**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: 333-228375-02**

**Central Index Key Number of the issuing entity:0001787490**

**BANK 2019-BNK21**

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

** **

**Central Index Key Number of the depositor: 0001005007**

**Banc of America Merrill LynchCommercial Mortgage Inc.**

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

** **

**Central Index Key Number of the sponsor: 0001102113**

**Bank of America, NationalAssociation**

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

** **

**Central Index Key Number of the sponsor: 0001541557**

**Morgan Stanley Mortgage CapitalHoldings LLC**

**(exact name of the sponsor 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)**

** **

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

**the issuing entity)** | **38-4117274**

**38-7221292**

**38-4117273**

**(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:**

**(646) 855-3953**

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

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

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

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

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

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

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

Not applicable.

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

Not applicable.

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

Large accelerated filer       o                                                                                                 Acceleratedfiler                                  o

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

                                                                                                                                              Emerging growthcompany                          o

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

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

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

Not applicable.

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

Not applicable.

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

Not applicable.

**DOCUMENTS INCORPORATED BY REFERENCE**

** **

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

Not applicable.

 

** **

**EXPLANATORY NOTES**

The Park Tower at Transbay Mortgage Loan, the230 Park Avenue South Mortgage Loan, the Storage Post Portfolio Mortgage Loan,the 105 East 17th Street Mortgage Loan, the Tysons Tower Mortgage Loan, theNational Anchored Retail Portfolio Mortgage Loan and the Landing at FancherCreek Mortgage Loan, which constituted approximately 9.7%, 9.3%, 7.2%, 5.1%,4.2%, 4.2% and 1.7%, respectively, of the asset pool of the issuing entity asof its cut-off date, are each an asset of the issuing entity and are each partof a loan combination that includes (a) with respect to the Park Tower atTransbay Mortgage Loan which is an asset of the issuing entity and eight other *paripassu* loans, which are not assets of the issuing entity, (b) with respectto the 230 Park Avenue South Mortgage Loan which is an asset of the issuingentity and five other *pari passu* loans, which are not assets of theissuing entity, (c) with respect to the Storage Post Portfolio Mortgage Loanwhich is an asset of the issuing entity and two other *pari passu* loans,which are not assets of the issuing entity, (d) with respect to the 105 East17th Street Mortgage Loan which is an asset of the issuing entity and one other*pari passu* loan, which is not an asset of the issuing entity, (e) withrespect to the Tysons Tower Mortgage Loan which is an asset of the issuingentity and six other *pari passu* loans, which are not assets of theissuing entity, (f) with respect to the National Anchored Retail PortfolioMortgage Loan which is an asset of the issuing entity and two other *paripassu* loans, which are not assets of the issuing entity and (g) withrespect to the Landing at Fancher Creek Mortgage Loan which is an asset of theissuing entity and one other *pari passu* loan, which is not an asset ofthe issuing entity. These loan combinations, including the Park Tower atTransbay Mortgage Loan, the 230 Park Avenue South Mortgage Loan, the StoragePost Portfolio Mortgage Loan, the 105 East 17th Street Mortgage Loan, theTysons Tower Mortgage Loan, the National Anchored Retail Portfolio MortgageLoan and the Landing at Fancher Creek Mortgage Loan, are being serviced andadministered pursuant to the Pooling and Servicing Agreement, which isincorporated by reference 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 Grand Canal Shoppes Mortgage Loan, which constitutedapproximately 3.4% of the asset pool of the issuing entity as of its cut-offdate.  The Grand Canal Shoppes Mortgage Loan is an asset of the issuingentity and is part of a loan combination that includes the Grand Canal ShoppesMortgage Loan and twenty-three other *pari passu* loans and onesubordinate companion loan, which are not assets of the issuing entity. A *paripassu* portion of the loan combination was securitized in the Morgan StanleyCapital I Trust 2019-H7 transaction, Commission File Number 333-227446-05 (the“MSC 2019-H7 Transaction”). This loan combination, including the GrandCanal Shoppes Mortgage Loan, is being serviced and administered pursuant to thepooling and servicing agreement for the MSC 2019-H7 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 Tower at Burbank Mortgage Loan and the NKXMultifamily Portfolio Mortgage Loan, which constituted approximately 5.9% and2.6%, respectively, of the asset pool of the issuing entity as of its cut-offdate.  The Tower at Burbank Mortgage Loan and the NKX MultifamilyPortfolio Mortgage Loan are each an asset of the issuing entity and are eachpart of a loan combination that includes (a) with respect to The Tower atBurbank Mortgage Loan and two other *pari passu* loans, which are notassets of the issuing entity or (b) with respect to the NKX Multifamily PortfolioMortgage Loan and one other *pari passu* loan, which is not an asset ofthe issuing entity. A *pari passu* portion of each loan combination wassecuritized in the BANK 2019-BNK20 transaction, Commission File Number333-227446-06 (the “BANK 2019-BNK20 Transaction”). These loancombinations, including The Tower at Burbank Mortgage Loan and the NKXMultifamily Portfolio Mortgage Loan, are being serviced and administeredpursuant to the pooling and servicing agreement for the BANK 2019-BNK20Transaction, which is incorporated by reference as Exhibit 4.3 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 Global Data Center Mortgage Loan, whichconstituted approximately 1.0% of the asset pool of the issuing entity as ofits cut-off date.  The Global Data Center Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the Global DataCenter 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 UBS Commercial Mortgage Trust 2019-C17transaction, Commission File Number 333-227784-04 (the “UBS 2019-C17Transaction”). This loan combination, including the Global Data CenterMortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the UBS 2019-C17 Transaction, which is incorporated byreference as Exhibit 4.4 to this Annual Report on Form 10-K.

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

Wells Fargo Bank, NationalAssociation is the master servicer and certificate administrator of themortgage loans serviced under the Pooling and Servicing Agreement and theprimary servicer of the Storage Post Portfolio Mortgage Loan prior to October24, 2019, The Tower at Burbank Mortgage Loan, the NKX Multifamily PortfolioMortgage Loan and the Global Data Center Mortgage Loan. As a result, WellsFargo Bank, National Association is a “servicer” as defined in Item1108(a)(2)(iii) of Regulation AB, in the capacities described above, because itis servicing mortgage loans that constituted 10% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria, accountants’ attestation reports and servicercompliance statements delivered by Wells Fargo Bank, National Association in the capacities described above are listed in the Exhibit Index.

Wells Fargo Bank, NationalAssociation is the custodian of the mortgage loans serviced under the Poolingand Servicing Agreement, The Tower at Burbank Mortgage Loan, the Grand CanalShoppes Mortgage Loan, the NKX Multifamily Portfolio Mortgage Loan and theGlobal Data Center 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. The assessmentsof 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.

Rialto Capital Advisors, LLC isthe special servicer of the mortgage loans serviced under the Pooling andServicing Agreement and the Global Data Center Mortgage Loan. As a result,Rialto Capital Advisors, LLC 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 Rialto Capital Advisors, LLC in the capacities described above arelisted in the Exhibit Index.

Park Bridge Lender Services LLC is the operating advisor ofthe mortgage loans serviced under the Pooling and Servicing Agreement, The Towerat Burbank Mortgage Loan and the NKX Multifamily Portfolio Mortgage Loan. As a result, Park Bridge Lender Services LLC is a servicing functionparticipant in the capacities described above, because it is servicing mortgageloans that constituted 5% or more of the assets of the issuing entity as of itscut-off date. The assessments of compliance with applicable servicing criteriaand accountants’ attestation reports delivered by Park Bridge Lender ServicesLLC in the capacities described above are listed in the Exhibit Index.

Midland Loan Services, a Divisionof PNC Bank, National Association is the primary servicer of the Storage PostPortfolio Mortgage Loan on and after October 24, 2019 and the Grand CanalShoppes Mortgage Loan and the special servicer of The Tower at Burbank MortgageLoan and the NKX Multifamily Portfolio Mortgage Loan. As a result, Midland LoanServices, a Division of PNC Bank, National Association is a “servicer” asdefined in Item 1108(a)(2)(iii) of Regulation AB, in the capacities describedabove, because it is servicing mortgage loans that constituted 10% or more ofthe assets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria, accountants’ attestation reportsand servicer compliance statements delivered by Midland Loan Services, aDivision of PNC Bank, National Association in the capacities described aboveare listed in the Exhibit Index.

Wells Fargo Bank, National Association acts as trustee of theGrand Canal Shoppes Mortgage Loan.  Pursuant to the pooling and servicingagreement for the MSC 2019-H7 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 the reportingperiod, the trustee did not perform any servicing function with respect to theservicing criteria specified in Item 1122(d)(2)(iii) of Regulation AB. The master servicer or the special servicer, to the extent required, performedthe servicing function identified with respect to Item 1122(d)(2)(iii) ofRegulation AB, and each such party included Item 1122(d)(2)(iii) of RegulationAB in the assessment of compliance with applicable servicing criteria andaccountant’s attestation report for the subject transaction.  As a result,this Annual Report on Form 10-K does not include an assessment of compliancewith applicable servicing criteria of the trustee. One or more other servicersof the Grand Canal Shoppes Mortgage Loan have delivered one or more assessmentsof compliance with respect to Item 1122(d)(2)(iii) of Regulation AB.

Wilmington Trust, NationalAssociation acts as trustee of the mortgage loans serviced under the Poolingand Servicing Agreement, The Tower at Burbank Mortgage Loan, the NKXMultifamily Portfolio Mortgage Loan and the Global Data Center MortgageLoan.  Pursuant to the Pooling and Servicing Agreement, the pooling andservicing agreement for the BANK 2019-BNK20 Transaction and the pooling andservicing agreement for the UBS 2019-C17 Transaction, the trustee is requiredto provide an assessment of compliance with applicable servicing criteriasolely with respect to Item 1122(d)(2)(iii) of Regulation AB (regardingadvances of funds or guarantees regarding collections, cash flows or distributions,and any interest or other fees charged for such advances, are made, reviewedand approved as specified in the transaction agreements). However, during thereporting period, the trustee did not perform any servicing function withrespect to the servicing criteria specified in Item 1122(d)(2)(iii) ofRegulation AB.  The master servicer or the special servicer, to the extentrequired, performed the servicing function identified with respect to Item1122(d)(2)(iii) of Regulation AB, and each such party included Item1122(d)(2)(iii) of Regulation AB in the assessment of compliance withapplicable servicing criteria and accountant’s attestation report for thesubject transaction.  As a result, this Annual Report on Form 10-K doesnot include an assessment of compliance with applicable servicing criteria ofthe trustee. One or more other servicers of the mortgage loans serviced underthe Pooling and Servicing Agreement, The Tower at Burbank Mortgage Loan, theNKX Multifamily Portfolio Mortgage Loan and the Global Data Center MortgageLoan have delivered one or more assessments of compliance with respect to Item1122(d)(2)(iii) of Regulation AB.

This Annual Report on Form 10-Kincludes assessments of compliance with applicable servicing criteria andaccountants’ attestation reports from CoreLogic Commercial Real EstateServices, Inc. and National Tax Search, LLC.  These entities were engagedby the master servicer of the Pooling and Servicing Agreement (except withrespect to those mortgage loans for which Midland Loan Services, a Division ofPNC Bank, National Association is the primary servicer) and the primaryservicer of The Tower at Burbank Mortgage Loan, the NKX Multifamily PortfolioMortgage Loan and the Global Data Center Mortgage Loan to remit tax paymentsreceived from the escrow accounts of borrowers to local taxing authorities, toreport 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 andDisclosure Interpretations, Section 301.01 (Item 1101(j)).

Theassessments of compliance with applicable servicing criteria, accountants’ attestationreports and servicer compliance statements of the certificate administrator ofThe Tower at Burbank Mortgage Loan, the Grand Canal Shoppes Mortgage Loan, theNKX Multifamily Portfolio Mortgage Loan and the Global Data Center MortgageLoan listed on the Exhibit Index are omitted from this Annual Report on Form10-K as the certificate administrator pursuant to the related pooling andservicing agreement or trust and servicing agreement does not perform anyactivities that address servicing criteria with respect to the issuing entityand because they are each not a “servicer” that meets the criteria in Item1108(a)(2)(i) through (iii) of Regulation AB.

With respect to the *pari passu*loan combinations that include the Grand Canal Shoppes Mortgage Loan and theGlobal Data Center Mortgage Loan, (i) the reports on assessment of compliancewith servicing criteria and attestation reports on assessment of compliancewith servicing criteria of LNR Partners, LLC as special servicer of the GrandCanal Shoppes Mortgage Loan and Pentalpha Surveillance LLC as operating advisorof the Grand Canal Shoppes Mortgage Loan and the Global Data Center MortgageLoan, listed on the Exhibit Index are omitted from this Annual Report on Form10-K as they are not required to be included on this Annual Report on Form 10-Kper Instruction 3 to Item 1122 of Regulation AB because they are partiesperforming activities that address servicing criteria relating to 5% or less ofthe assets of the issuing entity; and (ii) the servicer compliance statement ofLNR Partners, LLC as special servicer of the Grand Canal Shoppes 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) ofRegulation AB.

**PART I**

**Item 1.  Business.**

Omitted.

**Item 1A.  Risk Factors.**

Omitted.

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

None.

**Item 2.  Properties.**

Omitted.

**Item 3.  Legal Proceedings.**

Omitted.

**Item 4.  Mine Safety Disclosures.**

Not applicable.

**PART II**

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

Omitted.

**Item 6.  Selected Financial Data.**

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**Item 9B.  Other Information.**

None.

**PART III**

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

Omitted.

**Item 11.  Executive Compensation.**

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**ADDITIONAL DISCLOSURE ITEMS FOR REGULATION AB**

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

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

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

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

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

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

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

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

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, to resolvesuch claims on a classwide basis for the 271 RMBS trusts at issue.  On May6, 2019, the court entered an order approving the settlement agreement. Separate lawsuits against Wells Fargo Bank making similar allegations filed bycertain other institutional investors concerning several RMBS trusts in NewYork federal and state court are not covered by the agreement.  Withrespect to such litigations, Wells Fargo Bank believes plaintiffs' claims arewithout merit and intends to contest the claims vigorously, but there can be noassurances as to the outcome of the litigations or the possible impact of thelitigations on Wells Fargo Bank or the RMBS trusts.

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

The information regarding this Item has been previouslyprovided in the prospectus of the Registrant relating to the issuing entityfiled on October 23, 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 Zto 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 Grand Canal Shoppes MortgageLoan, which is being serviced and administered pursuant to the pooling andservicing agreement for the MSC 2019-H7 Transaction, are attached hereto underItem 15 to this Annual Report on Form 10-K. Attached as Exhibit AA to the poolingand servicing agreement for the MSC 2019-H7 Transaction incorporated byreference as Exhibit 4.2 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the MSC2019-H7 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 Tower at Burbank Mortgage Loanand the NKX Multifamily Portfolio Mortgage Loan, which are being serviced andadministered pursuant to the pooling and servicing agreement for the BANK2019-BNK20 Transaction, are attached hereto under Item 15 to this Annual Reporton Form 10-K. Attached as Exhibit Z to the pooling and servicing agreement forthe BANK 2019-BNK20 Transaction incorporated by reference as Exhibit 4.3 tothis Annual Report on Form 10-K is a chart identifying the entitiesparticipating in a servicing function for the BANK 2019-BNK20 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 Global Data Center Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the UBS 2019-C17 Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit Z to the pooling andservicing agreement for the UBS 2019-C17 Transaction incorporated by referenceas Exhibit 4.4 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the UBS 2019-C17 Transactionresponsible for each applicable servicing criteria set forth in Item 1122(d).

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

Material Instance of Noncompliance

In certain instances, the ScheduleAL Files (Item 1125 of Regulation AB) were not reported in accordance with theterms specified in the transaction agreements, in conflict with Item1122(d)(3)(i): “Reports to investors, including those to be filed with theCommission, are maintained in accordance with the transaction agreements and applicableCommission requirements. Specifically, such reports: (A) Are prepared inaccordance with timeframes and other terms set forth in the transactionagreements”.  The noncompliance consisted of omitted or inaccuratelyreported fields as described in (1) and (2) below.  (1) In connection withother enhancements Midland made to its manual Schedule AL process, starting inApril 2019, Midland developed and implemented new Schedule AL reportingtemplates for each applicable CMBS transaction that closed prior to April 2019and for each applicable CMBS transaction going forward.  Related to this,Midland made certain template setup errors, along with related and other manualinputting of information errors, and the errors were not identified prior to submissionof the applicable Schedule AL Files in certain cases due to breakdowns inquality control.  (2) In one applicable transaction, the related ScheduleAL File for 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 notinvolve the servicing of assets included in this securitization.

Steps Taken to Remedy the Material Instance of Noncompliance

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

Midland is currently remediating theSchedule AL reporting for certain of the CMBS transactions found to beincorrect.

**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 October 1, 2019, by and among Banc ofAmerica Merrill Lynch Commercial Mortgage Inc., 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 ParkBridge Lender Services LLC, as Operating Advisor and Asset RepresentationsReviewer (filed as Exhibit 4.1 to the registrant’s Current Report on Form 8-Kfiled on October 23, 2019 under Commission File No. 333-228375-02 andincorporated by reference herein).

4.2         Poolingand Servicing Agreement, dated as of July 1, 2019, by and among Morgan StanleyCapital I Inc., as Depositor, Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer, LNR Partners, LLC, as Special Servicer,Wells Fargo Bank, National Association, as Certificate Administrator andTrustee, and Pentalpha Surveillance LLC, as Operating Advisor and AssetRepresentations Reviewer (filed as Exhibit 4.3 to the registrant’s CurrentReport on Form 8-K filed on October 23, 2019 under Commission File No.333-228375-02 and incorporated by reference herein).

4.3         Poolingand Servicing Agreement, dated as of September 1, 2019, by and among MorganStanley Capital I Inc., as Depositor, Wells Fargo Bank, National Association,as General 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 Asset Representations Reviewer (filed as Exhibit 4.2 to theregistrant’s Current Report on Form 8-K filed on October 23, 2019 underCommission File No. 333-228375-02 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, andPentalpha Surveillance LLC, as Operating Advisor and Asset Representations Reviewer(filed as Exhibit 4.4 to the registrant’s Current Report on Form 8-K filed onOctober 23, 2019 under Commission File No. 333-228375-02 and incorporated byreference herein).

4.5         AgreementBetween Note Holders, dated as of September 16, 2019, by and between Bank ofAmerica, N.A., as Initial Note A-1 Holder, and Bank of America, N.A., asInitial Note A-2 Holder, and Bank of America, N.A., as Initial Note A-3 Holder,and Bank of America, N.A., as Initial Note A-4 Holder, and Bank of America,N.A., as Initial Note A-5 Holder, and Bank of America, N.A., as Initial NoteA-6 Holder, and Bank of America, N.A., as Initial Note A-7 Holder, and Bank ofAmerica, N.A., as Initial Note A-8 Holder, and Bank of America, N.A., asInitial Note A-9 Holder, and Bank of America, N.A., as Initial Note A-10 Holder(filed as Exhibit 4.5 to the registrant’s Current Report on Form 8-K filed onOctober 23, 2019 under Commission File No. 333-228375-02 and incorporated byreference herein).

4.6         AgreementBetween Note Holders, dated as of October 23, 2019, by and between Wells FargoBank, National Association, as Initial Note A-1 Holder, Wells Fargo Bank,National Association, as Initial Note A-2 Holder, Wells Fargo Bank, NationalAssociation, as Initial Note A-3 Holder, Bank of America, National Association,as Initial Note A-4 Holder, Bank of America, National Association, as InitialNote A-5 Holder, Bank of America, National Association, as Initial Note A-6Holder, and JPMorgan Chase Bank, National Association, as Initial Note A-7Holder (filed as Exhibit 4.6 to the registrant’s Current Report on Form 8-Kfiled on October 23, 2019 under Commission File No. 333-228375-02 andincorporated by reference herein).

4.7         AgreementBetween Note Holders, dated as of October 23, 2019, by and between MorganStanley Bank, N.A., as Initial Note A-1 Holder, Morgan Stanley Bank, N.A., asInitial Note A-2 Holder, Morgan Stanley Bank, N.A., as Initial Note A-3 Holder,and Morgan Stanley Mortgage Capital Holdings LLC, as Initial Agent (filed asExhibit 4.7 to the registrant’s Current Report on Form 8-K filed on October 23,2019 under Commission File No. 333-228375-02 and incorporated by referenceherein).

4.8         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,National Association, as Initial Note A-3 Holder (filed as Exhibit 4.8 to theregistrant’s Current Report on Form 8-K filed on October 23, 2019 underCommission File No. 333-228375-02 and incorporated by reference herein).

4.9         AgreementBetween Note Holders, dated as of August 22, 2019, by and between MorganStanley Bank, N.A., as Initial Note A-1 Holder, DBR Investments Co. Limited, asInitial Note A-2 Holder, and Morgan Stanley Mortgage Capital Holdings LLC, asInitial Agent (filed as Exhibit 4.9 to the registrant’s Current Report on Form8-K filed on October 23, 2019 under Commission File No. 333-228375-02 andincorporated by reference herein).

4.10       AgreementBetween Note Holders, dated as of October 23, 2019, by and between Wells FargoBank, National Association, as Initial Note A-1 Holder, Wells Fargo Bank,National Association, as Initial Note A-2 Holder, Wells Fargo Bank, NationalAssociation, as Initial Note A-3 Holder, JPMorgan Chase Bank, NationalAssociation, as Initial Note A-4 Holder, JPMorgan Chase Bank, NationalAssociation, as Initial Note A-5 Holder, JPMorgan Chase Bank, NationalAssociation, as Initial Note A-6 Holder, and JPMorgan Chase Bank, NationalAssociation, as Initial Note A-7 Holder (filed as Exhibit 4.10 to theregistrant’s Current Report on Form 8-K filed on October 23, 2019 underCommission File No. 333-228375-02 and incorporated by reference herein).

4.11       AgreementBetween Note Holders, dated as of October 23, 2019, by and between Morgan StanleyBank, N.A., as Initial Note A-1 Holder, Morgan Stanley Bank, N.A., as InitialNote A-2 Holder, Morgan Stanley Bank, N.A., as Initial Note A-3 Holder, andMorgan Stanley Mortgage Capital Holdings LLC, as Initial Agent (filed asExhibit 4.11 to the registrant’s Current Report on Form 8-K filed on October23, 2019 under Commission File No. 333-228375-02 and incorporated by referenceherein).

4.12       AgreementBetween Noteholders, dated as of July 3, 2019, between Morgan Stanley Bank,N.A., as Note A-1 Holder, Wells Fargo Bank, National Association, as Note A-2Holder, JPMorgan Chase Bank, National Association, as Note A-3 Holder, GoldmanSachs Bank USA, as Note A-4 Holder, and CPPIB Credit Investments II Inc., asNote B Holder (filed as Exhibit 4.12 to the registrant’s Current Report on Form8-K filed on October 23, 2019 under Commission File No. 333-228375-02 andincorporated by reference herein).

4.13       AgreementBetween Note Holders, dated as of September 26, 2019, by and between MorganStanley Bank, N.A., as Initial Note A-1 Holder, Morgan Stanley Bank, N.A., asInitial Note A-2 Holder, and Morgan Stanley Mortgage Capital Holdings LLC, asInitial Agent (filed as Exhibit 4.13 to the registrant’s Current Report on Form8-K filed on October 23, 2019 under Commission File No. 333-228375-02 andincorporated by reference herein).

4.14       AgreementBetween Note Holders, dated as of October 15, 2019, by and between Wells FargoBank, National Association, as Initial Note A-1 Holder, and Wells Fargo Bank,National Association, as Initial Note A-2 Holder (filed as Exhibit 4.14 to theregistrant’s Current Report on Form 8-K filed on October 23, 2019 underCommission File No. 333-228375-02 and incorporated by reference herein).

4.15       AgreementBetween Note Holders, dated as of October 15, 2019, by and between Wells FargoBank, National Association, as Initial Note A-1 Holder, and Wells Fargo Bank,National Association, as Initial Note A-2 Holder (filed as Exhibit 4.15 to theregistrant’s Current Report on Form 8-K filed on October 23, 2019 underCommission File No. 333-228375-02 and incorporated by reference herein).

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

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

33.1       Wells Fargo Bank, NationalAssociation, as Master Servicer

33.2       Rialto Capital Advisors,LLC, as Special Servicer

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

33.4       Wells Fargo Bank, 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 Park Tower at Transbay Mortgage Loan(see Exhibit 33.1)

33.10     Rialto Capital Advisors,LLC, as Special Servicer of the Park Tower at Transbay Mortgage Loan (seeExhibit 33.2)

33.11     Wilmington Trust, National Association, as Trustee of the Park Tower atTransbay Mortgage Loan (Omitted. See Explanatory Notes.)

33.12     Wells Fargo Bank, NationalAssociation, as Custodian of the Park Tower at Transbay Mortgage Loan (seeExhibit 33.5)

33.13     Park Bridge LenderServices LLC, as Operating Advisor of the Park Tower at Transbay Mortgage Loan(see Exhibit 33.6)

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

33.15     National Tax Search, LLC,as Servicing Function Participant of the Park Tower at Transbay Mortgage Loan(see Exhibit 33.8)

33.16     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 230 Park Avenue South Mortgage Loan(see Exhibit 33.1)

33.17     Rialto Capital Advisors,LLC, as Special Servicer of the 230 Park Avenue South Mortgage Loan (seeExhibit 33.2)

33.18     Wilmington Trust, National Association, as Trustee of the 230 Park Avenue SouthMortgage Loan (Omitted. See Explanatory Notes.)

33.19     Wells Fargo Bank, NationalAssociation, as Custodian of the 230 Park Avenue South Mortgage Loan (seeExhibit 33.5)

33.20     Park Bridge LenderServices LLC, as Operating Advisor of the 230 Park Avenue South Mortgage Loan(see Exhibit 33.6)

33.21     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the 230 Park AvenueSouth Mortgage Loan (see Exhibit 33.7)

33.22     National Tax Search, LLC,as Servicing Function Participant of the 230 Park Avenue South Mortgage Loan(see Exhibit 33.8)

33.23     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Storage Post Portfolio Mortgage Loanprior to October 24, 2019 (see Exhibit 33.1)

33.24     Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the StoragePost Portfolio Mortgage Loan on and after October 24, 2019

33.25     Rialto Capital Advisors,LLC, as Special Servicer of the Storage Post Portfolio Mortgage Loan (seeExhibit 33.2)

33.26     Wilmington Trust, National Association, as Trustee of the Storage PostPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.27     Wells Fargo Bank, NationalAssociation, as Custodian of the Storage Post Portfolio Mortgage Loan (seeExhibit 33.5)

33.28     Park Bridge Lender ServicesLLC, as Operating Advisor of the Storage Post Portfolio Mortgage Loan (seeExhibit 33.6)

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

33.30     National Tax Search, LLC,as Servicing Function Participant of the Storage Post Portfolio Mortgage Loan(see Exhibit 33.8)

33.31     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 105 East 17th Street Mortgage Loan (seeExhibit 33.1)

33.32     Rialto Capital Advisors,LLC, as Special Servicer of the 105 East 17th Street Mortgage Loan (see Exhibit33.2)

33.33     Wilmington Trust, National Association, as Trustee of the 105 East 17th StreetMortgage Loan (Omitted. See Explanatory Notes.)

33.34     Wells Fargo Bank, NationalAssociation, as Custodian of the 105 East 17th Street Mortgage Loan (seeExhibit 33.5)

33.35     Park Bridge LenderServices LLC, as Operating Advisor of the 105 East 17th Street Mortgage Loan(see Exhibit 33.6)

33.36     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the 105 East 17thStreet Mortgage Loan (see Exhibit 33.7)

33.37     National Tax Search, LLC,as Servicing Function Participant of the 105 East 17th Street Mortgage Loan(see Exhibit 33.8)

33.38     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the National Anchored Retail PortfolioMortgage Loan (see Exhibit 33.1)

33.39     Rialto Capital Advisors,LLC, as Special Servicer of the National Anchored Retail Portfolio MortgageLoan (see Exhibit 33.2)

33.40     Wilmington Trust, National Association, as Trustee of the National AnchoredRetail Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.41     Wells Fargo Bank, NationalAssociation, as Custodian of the National Anchored Retail Portfolio MortgageLoan (see Exhibit 33.5)

33.42     Park Bridge LenderServices LLC, as Operating Advisor of the National Anchored Retail PortfolioMortgage Loan (see Exhibit 33.6)

33.43     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the NationalAnchored Retail Portfolio Mortgage Loan (see Exhibit 33.7)

33.44     National Tax Search, LLC,as Servicing Function Participant of the National Anchored Retail PortfolioMortgage Loan (see Exhibit 33.8)

33.45     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Tysons Tower Mortgage Loan (see Exhibit33.1)

33.46     Rialto Capital Advisors,LLC, as Special Servicer of the Tysons Tower Mortgage Loan (see Exhibit 33.2)

33.47     Wilmington Trust, National Association, as Trustee of the Tysons Tower MortgageLoan (Omitted. See Explanatory Notes.)

33.48     Wells Fargo Bank, NationalAssociation, as Custodian of the Tysons Tower Mortgage Loan (see Exhibit 33.5)

33.49     Park Bridge LenderServices LLC, as Operating Advisor of the Tysons Tower Mortgage Loan (seeExhibit 33.6)

33.50     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Tysons TowerMortgage Loan (see Exhibit 33.7)

33.51     National Tax Search, LLC,as Servicing Function Participant of the Tysons Tower Mortgage Loan (seeExhibit 33.8)

33.52     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Landing at Fancher Creek Mortgage Loan(see Exhibit 33.1)

33.53     Rialto Capital Advisors,LLC, as Special Servicer of the Landing at Fancher Creek Mortgage Loan (seeExhibit 33.2)

33.54     Wilmington Trust, National Association, as Trustee of the Landing at FancherCreek Mortgage Loan (Omitted. See Explanatory Notes.)

33.55     Wells Fargo Bank, NationalAssociation, as Custodian of the Landing at Fancher Creek Mortgage Loan (seeExhibit 33.5)

33.56     Park Bridge LenderServices LLC, as Operating Advisor of the Landing at Fancher Creek MortgageLoan (see Exhibit 33.6)

33.57     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Landing atFancher Creek Mortgage Loan (see Exhibit 33.7)

33.58     National Tax Search, LLC,as Servicing Function Participant of the Landing at Fancher Creek Mortgage Loan(see Exhibit 33.8)

33.59     Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the GrandCanal Shoppes Mortgage Loan (see Exhibit 33.24)

33.60     LNR Partners, LLC, as Special Servicer of the Grand Canal Shoppes Mortgage Loan(Omitted. See Explanatory Notes.)

33.61     Wells Fargo Bank, National Association, as Trustee of the Grand Canal ShoppesMortgage Loan (Omitted. See Explanatory Notes.)

33.62     Wells Fargo Bank, NationalAssociation, as Custodian of the Grand Canal Shoppes Mortgage Loan (see Exhibit33.5)

33.63     Pentalpha Surveillance LLC, as Operating Advisor of the Grand Canal ShoppesMortgage Loan (Omitted. See Explanatory Notes.)

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

33.65     Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of The Tower atBurbank Mortgage Loan (see Exhibit 33.24)

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

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

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

33.69     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of The Tower atBurbank Mortgage Loan (see Exhibit 33.7)

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

33.71     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the NKX Multifamily Portfolio Mortgage Loan(see Exhibit 33.1)

33.72     Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the NKXMultifamily Portfolio Mortgage Loan (see Exhibit 33.24)

33.73     Wilmington Trust, National Association, as Trustee of the NKX MultifamilyPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.74     Wells Fargo Bank, NationalAssociation, as Custodian of the NKX Multifamily Portfolio Mortgage Loan (seeExhibit 33.5)

33.75     Park Bridge LenderServices LLC, as Operating Advisor of the NKX Multifamily Portfolio MortgageLoan (see Exhibit 33.6)

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

33.77     National Tax Search, LLC,as Servicing Function Participant of the NKX Multifamily Portfolio MortgageLoan (see Exhibit 33.8)

33.78     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Global Data Center Mortgage Loan (seeExhibit 33.1)

33.79     Rialto Capital Advisors,LLC, as Special Servicer of the Global Data Center Mortgage Loan (see Exhibit33.2)

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

33.81     Wells Fargo Bank, NationalAssociation, as Custodian of the Global Data Center Mortgage Loan (see Exhibit33.5)

33.82     Pentalpha Surveillance LLC, as Operating Advisor of the Global Data CenterMortgage Loan (Omitted. See Explanatory Notes.)

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

33.84     National Tax Search, LLC,as Servicing Function Participant of the Global Data Center Mortgage Loan (seeExhibit 33.8)

34          Attestation reports onassessment of compliance with servicing criteria for asset-backed securities.

34.1       Wells Fargo Bank, NationalAssociation, as Master Servicer

34.2       Rialto Capital Advisors,LLC, as Special Servicer

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

34.4       Wells Fargo Bank, 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, asServicing Function Participant

34.9       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Park Tower at Transbay Mortgage Loan(see Exhibit 34.1)

34.10     Rialto Capital Advisors,LLC, as Special Servicer of the Park Tower at Transbay Mortgage Loan (seeExhibit 34.2)

34.11     Wilmington Trust, National Association, as Trustee of the Park Tower atTransbay Mortgage Loan (Omitted. See Explanatory Notes.)

34.12     Wells Fargo Bank, NationalAssociation, as Custodian of the Park Tower at Transbay Mortgage Loan (seeExhibit 34.5)

34.13     Park Bridge LenderServices LLC, as Operating Advisor of the Park Tower at Transbay Mortgage Loan(see Exhibit 34.6)

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

34.15     National Tax Search, LLC,as Servicing Function Participant of the Park Tower at Transbay Mortgage Loan(see Exhibit 34.8)

34.16     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 230 Park Avenue South Mortgage Loan(see Exhibit 34.1)

34.17     Rialto Capital Advisors,LLC, as Special Servicer of the 230 Park Avenue South Mortgage Loan (seeExhibit 34.2)

34.18     Wilmington Trust, National Association, as Trustee of the 230 Park Avenue SouthMortgage Loan (Omitted. See Explanatory Notes.)

34.19     Wells Fargo Bank, NationalAssociation, as Custodian of the 230 Park Avenue South Mortgage Loan (seeExhibit 34.5)

34.20     Park Bridge LenderServices LLC, as Operating Advisor of the 230 Park Avenue South Mortgage Loan(see Exhibit 34.6)

34.21     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the 230 Park AvenueSouth Mortgage Loan (see Exhibit 34.7)

34.22     National Tax Search, LLC,as Servicing Function Participant of the 230 Park Avenue South Mortgage Loan(see Exhibit 34.8)

34.23     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Storage Post Portfolio Mortgage Loanprior to October 24, 2019 (see Exhibit 34.1)

34.24     Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the StoragePost Portfolio Mortgage Loan on and after October 24, 2019

34.25     Rialto Capital Advisors, LLC,as Special Servicer of the Storage Post Portfolio Mortgage Loan (see Exhibit34.2)

34.26     Wilmington Trust, National Association, as Trustee of the Storage PostPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.27     Wells Fargo Bank, NationalAssociation, as Custodian of the Storage Post Portfolio Mortgage Loan (seeExhibit 34.5)

34.28     Park Bridge Lender ServicesLLC, as Operating Advisor of the Storage Post Portfolio Mortgage Loan (seeExhibit 34.6)

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

34.30     National Tax Search, LLC,as Servicing Function Participant of the Storage Post Portfolio Mortgage Loan(see Exhibit 34.8)

34.31     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 105 East 17th Street Mortgage Loan (seeExhibit 34.1)

34.32     Rialto Capital Advisors,LLC, as Special Servicer of the 105 East 17th Street Mortgage Loan (see Exhibit34.2)

34.33     Wilmington Trust, National Association, as Trustee of the 105 East 17th StreetMortgage Loan (Omitted. See Explanatory Notes.)

34.34     Wells Fargo Bank, NationalAssociation, as Custodian of the 105 East 17th Street Mortgage Loan (seeExhibit 34.5)

34.35     Park Bridge LenderServices LLC, as Operating Advisor of the 105 East 17th Street Mortgage Loan(see Exhibit 34.6)

34.36     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the 105 East 17thStreet Mortgage Loan (see Exhibit 34.7)

34.37     National Tax Search, LLC,as Servicing Function Participant of the 105 East 17th Street Mortgage Loan(see Exhibit 34.8)

34.38     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the National Anchored Retail PortfolioMortgage Loan (see Exhibit 34.1)

34.39     Rialto Capital Advisors,LLC, as Special Servicer of the National Anchored Retail Portfolio MortgageLoan (see Exhibit 34.2)

34.40     Wilmington Trust, National Association, as Trustee of the National AnchoredRetail Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.41     Wells Fargo Bank, NationalAssociation, as Custodian of the National Anchored Retail Portfolio MortgageLoan (see Exhibit 34.5)

34.42     Park Bridge LenderServices LLC, as Operating Advisor of the National Anchored Retail PortfolioMortgage Loan (see Exhibit 34.6)

34.43     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the NationalAnchored Retail Portfolio Mortgage Loan (see Exhibit 34.7)

34.44     National Tax Search, LLC,as Servicing Function Participant of the National Anchored Retail PortfolioMortgage Loan (see Exhibit 34.8)

34.45     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Tysons Tower Mortgage Loan (see Exhibit34.1)

34.46     Rialto Capital Advisors, LLC,as Special Servicer of the Tysons Tower Mortgage Loan (see Exhibit 34.2)

34.47     Wilmington Trust, National Association, as Trustee of the Tysons Tower MortgageLoan (Omitted. See Explanatory Notes.)

34.48     Wells Fargo Bank, NationalAssociation, as Custodian of the Tysons Tower Mortgage Loan (see Exhibit 34.5)

34.49     Park Bridge LenderServices LLC, as Operating Advisor of the Tysons Tower Mortgage Loan (seeExhibit 34.6)

34.50     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Tysons TowerMortgage Loan (see Exhibit 34.7)

34.51     National Tax Search, LLC,as Servicing Function Participant of the Tysons Tower Mortgage Loan (seeExhibit 34.8)

34.52     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Landing at Fancher Creek Mortgage Loan(see Exhibit 34.1)

34.53     Rialto Capital Advisors,LLC, as Special Servicer of the Landing at Fancher Creek Mortgage Loan (seeExhibit 34.2)

34.54     Wilmington Trust, National Association, as Trustee of the Landing at FancherCreek Mortgage Loan (Omitted. See Explanatory Notes.)

34.55     Wells Fargo Bank, NationalAssociation, as Custodian of the Landing at Fancher Creek Mortgage Loan (seeExhibit 34.5)

34.56     Park Bridge LenderServices LLC, as Operating Advisor of the Landing at Fancher Creek MortgageLoan (see Exhibit 34.6)

34.57     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Landing atFancher Creek Mortgage Loan (see Exhibit 34.7)

34.58     National Tax Search, LLC,as Servicing Function Participant of the Landing at Fancher Creek Mortgage Loan(see Exhibit 34.8)

34.59     Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the GrandCanal Shoppes Mortgage Loan (see Exhibit 34.24)

34.60     LNR Partners, LLC, as Special Servicer of the Grand Canal Shoppes Mortgage Loan(Omitted. See Explanatory Notes.)

34.61     Wells Fargo Bank, National Association, as Trustee of the Grand Canal ShoppesMortgage Loan (Omitted. See Explanatory Notes.)

34.62     Wells Fargo Bank, NationalAssociation, as Custodian of the Grand Canal Shoppes Mortgage Loan (see Exhibit34.5)

34.63     Pentalpha Surveillance LLC, as Operating Advisor of the Grand Canal ShoppesMortgage Loan (Omitted. See Explanatory Notes.)

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

34.65     Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of The Tower atBurbank Mortgage Loan (see Exhibit 34.24)

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

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

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

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

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

34.71     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the NKX Multifamily Portfolio Mortgage Loan(see Exhibit 34.1)

34.72     Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the NKXMultifamily Portfolio Mortgage Loan (see Exhibit 34.24)

34.73     Wilmington Trust, National Association, as Trustee of the NKX MultifamilyPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.74     Wells Fargo Bank, NationalAssociation, as Custodian of the NKX Multifamily Portfolio Mortgage Loan (seeExhibit 34.5)

34.75     Park Bridge LenderServices LLC, as Operating Advisor of the NKX Multifamily Portfolio MortgageLoan (see Exhibit 34.6)

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

34.77     National Tax Search, LLC,as Servicing Function Participant of the NKX Multifamily Portfolio MortgageLoan (see Exhibit 34.8)

34.78     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Global Data Center Mortgage Loan (seeExhibit 34.1)

34.79     Rialto Capital Advisors,LLC, as Special Servicer of the Global Data Center Mortgage Loan (see Exhibit34.2)

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

34.81     Wells Fargo Bank, NationalAssociation, as Custodian of the Global Data Center Mortgage Loan (see Exhibit34.5)

34.82     Pentalpha Surveillance LLC, as Operating Advisor of the Global Data CenterMortgage Loan (Omitted. See Explanatory Notes.)

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

34.84     National Tax Search, LLC,as Servicing Function Participant of the Global Data Center Mortgage Loan (seeExhibit 34.8)

35          Servicer compliance statements.

35.1       Wells Fargo Bank, NationalAssociation, as Master Servicer

35.2       Rialto Capital Advisors,LLC, as Special Servicer

35.3       Wells Fargo Bank, NationalAssociation, as Certificate Administrator

35.4       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Park Tower at Transbay Mortgage Loan(see Exhibit 35.1)

35.5       Rialto Capital Advisors,LLC, as Special Servicer of the Park Tower at Transbay Mortgage Loan (seeExhibit 35.2)

35.6       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 230 Park Avenue South Mortgage Loan(see Exhibit 35.1)

35.7       Rialto Capital Advisors,LLC, as Special Servicer of the 230 Park Avenue South Mortgage Loan (seeExhibit 35.2)

35.8       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Storage Post Portfolio Mortgage Loanprior to October 24, 2019 (see Exhibit 35.1)

35.9       Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the StoragePost Portfolio Mortgage Loan on and after October 24, 2019

35.10     Rialto Capital Advisors,LLC, as Special Servicer of the Storage Post Portfolio Mortgage Loan (seeExhibit 35.2)

35.11     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 105 East 17th Street Mortgage Loan (seeExhibit 35.1)

35.12     Rialto Capital Advisors,LLC, as Special Servicer of the 105 East 17th Street Mortgage Loan (see Exhibit35.2)

35.13     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the National Anchored Retail PortfolioMortgage Loan (see Exhibit 35.1)

35.14     Rialto Capital Advisors,LLC, as Special Servicer of the National Anchored Retail Portfolio MortgageLoan (see Exhibit 35.2)

35.15     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Tysons Tower Mortgage Loan (see Exhibit35.1)

35.16     Rialto Capital Advisors,LLC, as Special Servicer of the Tysons Tower Mortgage Loan (see Exhibit 35.2)

35.17     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Landing at Fancher Creek Mortgage Loan(see Exhibit 35.1)

35.18     Rialto Capital Advisors,LLC, as Special Servicer of the Landing at Fancher Creek Mortgage Loan (seeExhibit 35.2)

35.19     Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the GrandCanal Shoppes Mortgage Loan (see Exhibit 35.9)

35.20     LNR Partners, LLC, as Special Servicer of the Grand Canal Shoppes Mortgage Loan(Omitted. See Explanatory Notes.)

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

35.22     Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of The Tower atBurbank Mortgage Loan (see Exhibit 35.9)

35.23     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the NKX Multifamily Portfolio Mortgage Loan(see Exhibit 35.1)

35.24     Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the NKXMultifamily Portfolio Mortgage Loan (see Exhibit 35.9)

35.25     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Global Data Center Mortgage Loan (seeExhibit 35.1)

35.26     Rialto Capital Advisors,LLC, as Special Servicer of the Global Data Center Mortgage Loan (see Exhibit35.2)

99.1       MortgageLoan Purchase Agreement, dated as of September 27, 2019, between Banc ofAmerica Merrill Lynch Commercial Mortgage Inc. and Bank of America, NationalAssociation (filed as Exhibit 99.2 to the registrant’s Current Report on Form8-K filed on October 23, 2019 under Commission File No. 333-228375-02 andincorporated by reference herein)

99.2       MortgageLoan Purchase Agreement, dated as of September 27, 2019, between Banc ofAmerica Merrill Lynch Commercial Mortgage Inc. and Morgan Stanley Mortgage CapitalHoldings LLC (filed as Exhibit 99.1 to the registrant’s Current Report on Form8-K filed on October 23, 2019 under Commission File No. 333-228375-02 andincorporated by reference herein)

99.3       MortgageLoan Purchase Agreement, dated as of September 27, 2019, between Banc ofAmerica Merrill Lynch Commercial Mortgage Inc. and Wells Fargo Bank, NationalAssociation (filed as Exhibit 99.3 to the registrant’s Current Report on Form8-K filed on October 23, 2019 under Commission File No. 333-228375-02 andincorporated by reference herein)

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

(c)   Not Applicable.

 

**SIGNATURES**

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

Banc of America Merrill LynchCommercial Mortgage Inc.(Depositor)

/s/ LelandF. Bunch, III

Leland F.Bunch, III, President and Chief Executive Officer

(senior officer in charge ofsecuritization of the depositor)

Date: March 20, 2020