**UNITED STATESSECURITIES AND EXCHANGE COMMISSION**

**WASHINGTON,D.C. 20549**

**FORM 10‐K**

(Mark one)

**/X/ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIESEXCHANGE ACT OF 1934**

**    For the fiscal year endedDecember 31, 2019 OR**

**//TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIESEXCHANGE ACT OF 1934**

**For the transition period from****            ****to****            **

 

 

 

**Commission file number:333-227446-07**

 

**Central Index Key Number of the issuing entity:****0001791295**

 

**Morgan Stanley Capital ITrust 2019-L3**

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

 

**Central Index Key Number of the depositor:0001547361**

 

**Morgan Stanley Capital I Inc.**

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

 

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

 

**Morgan Stanley MortgageCapital Holdings LLC**

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

 

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

 

**Starwood Mortgage Capital LLC**

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

** **

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

 

**Argentic Real Estate FinanceLLC**

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

 

 

**Central Index Key Number of the sponsor:0001089877**

 

**KeyBank National Association**

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

** **

**Central Index Key Number of the sponsor:0001558761**

 

**Cantor Commercial Real EstateLending, L.P.**

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

 

| **New York**                                                        | **38-4128792**

**38-4128793**

**38-7235612** |
|---------------------------------------------------------------------|------------------------------------------------|
| **(State or other jurisdiction of incorporation or  organization)** | **(I.R.S. Employer Identification Numbers)**   |

 

**c/o Wells Fargo Bank, N.A.**

**9062 Old Annapolis Road**

** Columbia, MD**

**(Address of principal executive offices)**

 

**21045**

**(Zip Code)**

 

**Telephone number, including area code:**

**(410) 884‐2000**

Securitiesregistered pursuant to Section 12(b) of the Act:

 

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

 

Securitiesregistered pursuant to Section 12(g) of the Act:

 

  NONE.

 

Indicateby check mark if the registrant is a well-known seasoned issuer, as defined inRule 405 of the Securities Act.

 

  Yes___ No X

 

Indicateby check mark if the registrant is not required to file reports pursuant toSection 13 or Section 15(d) of the Act.

 

  Yes___ No X

 

Note- Checking the box above will not relieve any registrant required to filereports pursuant to Section 13 or 15(d) of the Exchange Act from theirobligations under those Sections.

 

Indicate by check mark whether the registrant (1) has filed all reportsrequired to be filed by Section 13 or 15(d) of the Securities Exchange Act of1934 during the preceding 12 months (or for such shorter period that theregistrant was required to file such reports), and (2) has been subject to suchfiling requirements for the past 90 days.

 

  YesX No ___

 

Indicateby check mark whether the registrant has submitted electronically and posted onits corporate Web site, if any, every Interactive Data File required to besubmitted and posted pursuant to Rule 405 of Regulation S-T (Section 232.405 ofthis chapter) during the preceding 12 months (or for such shorter period thatthe registrant was required to submit and post such files).

 

  Notapplicable.

 

Indicateby check mark if disclosure of delinquent filers pursuant to Item 405 ofRegulation S-K (Section 229.405 of this chapter) is not contained herein, andwill not be contained, to the best of registrant's knowledge, in definitiveproxy or information statements incorporated by reference in Part III of thisForm 10-K or any amendment to this Form 10-K.

 

  Notapplicable.

 

Indicateby check mark whether the registrant is a large accelerated filer, anaccelerated filer, a non-accelerated filer, a smaller reporting company, oremerging growth company. See the definitions of "large acceleratedfiler", "accelerated filer," "smaller reportingcompany," and “emerging growth company” in Rule 12b-2 of the Exchange Act.

 

 Largeaccelerated filer ___ Accelerated filer ___ Non-accelerated filer X (Do not check if a smaller reporting company)Smaller reporting company ___

 

Emerginggrowth company ___

 

Ifan emerging growth company, indicate by check mark if the registrant haselected not to use the extended transition period for complying with any new orrevised financial accounting standards provided pursuant to Section 13(a) ofthe Ex­change Act.

 

  Notapplicable.

 

Indicateby check mark whether the registrant is a shell company (as defined in Rule12b-2 of the Act).

 

  Yes___ No X

 

Statethe aggregate market value of the voting and non-voting common equity held bynon-affiliates computed by reference to the price at which the common equitywas last sold, or the average bid and asked price of such common equity, as ofthe last business day of the registrant's most recently completed second fiscalquarter.

 

  Notapplicable.

 

Indicateby check mark whether the registrant has filed all documents and reportsrequired to be filed by Section 12, 13 or 15(d) of the Securities Exchange Actof 1934 subsequent to the distribution of securities under a plan confirmed bya court.

 

  Notapplicable.

 

Indicatethe number of shares outstanding of each of the registrant's classes of commonstock, as of the latest practicable date.

 

  Notapplicable.

 

DOCUMENTSINCORPORATED BY REFERENCE

 

Listhereunder the following documents if incorporated by reference and the Part ofthe Form 10-K (e.g., Part I, Part II, etc.) into which the document isincorporated: (1)Any annual report to security holders; (2) Any proxy orinformation statement; and (3)Any prospectus filed pursuant to Rule 424(b) or(c) under the Securities Act of 1933. The listed documents should be clearlydescribed for identification purposes (e.g., annual report to security holdersfor fiscal year ended December 24, 1980).

 

  Notapplicable.

 

**EXPLANATORY NOTES**

 

The MSC 2019-L3 mortgage pool includes thefollowing mortgage loans, each of which is serviced pursuant to a separatepooling and servicing agreement (each, an “Outside Pooling and ServicingAgreement”):

 

•   the GNL Office and IndustrialPortfolio mortgage loan, the Bushwick Avenue Portfolio mortgage loan and theHilton Portfolio mortgage loan, which are serviced pursuant to the CF 2019-CF2pooling and servicing agreement attached hereto as Exhibit 4.2;

 

•   the Grand Canal Shoppesmortgage loan, which is serviced pursuant to the MSC 2019-H7  pooling andservicing agreement attached hereto as Exhibit 4.3;

 

  •   the OsbornTriangle mortgage loan, which is serviced pursuant to the JPMCC 2019-OSB trustand servicing agreement attached hereto as Exhibit 4.4;

 

•   the National Anchored RetailPortfolio mortgage loan, which is serviced pursuant to the BANK 2019-BNK21pooling and servicing agreement attached hereto as Exhibit 4.5.

 

Except as set forth below, each of theparties to each pooling and servicing agreement listed in the Exhibit Indexboth (1) participates in the servicing function for purposes of Item 1122 ofRegulation AB and (2) constitutes a servicer that meets the criteria in Item1108(a)(2)(i) through (iii) of Regulation AB for purposes of Item 1123 ofRegulation AB:

 

•   The trustee under a poolingand servicing agreement has a nominal role with respect to the mortgage poolsecuritized pursuant to such pooling and servicing agreement.  Thetrustee’s only servicing function is the contingent obligation to make certainadvances if the master servicer under such pooling and servicing agreement failsto do so, while all other servicing functions are performed by otherparties.  The trustee under each of the pooling and servicing agreementslisted in the Exhibit Index has confirmed to the registrant that it has notmade any such contingent advances during the reporting period, andconsequently, each such trustee does not participate in the servicing functionfor purposes of Item 1122 of Regulation AB, nor does it perform the functionsof a servicer for purposes of the definition of “servicer” under Item 1101 ofRegulation AB or for purposes of Item 1123 of Regulation AB.

 

•   The certificate administratorunder a pooling and servicing agreement performs various payment administrationfunctions solely for the securitization governed by such pooling and servicingagreement and the mortgage pool securitized pursuant to such pooling andservicing agreement and does not have any obligations with respect to any othertransaction.  Consequently, the certificate administrator under an OutsidePooling and Servicing Agreement does not participate in the servicing functionfor purposes of Item 1122 of Regulation AB, nor does it perform the functionsof a servicer for purposes of the definition of “servicer” under Item 1101 ofRegulation AB or for purposes of Item 1123 of Regulation AB.

 

•   The operating advisor under apooling and servicing agreement represents the interests of seniorcertificateholders in the transaction governed by such pooling and servicingagreement and is responsible for monitoring the performance of the specialservicer under such pooling and servicing agreement and producing certainreports to certificateholders relating to the resolution of the mortgage poolsecuritized pursuant to such pooling and servicing agreement.  Theoperating advisor under a pooling and servicing agreement does not have anyobligations with respect to any other transaction and is solely obligated toperform loan reporting functions with respect to the securitization governed bysuch pooling and servicing agreement.  Consequently, the operating advisorunder an Outside Pooling and Servicing Agreement neither participates in theservicing function for purposes of Item 1122 of Regulation AB nor performs thefunctions of a servicer for purposes of the definition of “servicer” under Item1101 of Regulation AB or for purposes of Item 1123 of Regulation AB.  Inaddition, while the operating advisor under a pooling and servicing agreementhas certain reporting obligations in respect of the related mortgage pool, ithas no obligation to collect or disburse funds in respect of the mortgage poolor to administer any of the underlying mortgage loans.  Consequently, theoperating advisor under a pooling and servicing agreement participates in theservicing function for purposes of Item 1122 of Regulation AB, but is notresponsible for the “management or collection of the pool assets or makingallocations or distributions to holders of the asset-backed securities” withinthe meaning of “servicer” under Item 1101 of Regulation AB and does not performthe functions of a servicer for purposes of Item 1123 of Regulation AB. 

 

•   The asset representations reviewer under a poolingand servicing agreement has a limited obligation to review certain delinquentmortgage loans after a specified delinquency threshold has been met and therequired percentage of certificateholders vote to direct a review of suchdelinquent mortgage loans, and has no obligation to collect or disburse fundsin respect of the mortgage pool, to administer any of the underlying mortgageloans or to perform any servicing function.  Consequently, the assetrepresentations reviewer under a pooling and servicing agreement does notparticipate in the servicing function for purposes of Item 1122 of RegulationAB, is not responsible for the “management or collection of the pool assets ormaking allocations or distributions to holders of the asset-backed securities”within the meaning of “servicer” under Item 1101 of Regulation AB and does notperform the functions of a servicer for purposes of Item 1123 of Regulation AB.

•   KeyBank National Association,as The Stanwix special servicer under the CF 2019-CF2 pooling and servicingagreement, only has obligations in respect of The Stanwix mortgage loansecuritized thereunder. KeyBank National Association, as The Stanwix specialservicer under the CF 2019-CF2 pooling and servicing agreement, has noobligations with respect to the any mortgage loan included in the MSC 2019-L3mortgage pool and therefore such party in such capacity does not constitute areporting “servicing function participant” for purposes of Item 1122 ofRegulation AB, as specified in the Instruction 3 to Item 1122, and does notconstitute a reporting “servicer” for purposes of Item 1123 of Regulation AB,as specified in the Instruction to Item 1123.

 

•   Midland Loan Services, a Division of PNC Bank, NationalAssociation is the master servicer under the MSC2019-H7 pooling and servicing agreement, pursuant to which the Grand CanalShoppes mortgage loan is serviced.  Because Midland Loan Services,a Division of PNC Bank, National Association is notthe MSC 2019-L3 special servicer, is not affiliated with any sponsor andservices only the Grand Canal Shoppes mortgage loan, which constitutes morethan 5% but less than 10% of the mortgage pool, Midland Loan Services, aDivision of PNC Bank, National Association, as MSC2019-H7 master servicer, constitutes a reporting “servicing functionparticipant” for purposes of Item 1122 of Regulation AB, as specified in theInstruction 3 to Item 1122, but does not constitute a reporting “servicer” forpurposes of Item 1123 of Regulation AB, as specified in the Instruction to Item1123.

 

•   Situs Holdings, LLC is thespecial servicer under the JPMCC 2019-OSB trust and servicing agreement,pursuant to which the Osborn Triangle mortgage loan is serviced. Because SitusHoldings, LLC is not the MSC 2019-L3 specialservicer, is not affiliated with any sponsor and services only the OsbornTriangle mortgage loan, which constitutes less than 5% of the mortgage pool, SitusHoldings, LLC, as JPMCC 2019-OSB special servicer,does not constitute a reporting “servicing function participant” for purposesof Item 1122 of Regulation AB, as specified in the Instruction 3 to Item 1122,and does not constitute a reporting “servicer” for purposes of Item 1123 ofRegulation AB, as specified in the Instruction to Item 1123.

 

•   Rialto Capital Advisors, LLCis the special servicer under the BANK 2019-BNK21 pooling and servicingagreement, pursuant to which the National Anchored Retail Portfolio mortgageloan is serviced. Because Rialto Capital Advisors, LLC is not the MSC 2019-L3 special servicer, is not affiliatedwith any sponsor and services only the National Anchored Retail Portfoliomortgage loan, which constitutes less than 5% of the mortgage pool, RialtoCapital Advisors, LLC, as BANK 2019-BNK21 specialservicer, does not constitute a reporting “servicing function participant” forpurposes of Item 1122 of Regulation AB, as specified in the Instruction 3 toItem 1122, and does not constitute a reporting “servicer” for purposes of Item1123 of Regulation AB, as specified in the Instruction to Item 1123.

 

•  Citibank, N.A., as certificateadministrator under the CF 2019-CF2 pooling and servicing agreement, pursuantto which the GNL Office and Industrial Portfolio mortgage loan, the BushwickAvenue Portfolio mortgage loan and the Hilton Portfolio mortgage loan areserviced, engaged U.S. Bank National Association to perform the relatedcustodial services with respect to such mortgage loans, and U.S. Bank NationalAssociation performed all such custodial services pursuant to the relatedpooling and servicing agreement.

 

In addition, each of the following partiesengaged the services of certain servicing function participants andsub-servicers for the reporting period, as set forth below:

 

•   Wells Fargo Bank, NationalAssociation, as master servicer, engaged the services of (i) KeyBank NationalAssociation as sub-servicer in respect of the entire mortgage pool for thereporting period, and (ii) CoreLogic Commercial Real Estate Services, Inc. andNational Tax Search, LLC, in each case as a servicing function participant inrespect of the entire mortgage pool for the reporting period. 

•   Wells Fargo Bank, NationalAssociation, as master servicer under the BANK 2019-BNK21 pooling and servicingagreement, pursuant to which the National Anchored Retail Portfolio mortgageloan is serviced, engaged the services of CoreLogic Commercial Real EstateServices, Inc. and National Tax Search, LLC, in each case as a servicingfunction participant in respect of the National Anchored Retail Portfoliomortgage loan for the reporting period.

 

 

| **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.**    |
|              | Omitted.                        |
|              |                            |   |

 

| **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 of Financial Condition and Results of Operations.**                         |
|              | Omitted.                                                                                                            |
| **Item 7A.** | **Quantitative and  Qualitative Disclosures About Market Risk.**                                                    |
|              | Omitted.                                                                                                            |
| **Item 8.**  | **Financial Statements and  Supplementary Data.**                                                                   |
|              | Omitted.                                                                                                            |
| **Item 9.**  | **Changes in and  Disagreements With Accountants 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 Corporate Governance.**                                         |
|              | Omitted.                                                                                             |
| **Item 11.** | **Executive Compensation.**                                                                          |
|              | Omitted.                                                                                             |
| **Item 12.** | **Security Ownership of  Certain Beneficial Owners and Management and Related Stockholder Matters.** |
|              | Omitted.                                                                                             |
| **Item 13.** | **Certain Relationships and  Related Transactions, and Director Independence.**                      |
|              | Omitted.                                                                                             |
| **Item 14.** | **Principal Accounting Fees  and Services.**                                                         |
|              | Omitted.                                                                                             |
|              |                                                                                                 |   |

 

**ADDITIONALDISCLOSURE ITEMS FOR REGULATION AB**

 

**Item1112(b) of Regulation AB, Significant Obligor Financial Information.**

 

Notapplicable.

 

**Item1114(b)(2) of Regulation AB, Significant Enhancement Provider FinancialInformation.**

 

Noentity or group of affiliated entities provides any enhancement or othersupport for the certificates as described under Item 1114 (a) of Regulation AB.

 

**Item1115(b) of Regulation AB, Certain Derivatives Instruments (FinancialInformation).**

 

Noentity or group of affiliated entities provides any derivative instruments forthe certificates as described under Item 1115 of Regulation AB.

 

**Item1117 of Regulation AB, Legal Proceedings.**

 

Theregistrant knows of no legal proceeding pending against the sponsors,depositor, trustee, issuing entity, servicer contemplated by Item 1108(a)(3) ofRegulation AB, originator contemplated by Item 1110(b) of Regulation AB, orother party contemplated by Item 1100(d)(1) of Regulation AB, or of which anyproperty of the foregoing is the subject, that is material to security holders,other than as disclosed in the prospectus of the issuing entity filed in a424(b)(2) filing dated November 21, 2019, and other than as follows:

 

Beginningon June 18, 2014, a group of institutional investors filed civil complaints inthe Supreme Court of the State of New York, New York County, and later the U.S.District Court for the Southern District of New York, against Wells Fargo Bank,N.A., (“Wells Fargo Bank”) in its capacity as trustee for certain residentialmortgage backed securities (“RMBS”) trusts. The complaints against Wells FargoBank alleged that the trustee caused losses to investors and asserted causes ofaction based upon, among other things, the trustee's alleged failure to: (i)notify and enforce repurchase obligations of mortgage loan sellers forpurported breaches of representations and warranties, (ii) notify investors ofalleged events of default, and (iii) abide by appropriate standards of carefollowing alleged events of default. Relief sought included money damages in anunspecified amount, reimbursement of expenses, and equitable relief. InNovember 2018, Wells Fargo Bank reached an agreement, in which it denied anywrongdoing, to resolve such claims on a classwide basis for the 271 RMBS trustsat issue. On May 6, 2019, the court entered an order approving the settlementagreement. Separate lawsuits against Wells Fargo Bank making similarallegations filed by certain other institutional investors concerning severalRMBS trusts in New York federal and state court are not covered by the agreement.With respect to such litigations, Wells Fargo Bank believes plaintiffs' claimsare without merit and intends to contest the claims vigorously, but there canbe no assurances as to the outcome of the litigations or the possible impact ofthe litigations on Wells Fargo Bank or the RMBS trusts.

 

In the last several years, U.S. Bank NationalAssociation (“U.S. Bank”) and other large financial institutions have been suedin their capacity as trustee or successor trustee for certain residentialmortgage backed securities ("RMBS") trusts. The complaints, primarilyfiled by investors or investor groups against U.S. Bank and similarinstitutions, allege the trustees caused losses to investors as a result ofalleged failures by the sponsors, mortgage loan sellers and servicers to complywith the governing agreements for these RMBS trusts. Plaintiffs generallyassert causes of action based upon the trustees’ purported failures to enforcerepurchase obligations of mortgage loan sellers for alleged breaches of representationsand warranties, notify securityholders of purported events of default allegedlycaused by breaches of servicing standards by mortgage loan servicers and abideby a heightened standard of care following alleged events of default.Currently, U.S. Bank is a defendant in multiple actions alleging individual orclass action claims against it.

 

U.S. Bank denies liability and believes that it hasperformed its obligations under the RMBS trusts in good faith, that its actionswere not the cause of losses to investors, that it has meritorious defenses,and it has contested and intends to continue contesting the plaintiffs’ claimsvigorously. However, U.S. Bank cannot assure you as to the outcome of any ofthe litigation, or the possible impact of these litigations on the trustee orthe RMBS trusts.

 

On March 9, 2018, a law firm purporting to representfifteen Delaware statutory trusts (the “DSTs”) that issued securities backed bystudent loans (the “Student Loans”) filed a lawsuit in the Delaware Court ofChancery against U.S. Bank National Association (“U.S. Bank”) in its capacitiesas indenture trustee and successor special servicer, and three otherinstitutions in their respective transaction capacities, with respect to theDSTs and the Student Loans. This lawsuit is captioned The National CollegiateStudent Loan Master Trust I, et al. v. U.S. Bank National Association, et al.,C.A. No. 2018-0167-JRS (Del. Ch.). The complaint, which was later amended onJune 15, 2018, alleged that the DSTs have been harmed as a result of purportedmisconduct or omissions by the defendants concerning administration of thetrusts and servicing of the student loans.

 

U.S. Bank believes that it has performed itsobligations as indenture trustee and special servicer in good faith and incompliance in all material respects with the terms of the agreements governingthe DSTs (the “Governing Agreements”), and accordingly that the claims againstit in the lawsuit are without merit.

 

U.S.Bank has filed a motion seeking dismissal of the operative complaint in itsentirety with prejudice pursuant to Chancery Court Rules 12(b)(1) and 12(b)(6)or, in the alternative, U.S. Bank requested a stay of the case while otherprior filed disputes involving the DSTs and the Student Loans are beinglitigated. On November 7, 2018, the Court ruled that the case should be stayedin its entirety pending resolution of the first-filed cases.

 

**Item1119 of Regulation AB, Affiliations and Certain Relationships and RelatedTransactions.**

 

Theinformation regarding this Item has been disclosed in the prospectus of theissuing entity filed in a 424(b)(2) filing dated November 21, 2019.

 

**Item1122 of Regulation AB, Compliance with Applicable Servicing Criteria.**

 

Thereports on assessment of compliance with the servicing criteria forasset-backed securities and the related attestation reports on such assessmentsof compliance are attached hereto under Item 15.

 

Thereport on assessment of compliance with applicable servicing criteria furnishedpursuant to Item 1122 of Regulation AB by Midland Loan Services, a Division ofPNC Bank National Association discloses that a material instance ofnoncompliance occurred, as described below:

 

MaterialInstance of Noncompliance

 

In certain instances, the Schedule AL Files (Item 1125of Regulation AB) were not reported in accordance with the terms specified inthe transaction 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 numbers due to thefollowing: (1) the initial setup files contained information at the assetlevel, and Midland was required to manually compile the information to presentit at the loan level as required by Schedule AL; and (2) certain reportingrequirements required manual processing by Midland, including the use ofvarious data computation formulas, quality control checks and analysis.

 

The identified instances did not involve the servicingof assets included in this securitization.

 

StepsTaken to Remedy the Material Instance of Noncompliance

 

Midland’s Schedule AL reporting process was enhanced inApril of 2019, however, the process remained manual throughout the 2019calendar year and additional errors during such year were identified during therelated audit. Following identification, Midland made staffing changes andadditional improvements to its processes and procedures to support its ScheduleAL reporting obligations and expects to move to an automated solution for thisprocess.

 

**Item1123 of Regulation AB, Servicer Compliance Statement.**

 

Theservicer compliance statements are attached hereto under Item 15.

 

**PART IV**

 

**Item15. Exhibits, Financial Statement Schedules.**

 

(a) Exhibits.

 

(4.1)Poolingand Servicing Agreement, dated as of November 1, 2019, between Morgan StanleyCapital I Inc., as depositor, Wells Fargo Bank, National Association, as masterservicer, LNR Partners, LLC, as general special servicer, Situs Holdings, LLC,as ILPT Industrial Portfolio special servicer, Wells Fargo Bank, NationalAssociation, as certificate administrator, Wilmington Trust, NationalAssociation, as trustee and Pentalpha Surveillance LLC, as operating advisorand as asset representations reviewer (filed as Exhibit 4.1 to the registrant'sCurrent Report on Form 8-K/A filed on January 3, 2020 under SEC File No.333-227446-07 and incorporated by reference herein).

 

(4.2)Poolingand Servicing Agreement, dated as of October 1, 2019, between CCRE Commercial MortgageSecurities, L.P., as depositor, KeyBank National Association, as masterservicer and as a special servicer solely with respect to The Stanwix wholeloan, LNR Partners, LLC, as a special servicer, Citibank, N.A., as trustee,Citibank, N.A., as certificate administrator, paying agent and custodian, ParkBridge Lender Services LLC, as operating advisor, and Park Bridge Lender LLC,as asset representations reviewer, relating to the CF 2019-CF2 securitizationtransaction, pursuant to which the GNL Office and Industrial Portfolio MortgageLoan, the Bushwick Avenue Portfolio Mortgage Loan and the Hilton PortfolioMortgage Loan are serviced (filed as Exhibit 4.2 to the registrant's CurrentReport on Form 8-K filed on November 21, 2019 under SEC File No. 333-227446-07and incorporated by reference herein).

 

(4.3)Poolingand Servicing Agreement, dated as of July 1, 2019, between Morgan StanleyCapital I Inc., as depositor, Midland Loan Services, a Division of PNC Bank,National Association, as master servicer, LNR Partners, LLC, as specialservicer, Wells Fargo Bank, National Association, as certificate administratorand trustee, and Pentalpha Surveillance LLC, as operating advisor and assetrepresentations reviewer, relating to the MSC 2019-H7 securitizationtransaction, pursuant to which the Grand Canal Shoppes Mortgage Loan isserviced (filed as Exhibit 4.3 to the registrant's Current Report on Form 8-Kfiled on November 21, 2019 under SEC File No. 333-227446-07 and incorporated byreference herein).

 

(4.4)Trustand Servicing Agreement, dated as of June 13, 2019, between J.P. Morgan ChaseCommercial Mortgage Securities Corp., as depositor, KeyBank NationalAssociation, as servicer, Situs Holdings, LLC, as special servicer, Wells FargoBank, National Association, as certificate administrator and as trustee, andPark Bridge Lender Services LLC, as operating advisor, relating to the JPMCC2019-OSB securitization transaction, pursuant to which the Osborn TriangleMortgage Loan is serviced (filed as Exhibit 4.4 to the registrant's CurrentReport on Form 8-K filed on November 21, 2019 under SEC File No. 333-227446-07and incorporated by reference herein).

 

(4.5)Poolingand Servicing Agreement, dated as of October 1, 2019, between Banc of AmericaMerrill 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 as asset representationsreviewer, relating to the BANK 2019-BNK21 securitization transaction, pursuantto which the National Anchored Retail Portfolio Mortgage Loan is serviced(filed as Exhibit 4.5 to the registrant's Current Report on Form 8-K filed onNovember 21, 2019 under SEC File No. 333-227446-07 and incorporated byreference herein).

 

(31) Rule13a-14(d)/15d-14(d) Certification.

 

(33)  Reports on assessment ofcompliance with servicing criteria for asset-backed securities.

 

33.1 Wells Fargo Bank,National Association, as Certificate Administrator

 

33.2 Wells FargoBank, National Association, as Custodian

 

33.3 Wells FargoBank, National Association, as Master Servicer

 

33.4 LNR Partners, LLC,as Special Servicer

 

33.5 SitusHoldings, LLC, as Special Servicer (with respect to the ILPT IndustrialPortfolio mortgage loan)

 

33.6 Park BridgeLender Services LLC, as Operating Advisor

 

33.7  KeyBank NationalAssociation, as Primary Servicer

 

33.8 CoreLogicCommercial Real Estate Services, Inc., as Servicing Function Participant

 

33.9 National TaxSearch, LLC, as Servicing Function Participant

 

33.10 KeyBankNational Association, as Master Servicer under the CF 2019-CF2 securitization, pursuantto which the following mortgage loans were serviced by such party: GNL Officeand Industrial Portfolio (from 11/21/19 to 12/31/19), Bushwick Avenue Portfolio(from 11/21/19 to 12/31/19) and Hilton Portfolio (from 11/21/19 to 12/31/19)(see Exhibit 33.7)

 

33.11 Midland LoanServices, a Division of PNC Bank, National Association, as Master Servicerunder the MSC 2019-H7 securitization, pursuant to which the following mortgageloans were serviced by such party: Grand Canal Shoppes (from 11/21/19 to12/31/19)

 

33.12 KeyBankNational Association, as Master Servicer under the JPMCC 2019-OSBsecuritization, pursuant to which the following mortgage loans were serviced bysuch party: Osborn Triangle (from 11/21/19 to 12/31/19) (see Exhibit 33.7)

 

33.13 Wells FargoBank, National Association, as Master Servicer under the BANK 2019-BNK21securitization, pursuant to which the following mortgage loans were serviced bysuch party: National Anchored Retail Portfolio (from 11/21/19 to 12/31/19) (seeExhibit 33.3)

 

33.14 CoreLogicCommercial Real Estate Services, Inc., as Servicing Function Participant underthe BANK 2019-BNK21 securitization, pursuant to which the following mortgageloans were serviced by such party: National Anchored Retail Portfolio (from11/21/19 to 12/31/19) (see Exhibit 33.8)

 

33.15 National TaxSearch, LLC, as Servicing Function Participant under the BANK 2019-BNK21securitization, pursuant to which the following mortgage loans were serviced bysuch party: National Anchored Retail Portfolio (from 11/21/19 to 12/31/19) (seeExhibit 33.9)

 

33.16 LNR Partners,LLC, as Special Servicer under the CF 2019-CF2 securitization, pursuant towhich the following mortgage loans were serviced by such party: GNL Office andIndustrial Portfolio (from 11/21/19 to 12/31/19), Bushwick Avenue Portfolio(from 11/21/19 to 12/31/19) and Hilton Portfolio (from 11/21/19 to 12/31/19)(see Exhibit 33.4)

 

33.17 LNR Partners,LLC, as Special Servicer under the MSC 2019-H7 securitization, pursuant towhich the following mortgage loans were serviced by such party: Grand CanalShoppes (from 11/21/19 to 12/31/19) (see Exhibit 33.4)

 

33.18 U.S. BankNational Association, as Custodian under the CF 2019-CF2 securitization,pursuant to which the following mortgage loans were serviced by such party: GNLOffice and Industrial Portfolio (from 11/21/19 to 12/31/19), Bushwick AvenuePortfolio (from 11/21/19 to 12/31/19) and Hilton Portfolio (from 11/21/19 to12/31/19)

 

33.19  Wells Fargo Bank,National Association, as Custodian under the MSC 2019-H7 securitization,pursuant to which the following mortgage loans were serviced by such party:Grand Canal Shoppes (from 11/21/19 to 12/31/19) (see Exhibit 33.2)

 

33.20 Wells FargoBank, National Association, as Custodian under the JPMCC 2019-OSBsecuritization, pursuant to which the following mortgage loans were serviced bysuch party: Osborn Triangle (from 11/21/19 to 12/31/19) (see Exhibit 33.2)

 

33.21 Wells FargoBank, National Association, as Custodian under the BANK 2019-BNK21securitization, pursuant to which the following mortgage loans were serviced bysuch party: National Anchored Retail Portfolio (from 11/21/19 to 12/31/19) (seeExhibit 33.2)

 

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

 

34.1  Wells Fargo Bank,National Association, as Certificate Administrator

 

34.2 Wells FargoBank, National Association, as Custodian

 

34.3 Wells FargoBank, National Association, as Master Servicer

 

34.4 LNR Partners,LLC, as Special Servicer

 

34.5 SitusHoldings, LLC, as Special Servicer (with respect to the ILPT IndustrialPortfolio mortgage loan)

 

34.6 Park BridgeLender Services LLC, as Operating Advisor

 

34.7 KeyBankNational Association, as Primary Servicer

 

34.8 CoreLogicCommercial Real Estate Services, Inc., as Servicing Function Participant

 

34.9 National TaxSearch, LLC, as Servicing Function Participant

 

34.10 KeyBankNational Association, as Master Servicer under the CF 2019-CF2 securitization,pursuant to which the following mortgage loans were serviced by such party: GNLOffice and Industrial Portfolio (from 11/21/19 to 12/31/19), Bushwick AvenuePortfolio (from 11/21/19 to 12/31/19) and Hilton Portfolio (from 11/21/19 to12/31/19) (see Exhibit 34.7)

 

34.11  Midland LoanServices, a Division of PNC Bank, National Association, as Master Servicerunder the MSC 2019-H7 securitization, pursuant to which the following mortgageloans were serviced by such party: Grand Canal Shoppes (from 11/21/19 to12/31/19)

 

34.12 KeyBankNational Association, as Master Servicer under the JPMCC 2019-OSBsecuritization, pursuant to which the following mortgage loans were serviced bysuch party: Osborn Triangle (from 11/21/19 to 12/31/19) (see Exhibit 34.7)

 

34.13 Wells FargoBank, National Association, as Master Servicer under the BANK 2019-BNK21securitization, pursuant to which the following mortgage loans were serviced bysuch party: National Anchored Retail Portfolio (from 11/21/19 to 12/31/19) (seeExhibit 34.3)

 

34.14 CoreLogicCommercial Real Estate Services, Inc., as Servicing Function Participant underthe BANK 2019-BNK21 securitization, pursuant to which the following mortgageloans were serviced by such party: National Anchored Retail Portfolio (from11/21/19 to 12/31/19) (see Exhibit 34.8)

 

34.15 National TaxSearch, LLC, as Servicing Function Participant under the BANK 2019-BNK21securitization, pursuant to which the following mortgage loans were serviced bysuch party: National Anchored Retail Portfolio (from 11/21/19 to 12/31/19) (seeExhibit 34.9)

 

34.16 LNR Partners,LLC, as Special Servicer under the CF 2019-CF2 securitization, pursuant towhich the following mortgage loans were serviced by such party: GNL Office andIndustrial Portfolio (from 11/21/19 to 12/31/19), Bushwick Avenue Portfolio(from 11/21/19 to 12/31/19) and Hilton Portfolio (from 11/21/19 to 12/31/19)(see Exhibit 34.4)

 

34.17  LNR Partners, LLC, asSpecial Servicer under the MSC 2019-H7 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Grand Canal Shoppes (from11/21/19 to 12/31/19) (see Exhibit 34.4)

 

34.18 U.S. BankNational Association, as Custodian under the CF 2019-CF2 securitization,pursuant to which the following mortgage loans were serviced by such party: GNLOffice and Industrial Portfolio (from 11/21/19 to 12/31/19), Bushwick AvenuePortfolio (from 11/21/19 to 12/31/19) and Hilton Portfolio (from 11/21/19 to12/31/19)

 

34.19 Wells FargoBank, National Association, as Custodian under the MSC 2019-H7 securitization,pursuant to which the following mortgage loans were serviced by such party:Grand Canal Shoppes (from 11/21/19 to 12/31/19) (see Exhibit 34.2)

 

34.20 Wells FargoBank, National Association, as Custodian under the JPMCC 2019-OSB securitization,pursuant to which the following mortgage loans were serviced by such party:Osborn Triangle (from 11/21/19 to 12/31/19) (see Exhibit 34.2)

 

34.21 Wells FargoBank, National Association, as Custodian under the BANK 2019-BNK21securitization, pursuant to which the following mortgage loans were serviced bysuch party: National Anchored Retail Portfolio (from 11/21/19 to 12/31/19) (seeExhibit 34.2)

 

(35). Servicer compliance statement.

 

35.1 Wells FargoBank, National Association, as Certificate Administrator

 

35.2 Wells FargoBank, National Association, as Custodian

 

35.3 Wells FargoBank, National Association, as Master Servicer

 

35.4 LNR Partners,LLC, as Special Servicer

 

35.5  Situs Holdings, LLC,as Special Servicer (with respect to the ILPT Industrial Portfolio mortgageloan)

 

35.6 KeyBankNational Association, as Primary Servicer

 

35.7  KeyBank NationalAssociation, as Master Servicer under the CF 2019-CF2 securitization, pursuantto which the following mortgage loans were serviced by such party: GNL Officeand Industrial Portfolio (from 11/21/19 to 12/31/19), Bushwick Avenue Portfolio(from 11/21/19 to 12/31/19) and Hilton Portfolio (from 11/21/19 to 12/31/19)(see Exhibit 35.6)

 

35.8 KeyBankNational Association, as Master Servicer under the JPMCC 2019-OSBsecuritization, pursuant to which the following mortgage loans were serviced bysuch party: Osborn Triangle (from 11/21/19 to 12/31/19) (see Exhibit 35.6)

 

35.9 Wells FargoBank, National Association, as Master Servicer under the BANK 2019-BNK21securitization, pursuant to which the following mortgage loans were serviced bysuch party: National Anchored Retail Portfolio (from 11/21/19 to 12/31/19) (seeExhibit 35.3)

 

35.10 LNR Partners,LLC, as Special Servicer under the CF 2019-CF2 securitization, pursuant towhich the following mortgage loans were serviced by such party: GNL Office andIndustrial Portfolio (from 11/21/19 to 12/31/19), Bushwick Avenue Portfolio(from 11/21/19 to 12/31/19) and Hilton Portfolio (from 11/21/19 to 12/31/19)(see Exhibit 35.4)

 

35.11 LNR Partners,LLC, as Special Servicer under the MSC 2019-H7 securitization, pursuant towhich the following mortgage loans were serviced by such party: Grand CanalShoppes (from 11/21/19 to 12/31/19) (see Exhibit 35.4)

 

35.12 U.S. BankNational Association, as Custodian under the CF 2019-CF2 securitization,pursuant to which the following mortgage loans were serviced by such party: GNLOffice and Industrial Portfolio (from 11/21/19 to 12/31/19), Bushwick Avenue Portfolio(from 11/21/19 to 12/31/19) and Hilton Portfolio (from 11/21/19 to 12/31/19)

 

35.13 Wells FargoBank, National Association, as Custodian under the MSC 2019-H7 securitization,pursuant to which the following mortgage loans were serviced by such party:Grand Canal Shoppes (from 11/21/19 to 12/31/19) (see Exhibit 35.2)

 

35.14  Wells Fargo Bank,National Association, as Custodian under the JPMCC 2019-OSB securitization,pursuant to which the following mortgage loans were serviced by such party:Osborn Triangle (from 11/21/19 to 12/31/19) (see Exhibit 35.2)

 

35.15 Wells FargoBank, National Association, as Custodian under the BANK 2019-BNK21 securitization,pursuant to which the following mortgage loans were serviced by such party:National Anchored Retail Portfolio (from 11/21/19 to 12/31/19) (see Exhibit35.2)

 

(99.1)MortgageLoan Purchase Agreement, dated November 8, 2019, between Morgan Stanley CapitalI Inc. and Morgan Stanley Mortgage Capital Holdings LLC (filed as Exhibit 99.1to the registrant's Current Report on Form 8-K filed on November 21, 2019 underSEC File No. 333-227446-07 and incorporated by reference herein).

 

(99.2)MortgageLoan Purchase Agreement, dated November 8, 2019, between Morgan Stanley CapitalI Inc. and Starwood Mortgage Capital LLC (filed as Exhibit 99.2 to theregistrant's Current Report on Form 8-K filed on November 21, 2019 under SECFile No. 333-227446-07 and incorporated by reference herein).

 

(99.3)MortgageLoan Purchase Agreement, dated November 8, 2019, between Morgan Stanley CapitalI Inc. and Argentic Real Estate Finance LLC (filed as Exhibit 99.3 to theregistrant's Current Report on Form 8-K filed on November 21, 2019 under SECFile No. 333-227446-07 and incorporated by reference herein).

 

(99.4)Mortgage Loan Purchase Agreement, dated November 8, 2019, between MorganStanley Capital I Inc. and KeyBank National Association (filed as Exhibit 99.4to the registrant's Current Report on Form 8-K filed on November 21, 2019 underSEC File No. 333-227446-07 and incorporated by reference herein).

 

(99.5)MortgageLoan Purchase Agreement, dated November 8, 2019, between Morgan Stanley CapitalI Inc. and Cantor Commercial Real Estate Lending, L.P. (filed as Exhibit 99.5to the registrant's Current Report on Form 8-K filed on November 21, 2019 underSEC File No. 333-227446-07 and incorporated by reference herein).

 

(99.6)AgreementBetween Note Holders, dated as of September 12, 2019, by and between KeyBankNational Association, as initial note A-1 holder, KeyBank National Association,as initial note A-2 holder, initial note A-3 holder, initial note A-4 holder,initial note A-5 holder, initial note A-6 holder, initial note A-7 holder andinitial note A-8 holder, relating to the GNL Office and Industrial Portfolioloan combination (filed as Exhibit 99.6 to the registrant's Current Report onForm 8-K filed on November 21, 2019 under SEC File No. 333-227446-07 andincorporated by reference herein).

 

(99.7)AgreementBetween Note Holders, dated as of October 24, 2019, by and between Bank ofAmerica, N.A. and KeyBank National Association, relating to the ParklawnBuilding loan combination (filed as Exhibit 99.7 to the registrant's CurrentReport on Form 8-K filed on November 21, 2019 under SEC File No. 333-227446-07and incorporated by reference herein).

 

(99.8)Co-LenderAgreement, dated as of September 9, 2019, by and between SPREF WH III LLC, asinitial note A-1 holder, SPREF WH III LLC, as initial note A-2 holder, SPREF WHIII LLC, as initial note A-3 holder, SPREF WH III LLC, as initial note A-4 holder,SPREF WH III LLC, as initial note A-5 holder, and SPREF WH III LLC, as initialnote A-6 holder, relating to the East Village Multifamily Portfolio loancombination (filed as Exhibit 99.8 to the registrant's Current Report on Form8-K filed on November 21, 2019 under SEC File No. 333-227446-07 andincorporated by reference herein).

 

(99.9)AgreementBetween Note Holders, 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, relating to the Grand Canal Shoppes loan combination (filed asExhibit 99.9 to the registrant's Current Report on Form 8-K filed on November21, 2019 under SEC File No. 333-227446-07 and incorporated by referenceherein).

 

(99.10) IntercreditorAgreement, dated as of November 15, 2019, by and between Morgan Stanley Bank,N.A., as note A-1 holder and note A-2 holder, Morgan Stanley Mortgage CapitalHoldings LLC, as note B-1-A holder, note B-1-B holder, note B-1-C holder andnote B-1-D holder, Bank of America, National Association, as note A-3 holder,note A-4 holder, note B-2-A holder, note B-2-B holder, note B-2-C holder andnote B-2-D holder, and UBS AG, New York Branch, as note A-5 holder, note A-6holder, note A-7 holder, note A-8 holder, note B-3-A holder, note B-3-B holder,note B-3-C holder and note B-3-D holder, relating to the ILPT IndustrialPortfolio loan combination (filed as Exhibit 99.10 to the registrant's CurrentReport on Form 8-K filed on November 21, 2019 under SEC File No. 333-227446-07and incorporated by reference herein).

 

(99.11)AgreementBetween Note Holders, dated as of November 21, 2019, by and between ArgenticReal Estate Finance LLC, as initial note A-1 holder, Argentic Real EstateFinance LLC, as initial note A-2 holder, Argentic Real Estate Finance LLC, asinitial note A-3 holder, and Argentic Real Estate Finance LLC, as initial noteA-4 holder, relating to the Royal Palm Place loan combination (filed as Exhibit99.11 to the registrant's Current Report on Form 8-K filed on November 21, 2019under SEC File No. 333-227446-07 and incorporated by reference herein).

 

(99.12)Co-LenderAgreement, dated as of October 25, 2019, by and between Starwood MortgageCapital LLC, as initial note A-1 holder, Starwood Mortgage Capital LLC, asinitial note A-2 holder, Starwood Mortgage Capital LLC, as initial note A-3holder, Starwood Mortgage Capital LLC, as initial note A-4 holder, StarwoodMortgage Capital LLC, as initial note A-5 holder, Starwood Mortgage CapitalLLC, as initial note A-6 holder, and Starwood Mortgage Capital LLC, as initialnote A-7 holder, relating to the Wells Fargo Place loan combination (filed asExhibit 99.12 to the registrant's Current Report on Form 8-K filed on November21, 2019 under SEC File No. 333-227446-07 and incorporated by referenceherein).

 

(99.13)Co-LenderAgreement, dated as of August 9, 2019, by and between Starwood Mortgage CapitalLLC, as initial note A-1 holder, Starwood Mortgage Capital LLC, as initial noteA-2 holder, Starwood Mortgage Capital LLC, as initial note A-3 holder, StarwoodMortgage Capital LLC, as initial note A-4 holder, and Starwood Mortgage CapitalLLC, as initial note A-5 holder, relating to the Bushwick Avenue Portfolio loancombination (filed as Exhibit 99.13 to the registrant's Current Report on Form8-K filed on November 21, 2019 under SEC File No. 333-227446-07 andincorporated by reference herein).

 

(99.14)Co-LenderAgreement, dated as of June 13, 2019, by and between JPMorgan Chase Bank,National Association and JPMorgan Chase Bank, National Association, relating tothe Osborn Triangle loan combination (filed as Exhibit 99.14 to theregistrant's Current Report on Form 8-K filed on November 21, 2019 under SECFile No. 333-227446-07 and incorporated by reference herein).

 

(99.15)Co-Lender Agreement, dated as of October 4, 2019, by and between SPREF WH IIILLC, as initial note A-1 holder and SPREF WH III LLC, as initial note A-2holder, relating to the American Metro Center loan combination (filed asExhibit 99.15 to the registrant's Current Report on Form 8-K filed on November21, 2019 under SEC File No. 333-227446-07 and incorporated by referenceherein).

 

(99.16)Co-LenderAgreement, dated as of August 9, 2019, by and between Starwood Mortgage CapitalLLC, as initial note A-1 holder, Starwood Mortgage Capital LLC, as initial noteA-2 holder, and Starwood Mortgage Capital LLC, as initial note A-3 holder,relating to the Hilton Portfolio loan combination (filed as Exhibit 99.16 tothe registrant's Current Report on Form 8-K filed on November 21, 2019 underSEC File No. 333-227446-07 and incorporated by reference herein).

 

(99.17)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, relating tothe National Anchored Retail Portfolio loan combination (filed as Exhibit 99.17to the registrant's Current Report on Form 8-K filed on November 21, 2019 underSEC File No. 333-227446-07 and incorporated by reference herein).

 

(99.18)PrimaryServicing Agreement, dated as of November 1, 2019, by and between Wells FargoBank, National Association, as master servicer, and KeyBank NationalAssociation, as primary servicer (filed as Exhibit 99.18 to the registrant'sCurrent Report on Form 8-K filed on November 21, 2019 under SEC File No.333-227446-07 and incorporated by reference herein).

 

(b)See (a) above.

 

(c) NotApplicable.

** **

**SIGNATURES**

 

Pursuantto the requirements of Section 13 or 15(d) of the Securities Exchange Act of1934, the registrant has duly caused this report to be signed on its behalf bythe undersigned, thereunto duly authorized.

 

MorganStanley Capital I Inc.

(Depositor)

 

By:/s/ Jane Lam

JaneLam, Director and President

(seniorofficer in charge of securitization of the depositor)

 

Date: March 30, 2020