portion of theloan combination was securitized in the Benchmark 2019-B12 Mortgage Trusttransaction, Commission File Number 333-228597-01 (the “BMARK 2019-B12Transaction”). This loan combination, including the CIRE Equity Retail& Industrial Portfolio Mortgage Loan, is being serviced and administeredpursuant to the pooling and servicing agreement for the BMARK 2019-B12Transaction, which is incorporated by reference as Exhibit 4.2 to this AnnualReport on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to The Tower at Burbank Mortgage Loan, whichconstituted approximately 3.7% of the asset pool of the issuing entity as ofits cut-off date.  The Tower at Burbank Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes The Tower atBurbank Mortgage Loan and two other *pari passu* loans, which are notassets of the issuing entity. A *pari passu* portion of the loancombination was securitized in the BANK 2019-BNK20 transaction, Commission FileNumber 333-227446-06 (the “BANK 2019-BNK20 Transaction”). This loancombination, including The Tower at Burbank Mortgage Loan, is being servicedand administered pursuant to the pooling and servicing agreement for the BANK2019-BNK20 Transaction, which is incorporated by reference as Exhibit 4.3 tothis Annual Report on Form 10-K.

The Exhibit Index describes exhibitsprovided by certain parties (in their capacities indicated on the ExhibitIndex) with respect to the Phoenix Industrial Portfolio II Mortgage Loan, whichconstituted approximately 3.0% of the asset pool of the issuing entity as ofits cut-off date.  The Phoenix Industrial Portfolio II Mortgage Loan is anasset of the issuing entity and is part of a loan combination that includes thePhoenix Industrial Portfolio II Mortgage Loan and four other *pari passu*loans, which are not assets of the issuing entity. A *pari passu* portionof the loan combination was securitized in the UBS Commercial Mortgage Trust2019-C17 transaction, Commission File Number 333-227784-04 (the “UBS2019-C17 Transaction”). This loan combination, including the PhoenixIndustrial Portfolio II Mortgage Loan, is being serviced and administeredpursuant to the pooling and servicing agreement for the UBS 2019-C17Transaction, which is incorporated by reference as Exhibit 4.4 to this AnnualReport on Form 10-K.

The Exhibit Index describes exhibitsprovided by certain parties (in their capacities indicated on the ExhibitIndex) with respect to the Planet Self Storage Portfolio Mortgage Loan, whichconstituted approximately 3.7% of the asset pool of the issuing entity as ofits cut-off date.  The Planet Self Storage Portfolio Mortgage Loan is anasset of the issuing entity and is part of a loan combination that includes thePlanet Self Storage Portfolio Mortgage Loan and two other *pari passu*loans, which are not assets of the issuing entity. A *pari passu* portionof the loan combination was securitized in the Wells Fargo Commercial MortgageTrust 2019-C53 transaction, Commission File Number 333-226486-09 (the “WFCM2019-C53 Transaction”). This loan combination, including the Planet SelfStorage Portfolio Mortgage Loan, is being serviced and administered pursuant tothe pooling and servicing agreement for the WFCM 2019-C53 Transaction, which isincorporated by reference as Exhibit 4.5 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Washington Avenue Portfolio Mortgage Loan,which constituted approximately 1.9% of the asset pool of the issuing entity asof its cut-off date.  The Washington Avenue Portfolio Mortgage Loan is anasset of the issuing entity and is part of a loan combination that includes theWashington Avenue Portfolio Mortgage Loan and one other *pari passu* loan,which is not an asset of the issuing entity. The other *pari passu*portion of the loan combination was securitized in the GS Mortgage SecuritiesTrust 2019-GSA1 transaction, Commission File Number 333-226082-05 (the “GSMS2019-GSA1 Transaction”). This loan combination, including the WashingtonAvenue Portfolio Mortgage Loan, is being serviced and administered pursuant tothe pooling and servicing agreement for the GSMS 2019-GSA1 Transaction, whichis incorporated by reference as Exhibit 4.6 to this Annual Report on Form 10-K.

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

Wells Fargo Bank, NationalAssociation is the master servicer and certificate administrator of themortgage loans serviced under the Pooling and Servicing Agreement and theprimary servicer of the Phoenix Industrial Portfolio II Mortgage Loan, thePlanet Self Storage Portfolio Mortgage Loan and The Tower at Burbank MortgageLoan.  As a result, Wells Fargo Bank, National Association  is a“servicer” as defined in Item 1108(a)(2)(iii) of Regulation AB, in thecapacities described above, because it is servicing mortgage loans thatconstituted 10% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby Wells Fargo Bank, National Association  in the capacities describedabove are listed in the Exhibit Index.

Wells Fargo Bank, National Association is the custodian ofthe mortgage loans serviced under the Pooling and Servicing Agreement, theWashington Avenue Portfolio Mortgage Loan, the Phoenix Industrial Portfolio IIMortgage Loan, the Planet Self Storage Portfolio Mortgage Loan and The Tower atBurbank Mortgage Loan.  As a result, Wells Fargo Bank, NationalAssociation  is a servicing function participant in the capacitiesdescribed above, because it is servicing mortgage loans that constituted 5% ormore of the assets of the issuing entity as of its cut-off date. Theassessments of compliance with applicable servicing criteria and accountants’ attestationreports delivered by Wells Fargo Bank, National Association  in thecapacities described above are listed in the Exhibit Index.

LNR Partners, LLC is the specialservicer of the mortgage loans serviced under the Pooling and ServicingAgreement and the Washington Avenue Portfolio Mortgage Loan. As a result, LNRPartners, LLC is a “servicer” as defined in Item 1108(a)(2)(iii) of RegulationAB, in the capacities described above, because it is servicing mortgage loansthat constituted 10% or more of the assets of the issuing entity as of itscut-off date. The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby LNR Partners, LLC in the capacities described above are listed in theExhibit Index.

Park Bridge Lender Services LLC is the operating advisor ofthe mortgage loans serviced under the Pooling and Servicing Agreement, theWashington Avenue Portfolio Mortgage Loan, the Planet Self Storage PortfolioMortgage Loan and The Tower at Burbank Mortgage Loan.  As a result, ParkBridge Lender Services LLC is a servicing function participant in thecapacities described above, because it is servicing mortgage loans thatconstituted 5% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria andaccountants’ attestation reports delivered by Park Bridge Lender Services LLCin the capacities described above are listed in the Exhibit Index.

Midland Loan Services, a Divisionof PNC Bank, National Association is the primary servicer and special servicerof the CIRE Equity Retail & Industrial Portfolio Mortgage Loan, the primaryservicer of the Washington Avenue Portfolio Mortgage Loan and the special servicerof the Planet Self Storage Portfolio Mortgage Loan and The Tower at BurbankMortgage Loan. As a result, Midland Loan Services, a Division of PNC Bank,National Association is a “servicer” as defined in Item 1108(a)(2)(iii) ofRegulation AB, in the capacities described above, because it is servicingmortgage loans that constituted 10% or more of the assets of the issuing entityas of its cut-off date. The assessments of compliance with applicable servicingcriteria, accountants’ attestation reports and servicer compliance statementsdelivered by Midland Loan Services, a Division of PNC Bank, NationalAssociation in the capacities described above are listed in the Exhibit Index.

Wells Fargo Bank, NationalAssociation acts as trustee of the Washington Avenue Portfolio MortgageLoan.  Pursuant to the pooling and servicing agreement for the GSMS2019-GSA1 Transaction, the trustee is required to provide an assessment ofcompliance with applicable servicing criteria solely with respect to Item1122(d)(2)(iii) of Regulation AB (regarding advances of funds or guaranteesregarding collections, cash flows or distributions, and any interest or otherfees charged for such advances, are made, reviewed and approved as specified inthe transaction agreements). However, during the reporting period, the trusteedid not perform any servicing function with respect to the servicing 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 Washington Avenue Portfolio Mortgage Loan have delivered one or moreassessments of compliance with respect to Item 1122(d)(2)(iii) of RegulationAB.

Wilmington Trust, NationalAssociation acts as trustee of the mortgage loans serviced under the Poolingand Servicing Agreement, the CIRE Equity Retail & Industrial PortfolioMortgage Loan, the Phoenix Industrial Portfolio II Mortgage Loan, the PlanetSelf Storage Portfolio Mortgage Loan and The Tower at Burbank MortgageLoan.  Pursuant to the Pooling and Servicing Agreement, the pooling andservicing agreement for the BMARK 2019-B12 Transaction, the pooling andservicing agreement for the UBS 2019-C17 Transaction, the pooling and servicingagreement for the BANK 2019-BNK20 Transaction and the pooling and servicingagreement for the WFCM 2019-C53 Transaction, the trustee is required to providean assessment of compliance with applicable servicing criteria solely withrespect to Item 1122(d)(2)(iii) of Regulation AB (regarding advances of fundsor guarantees regarding collections, cash flows or distributions, and anyinterest or other fees charged for such advances, are made, reviewed andapproved as specified in the transaction agreements). However, during thereporting period, the trustee did not perform any servicing function withrespect to the servicing criteria specified in Item 1122(d)(2)(iii) ofRegulation AB.  The master servicer or the special servicer, to the extentrequired, performed the servicing function identified with respect to Item1122(d)(2)(iii) of Regulation AB, and each such party included Item 1122(d)(2)(iii)of Regulation AB in the assessment of compliance with applicable servicingcriteria and accountant’s attestation report for the subject transaction. As a result, this Annual Report on Form 10-K does not include an assessment ofcompliance with applicable servicing criteria of the trustee. One or more otherservicers of the mortgage loans serviced under the Pooling and ServicingAgreement, the CIRE Equity Retail & Industrial Portfolio Mortgage Loan, TheTower at Burbank Mortgage Loan, the Phoenix Industrial Portfolio II MortgageLoan and the Planet Self Storage Portfolio Mortgage Loan have delivered one ormore assessments of compliance with respect to Item 1122(d)(2)(iii) ofRegulation AB.

This Annual Report on Form 10-Kincludes assessments of compliance with applicable servicing criteria andaccountants’ attestation reports from CoreLogic Commercial Real EstateServices, Inc. and National Tax Search, LLC.  These entities were engagedby the master servicer of the Pooling and Servicing Agreement and the primaryservicer of the Phoenix Industrial Portfolio II Mortgage Loan, the Planet SelfStorage Portfolio Mortgage Loan and The Tower at Burbank Mortgage Loan to remittax payments received from the escrow accounts of borrowers to local taxing authorities,to report tax amounts due, to verify tax parcel information, and to verifynon-escrow tax payments. These servicing functions are included within theservicing criteria set forth in Items 1122(d)(4)(xi) and 1122(d)(4)(xii) ofRegulation AB.  Therefore, under the principles-based definition of“servicer” set forth in Item 1101(j) of Regulation AB that looks to thefunctions that an entity performs, these vendors are “servicers” for thepurposes of Item 1122 of Regulation AB.  See Compliance and DisclosureInterpretations, Section 301.01 (Item 1101(j)).

Theassessments of compliance with applicable servicing criteria, accountants’attestation reports and servicer compliance statements of the certificateadministrator of the CIRE Equity Retail & Industrial Portfolio MortgageLoan, the Washington Avenue Portfolio Mortgage Loan, the Phoenix IndustrialPortfolio II Mortgage Loan, the Planet Self Storage Portfolio Mortgage Loan andThe Tower at Burbank Mortgage Loan, listed on the Exhibit Index are omittedfrom this Annual Report on Form 10-K as the certificate administrator pursuantto the related pooling and servicing agreement or trust and servicing agreementdoes not perform any activities that address servicing criteria with respect tothe issuing entity and because they are each not a “servicer” that meets thecriteria in Item 1108(a)(2)(i) through (iii) of Regulation AB.

With respect to the *pari passu*loan combinations that include the CIRE Equity Retail & IndustrialPortfolio Mortgage Loan and the Phoenix Industrial Portfolio II Mortgage Loan,(i) the reports on assessment of compliance with servicing criteria andattestation reports on assessment of compliance with servicing criteria ofPentalpha Surveillance LLC as operating advisor of the CIRE Equity Retail &Industrial Portfolio Mortgage Loan and the Phoenix Industrial Portfolio IIMortgage Loan, Rialto Capital Advisors, LLC as special servicer of the PhoenixIndustrial Portfolio II Mortgage Loan and Citibank, N.A. as custodian of theCIRE Equity Retail & Industrial 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 statement of Rialto Capital Advisors,LLC as special servicer of the Phoenix Industrial Portfolio II Mortgage Loan,listed on the Exhibit Index is omitted from this Annual Report on Form 10-K asit is not required by Item 1123 of Regulation AB to be included on this AnnualReport on Form 10-K because it is an unaffiliated party that is not a “servicer”that meets the criteria in Item 1108(a)(2)(i) through (iii) of Regulation AB.

**PART I**

**Item 1.  Business.**

Omitted.

**Item 1A.  Risk Factors.**

Omitted.

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

None.

**Item 2.  Properties.**

Omitted.

**Item 3.  Legal Proceedings.**

Omitted.

**Item 4.  Mine Safety Disclosures.**

Not applicable.

**PART II**

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

Omitted.

**Item 6.  Selected Financial Data.**

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**Item 9B.  Other Information.**

None.

**PART III**

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

Omitted.

**Item 11.  Executive Compensation.**

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**ADDITIONAL DISCLOSURE ITEMS FOR REGULATION AB**

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

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

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

No entity or group of affiliated entities provides any externalcreditenhancement 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 this transactionas described under Item 1115 of Regulation AB.

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

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

In the ordinary course of business, Citibank N.A. (“Citibank”)is involved in a number of legal proceedings, including in connection with itsrole as trustee of certain RMBS transactions.  Certain of these Citibankas trustee-related matters are disclosed herein. 

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

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

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

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

Beginning on June 18, 2014, a group of institutionalinvestors filed civil complaints in the Supreme Court of the State of New York,New York County, and later the U.S. District Court for the Southern District ofNew York, against Wells Fargo Bank, N.A., (“Wells Fargo Bank”) in itscapacity as trustee for certain residential mortgage backed securities (“RMBS”)trusts.  The complaints against Wells Fargo Bank alleged that the trusteecaused losses to investors and asserted causes of action based upon, amongother things, the trustee's alleged failure to: (i) notify and enforcerepurchase obligations of mortgage loan sellers for purported breaches ofrepresentations and warranties, (ii) notify investors of alleged events ofdefault, and (iii) abide by appropriate standards of care following allegedevents of default. Relief sought included money damages in an unspecifiedamount, reimbursement of expenses, and equitable relief. In November 2018,Wells Fargo Bank reached an agreement, in which it denied any wrongdoing, toresolve such claims on a classwide basis for the 271 RMBS trusts atissue.  On May 6, 2019, the court entered an order approving thesettlement agreement.  Separate lawsuits against Wells Fargo Bank makingsimilar allegations filed by certain other institutional investors concerningseveral RMBS trusts in New York federal and state court are not covered by theagreement.  With respect to such litigations, Wells Fargo Bank believesplaintiffs' claims are without merit and intends to contest the claimsvigorously, but there can be no assurances as to the outcome of the litigationsor the possible impact of the litigations on Wells Fargo Bank or the RMBStrusts.

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

The information regarding this Item has been previouslyprovided in the prospectus of the Registrant relating to the issuing entityfiled on December 3, 2019 pursuant to Rule 424(b)(2).

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

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

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the CIRE Equity Retail &Industrial Portfolio Mortgage Loan, which is being serviced and administeredpursuant to the pooling and servicing agreement for the BMARK 2019-B12Transaction, are attached hereto under Item 15 to this Annual Report on Form10-K. Attached as Exhibit O to the pooling and servicing agreement for theBMARK 2019-B12 Transaction incorporated by reference as Exhibit 4.2 to thisAnnual Report on Form 10-K is a chart identifying the entities participating ina servicing function for the BMARK 2019-B12 Transaction responsible for each applicableservicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to The Tower at Burbank Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the BANK 2019-BNK20 Transaction, are attached hereto under Item15 to this Annual Report on Form 10-K. Attached as Exhibit Z to the pooling andservicing agreement for the BANK 2019-BNK20 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 BANK2019-BNK20 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 Phoenix Industrial Portfolio IIMortgage Loan, which is being serviced and administered pursuant to the poolingand servicing agreement for the UBS 2019-C17 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit Z to the poolingand servicing agreement for the UBS 2019-C17 Transaction incorporated byreference as Exhibit 4.4 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the UBS2019-C17 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Planet Self Storage PortfolioMortgage Loan, which is being serviced and administered pursuant to the poolingand servicing agreement for the WFCM 2019-C53 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit AA to thepooling and servicing agreement for the WFCM 2019-C53 Transaction incorporatedby reference as Exhibit 4.5 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the WFCM2019-C53 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Washington Avenue PortfolioMortgage Loan, which is being serviced and administered pursuant to the poolingand servicing agreement for the GSMS 2019-GSA1 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit AA to thepooling and servicing agreement for the GSMS 2019-GSA1 Transaction incorporatedby reference as Exhibit 4.6 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the GSMS2019-GSA1 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

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

Material Instance of Noncompliance

In certain instances, the Schedule AL Files (Item 1125 ofRegulation AB) were not reported in accordance with the terms specified in thetransaction agreements, in conflict with Item 1122(d)(3)(i): “Reports toinvestors, including those to be filed with the Commission, are maintained inaccordance with the transaction agreements and applicable Commissionrequirements. Specifically, such reports: (A) Are prepared in accordance withtimeframes and other terms set forth in the transaction agreements”.  Thenoncompliance consisted of omitted or inaccurately reported fields as describedin (1) and (2) below.  (1) In connection with other enhancements Midlandmade to its manual Schedule AL process, starting in April 2019, Midlanddeveloped and implemented new Schedule AL reporting templates for eachapplicable CMBS transaction that closed prior to April 2019 and for eachapplicable CMBS transaction going forward.  Related to this, Midland madecertain template setup errors, along with related and other manual inputting ofinformation errors, and the errors were not identified prior to submission ofthe applicable Schedule AL Files in certain cases due to breakdowns in qualitycontrol.  (2) In one applicable transaction, the related Schedule AL Filefor a given month was not saved properly resulting in the prior month'sSchedule AL File being submitted for the given month instead of the correctSchedule AL File. 

The identified instances did involve the servicing of assetsincluded in this securitization as it relates to Schedule AL reporting.

Steps Taken to Remedy the Material Instance of Noncompliance

Midland’s Schedule AL reporting process was enhanced in Aprilof 2019, however, the process remained manual throughout the 2019 calendaryear.  Errors relating to certain Schedule AL Files during 2019 wereidentified during the related audit.  Following identification, Midlandmade staffing changes and additional enhancements and improvements to itsprocesses and procedures to support its Schedule AL reporting obligations andexpects to move to an automated solution for this process.  

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

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

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

**PART IV**

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

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

(1) Not applicable

(2) Not applicable

(3) See below

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

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

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

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

4.5          Poolingand Servicing Agreement, dated as of November 1, 2019, among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator, Wilmington Trust, NationalAssociation, as Trustee, and Park Bridge Lender Services LLC, as OperatingAdvisor and as Asset Representations Reviewer (filed as Exhibit 4.3 to theregistrant’s Current Report on Form 8-K filed on December 3, 2019 underCommission File No. 333-226486-11 and incorporated by reference herein).

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

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

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

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

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

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

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

4.13        AgreementBetween Noteholders, dated as of July 11, 2019, by and between Deutsche BankAG, New York Branch, as Initial Note A-1 Holder, Deutsche Bank AG, New YorkBranch, as Initial Note A-2 Holder, Deutsche Bank AG, New York Branch, asInitial Note A-3 Holder, UBS AG, by and through its branch office at 1285Avenue of the Americas, New York, New York, as Initial Note A-4 Holder, UBS AG,by and through its branch office at 1285 Avenue of the Americas, New York, NewYork, as Initial Note A-5 Holder, and UBS AG, by and through its branch officeat 1285 Avenue of the Americas, New York, New York, as Initial Note A-6 Holder(filed as Exhibit 4.13 to the registrant’s Current Report on Form 8-K filed onDecember 3, 2019 under Commission File No. 333-226486-11 and incorporated byreference herein).

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

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

33.1        Wells Fargo Bank, NationalAssociation, as Master Servicer

33.2        LNR Partners, LLC, asSpecial Servicer

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

33.4        Wells Fargo Bank, NationalAssociation, as Certificate Administrator

33.5        Wells Fargo Bank, NationalAssociation, as Custodian

33.6        Park Bridge LenderServices LLC, as Operating Advisor

33.7        CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant

33.8        National Tax Search, LLC,as Servicing Function Participant

33.9        Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Global Payments, Inc. Mortgage Loan(see Exhibit 33.1)

33.10      LNR Partners, LLC, asSpecial Servicer of the Global Payments, Inc. Mortgage Loan (see Exhibit 33.2)

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

33.12      Wells Fargo Bank, NationalAssociation, as Custodian of the Global Payments, Inc. Mortgage Loan (seeExhibit 33.5)

33.13      Park Bridge LenderServices LLC, as Operating Advisor of the Global Payments, Inc. Mortgage Loan(see Exhibit 33.6)

33.14      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the GlobalPayments, Inc. Mortgage Loan (see Exhibit 33.7)

33.15      National Tax Search, LLC,as Servicing Function Participant of the Global Payments, Inc. Mortgage Loan(see Exhibit 33.8)

33.16      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the NMR Pharmacy Portfolio Mortgage Loan(see Exhibit 33.1)

33.17      LNR Partners, LLC, asSpecial Servicer of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 33.2)

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

33.19      Wells Fargo Bank, NationalAssociation, as Custodian of the NMR Pharmacy Portfolio Mortgage Loan (seeExhibit 33.5)

33.20      Park Bridge LenderServices LLC, as Operating Advisor of the NMR Pharmacy Portfolio Mortgage Loan(see Exhibit 33.6)

33.21      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the NMR Pharmacy PortfolioMortgage Loan (see Exhibit 33.7)

33.22      National Tax Search, LLC,as Servicing Function Participant of the NMR Pharmacy Portfolio Mortgage Loan(see Exhibit 33.8)

33.23      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the CIREEquity Retail & Industrial Portfolio Mortgage Loan

33.24      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the CIREEquity Retail & Industrial Portfolio Mortgage Loan (see Exhibit 33.23)

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

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

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

33.28      Wells Fargo Bank, NationalAssociation, as Primary Servicer of The Tower at Burbank Mortgage Loan (seeExhibit 33.1)

33.29      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of The Tower atBurbank Mortgage Loan (see Exhibit 33.23)

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

33.31      Wells Fargo Bank, NationalAssociation, as Custodian of The Tower at Burbank Mortgage Loan (see Exhibit33.5)

33.32      Park Bridge LenderServices LLC, as Operating Advisor of The Tower at Burbank Mortgage Loan (seeExhibit 33.6)

33.33      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of The Tower at BurbankMortgage Loan (see Exhibit 33.7)

33.34      National Tax Search, LLC,as Servicing Function Participant of The Tower at Burbank Mortgage Loan (seeExhibit 33.8)

33.35      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Phoenix Industrial Portfolio IIMortgage Loan (see Exhibit 33.1)

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

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

33.38      Wells Fargo Bank, NationalAssociation, as Custodian of the Phoenix Industrial Portfolio II Mortgage Loan(see Exhibit 33.5)

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

33.40      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the PhoenixIndustrial Portfolio II Mortgage Loan (see Exhibit 33.7)

33.41      National Tax Search, LLC,as Servicing Function Participant of the Phoenix Industrial Portfolio IIMortgage Loan (see Exhibit 33.8)

33.42      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Planet Self Storage Portfolio MortgageLoan (see Exhibit 33.1)

33.43      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the PlanetSelf Storage Portfolio Mortgage Loan (see Exhibit 33.23)

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

33.45      Wells Fargo Bank, NationalAssociation, as Custodian of the Planet Self Storage Portfolio Mortgage Loan(see Exhibit 33.5)

33.46      Park Bridge LenderServices LLC, as Operating Advisor of the Planet Self Storage PortfolioMortgage Loan (see Exhibit 33.6)

33.47      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Planet SelfStorage Portfolio Mortgage Loan (see Exhibit 33.7)

33.48      National Tax Search, LLC,as Servicing Function Participant of the Planet Self Storage Portfolio MortgageLoan (see Exhibit 33.8)

33.49      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of theWashington Avenue Portfolio Mortgage Loan (see Exhibit 33.23)

33.50      LNR Partners, LLC, asSpecial Servicer of the Washington Avenue Portfolio Mortgage Loan (see Exhibit33.2)

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

33.52      Wells Fargo Bank, NationalAssociation, as Custodian of the Washington Avenue Portfolio Mortgage Loan (seeExhibit 33.5)

33.53      Park Bridge LenderServices LLC, as Operating Advisor of the Washington Avenue Portfolio MortgageLoan (see Exhibit 33.6)

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

34.1        Wells Fargo Bank, NationalAssociation, as Master Servicer

34.2        LNR Partners, LLC, asSpecial Servicer

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

34.4        Wells Fargo Bank, NationalAssociation, as Certificate Administrator

34.5        Wells Fargo Bank, NationalAssociation, as Custodian

34.6        Park Bridge LenderServices LLC, as Operating Advisor

34.7        CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant

34.8        National Tax Search, LLC,as Servicing Function Participant

34.9        Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Global Payments, Inc. Mortgage Loan(see Exhibit 34.1)

34.10      LNR Partners, LLC, asSpecial Servicer of the Global Payments, Inc. Mortgage Loan (see Exhibit 34.2)

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

34.12      Wells Fargo Bank, NationalAssociation, as Custodian of the Global Payments, Inc. Mortgage Loan (seeExhibit 34.5)

34.13      Park Bridge LenderServices LLC, as Operating Advisor of the Global Payments, Inc. Mortgage Loan(see Exhibit 34.6)

34.14      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the GlobalPayments, Inc. Mortgage Loan (see Exhibit 34.7)

34.15      National Tax Search, LLC,as Servicing Function Participant of the Global Payments, Inc. Mortgage Loan(see Exhibit 34.8)

34.16      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the NMR Pharmacy Portfolio Mortgage Loan(see Exhibit 34.1)

34.17      LNR Partners, LLC, asSpecial Servicer of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 34.2)

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

34.19      Wells Fargo Bank, NationalAssociation, as Custodian of the NMR Pharmacy Portfolio Mortgage Loan (seeExhibit 34.5)

34.20      Park Bridge LenderServices LLC, as Operating Advisor of the NMR Pharmacy Portfolio Mortgage Loan(see Exhibit 34.6)

34.21      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the NMR PharmacyPortfolio Mortgage Loan (see Exhibit 34.7)

34.22      National Tax Search, LLC, asServicing Function Participant of the NMR Pharmacy Portfolio Mortgage Loan (seeExhibit 34.8)

34.23      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the CIREEquity Retail & Industrial Portfolio Mortgage Loan

34.24      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the CIREEquity Retail & Industrial Portfolio Mortgage Loan (see Exhibit 34.23)

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

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

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

34.28      Wells Fargo Bank, NationalAssociation, as Primary Servicer of The Tower at Burbank Mortgage Loan (seeExhibit 34.1)

34.29      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of The Tower atBurbank Mortgage Loan (see Exhibit 34.23)

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

34.31      Wells Fargo Bank, NationalAssociation, as Custodian of The Tower at Burbank Mortgage Loan (see Exhibit34.5)

34.32      Park Bridge LenderServices LLC, as Operating Advisor of The Tower at Burbank Mortgage Loan (seeExhibit 34.6)

34.33      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of The Tower atBurbank Mortgage Loan (see Exhibit 34.7)

34.34      National Tax Search, LLC,as Servicing Function Participant of The Tower at Burbank Mortgage Loan (seeExhibit 34.8)

34.35      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Phoenix Industrial Portfolio IIMortgage Loan (see Exhibit 34.1)

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

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

34.38      Wells Fargo Bank, NationalAssociation, as Custodian of the Phoenix Industrial Portfolio II Mortgage Loan(see Exhibit 34.5)

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

34.40      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Phoenix IndustrialPortfolio II Mortgage Loan (see Exhibit 34.7)

34.41      National Tax Search, LLC,as Servicing Function Participant of the Phoenix Industrial Portfolio IIMortgage Loan (see Exhibit 34.8)

34.42      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Planet Self Storage Portfolio MortgageLoan (see Exhibit 34.1)

34.43      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the PlanetSelf Storage Portfolio Mortgage Loan (see Exhibit 34.23)

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

34.45      Wells Fargo Bank, NationalAssociation, as Custodian of the Planet Self Storage Portfolio Mortgage Loan(see Exhibit 34.5)

34.46      Park Bridge Lender ServicesLLC, as Operating Advisor of the Planet Self Storage Portfolio Mortgage Loan(see Exhibit 34.6)

34.47      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Planet Self StoragePortfolio Mortgage Loan (see Exhibit 34.7)

34.48      National Tax Search, LLC,as Servicing Function Participant of the Planet Self Storage Portfolio MortgageLoan (see Exhibit 34.8)

34.49      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of theWashington Avenue Portfolio Mortgage Loan (see Exhibit 34.23)

34.50      LNR Partners, LLC, asSpecial Servicer of the Washington Avenue Portfolio Mortgage Loan (see Exhibit34.2)

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

34.52      Wells Fargo Bank, NationalAssociation, as Custodian of the Washington Avenue Portfolio Mortgage Loan (seeExhibit 34.5)

34.53      Park Bridge LenderServices LLC, as Operating Advisor of the Washington Avenue Portfolio MortgageLoan (see Exhibit 34.6)

35           Servicer compliance statements.

35.1        Wells Fargo Bank, NationalAssociation, as Master Servicer

35.2        LNR Partners, LLC, asSpecial Servicer

35.3        Wells Fargo Bank, NationalAssociation, as Certificate Administrator

35.4        Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Global Payments, Inc. Mortgage Loan(see Exhibit 35.1)

35.5        LNR Partners, LLC, asSpecial Servicer of the Global Payments, Inc. Mortgage Loan (see Exhibit 35.2)

35.6        Wells Fargo Bank, NationalAssociation, as Primary Servicer of the NMR Pharmacy Portfolio Mortgage Loan(see Exhibit 35.1)

35.7        LNR Partners, LLC, asSpecial Servicer of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 35.2)

35.8        Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the CIREEquity Retail & Industrial Portfolio Mortgage Loan

35.9        Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the CIREEquity Retail & Industrial Portfolio Mortgage Loan (see Exhibit 35.8)

35.10      Wells Fargo Bank, NationalAssociation, as Primary Servicer of The Tower at Burbank Mortgage Loan (seeExhibit 35.1)

35.11      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of The Tower atBurbank Mortgage Loan (see Exhibit 35.8)

35.12      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Phoenix Industrial Portfolio IIMortgage Loan (see Exhibit 35.1)

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

35.14      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Planet Self Storage Portfolio MortgageLoan (see Exhibit 35.1)

35.15      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the PlanetSelf Storage Portfolio Mortgage Loan (see Exhibit 35.8)

35.16      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of theWashington Avenue Portfolio Mortgage Loan (see Exhibit 35.8)

35.17      LNR Partners, LLC, asSpecial Servicer of the Washington Avenue Portfolio Mortgage Loan (see Exhibit35.2)

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

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

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

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

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

(b)  The exhibits required to be filed by the Registrant pursuant to Item 601 ofRegulation S-K are listed above.

(c)    Not Applicable.

 

**SIGNATURES**

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

Wells Fargo Commercial MortgageSecurities, Inc.(Depositor)

/s/ AnthonySfarra

AnthonySfarra, President

(senior officer in charge ofsecuritization of the depositor)

Date: March 18, 2020