(logo) CWCapital

ASSET MANAGEMENT

 

 

**Original Issuance Date:February 25, 2020**

**Reissuance Date withRespect to Management’s Assertion 3:  March 23, 2020**

** **

 

**Management's Assertion on Compliance with Regulation ABCriteria**

 

 

Re:         Assessment of Compliance forservices provided pursuant to the Pooling and Servicing Agreements entered intoby CWCapital Asset Management LLC beginning January 1, 2006 for the 12 monthperiod ended December 31, 2019.

 

1.            CWCapitalAsset Management LLC ("CWCAM") is responsible for assessingcompliance with applicable servicing criteria set forth in Item 1122 (d) ofRegulation AB of the Securities and Exchange Commission for the securitizationsissued beginning January 1, 2006, as listed on Appendix A ("ApplicableServicing Criteria").

 

2.            CWCAM hasassessed its compliance with the applicable servicing criteria as of December31, 2019 and for the period from January 1, 2019 to December 31, 2019 (the"Reporting Period"). In making this assessment, management used thecriteria set forth by the Securities and Exchange Commission in paragraph (d)of Item 1122 of Regulation AB, excluding the criteria set forth in Item 1122(d)(l)(iii), (d)(3)(i)(b), (d)(3)(i)(c), (d)(3)(i)(d), (d)(3)(ii), (d)(3)(iii),(d)(3)(iv), (d)(4)(v), (d)(4)(ix), (d)(4)(x), (d)(4)(xi), (d)(4)(xii),(d)(4)(xiii), (d)(4)(xiv), and (d)(4)(xv) of Regulation AB, which CWCAM hasconcluded are not applicable to the activities it performs (collectively, the"Not Applicable Criteria"). With respect to applicable servicingcriteria (d)(l)(ii), (d)(2)(vi), (d)(4)(i), (d)(4)(iii), and (d)(4)(iv), CWCAMhas determined that there were no occurrences of events that would requireCWCAM to perform such activities. The securitizations covered by this reportinclude all securitizations wherein CWCAM is named as the Special Servicer forsecuritizations issued beginning January 1, 2006, as listed in Appendix B (the"Platform").

 

3.            The originalissuance date of the Management’s Assertion on Compliance with Regulation ABCriteria was dated February 25, 2020 which excluded two securitizations onAppendix B for which CWCAM was the Special Servicer.  CWCAM is reissuingthe Management’s Assertion on Compliance with Regulation AB Criteria with anamended Appendix B, dated March 23, 2020, which has added the followingsecuritizations: MSBAM 2014-C19 and MSBAM2015-C21.             

 

4.            Based onsuch assessment, management believes, as of December 31, 2019 and for the ReportingPeriod, the following: 

1)      CWCAM has determined that the NotApplicable Criteria are in fact not applicable to the activities it performswith respect to the Platform.

2)      CWCAM has complied in all materialrespects with the applicable servicing criteria set forth in Item 1122.

 

5.            CohnReznickLLP, an independent registered public accounting firm, has issued anattestation report on CWCAM’s compliance with the Applicable Servicing Criteriaas of December 31, 2019 and for the Reporting Period.  CohnReznick LLP’soriginal attestation report - Report of Independent Registered PublicAccounting Firm was dated February 25, 2020.  CohnReznick LLP reissuanceattestation report - Report of Independent Registered Public Accounting firm isdual dated February 25, 2020, except for Management Assertion 3 which is datedMarch 23, 2020.

 

 

CWCapital Asset Management LLC

 

 

By: /s/ James P. Shevlin

James P. Shevlin

President/Chief OperatingOfficer

Date: March 23, 2020

 

 

By: /s/ Bruce Cunningham

Bruce Cunningham

Chief Financial Officer

Date: March 23, 2020

 

 

Appendix A

 

|             | *Relevant Servicing Criteria*                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |                                                                                                                                                   |
|------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------|
| **Reference**    | **Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | **CWCAM**                                                                                                                                              |
|             | **General Servicing Considerations**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |                                                                                                                                                   |
| 1122(d)(l)(i)    | Policies and procedures are  instituted to monitor any performance or other triggers and events of default  in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | Applicable                                                                                                                                             |
| 1122(d)(l)(ii)   | If any material servicing  activities are outsourced to third parties, policies and procedures are  instituted to monitor the third party's performance and compliance with such  servicing activities.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | Applicable                                                                                                                                             |
| 1122(d)(l)(iii)  | Any requirements in the  transaction agreements to maintain a back-up servicer for the mortgage loans  are maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | Not Applicable                                                                                                                                         |
| 1122(d)(l)(iv)   | A fidelity bond and errors  and omissions policy is in effect on the party participating in the servicing  function throughout the reporting period in the amount of coverage required by  and otherwise in accordance with the terms of the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                  | Applicable                                                                                                                                             |
| 1122(d)(l)(v)    | Aggregation of information,  as applicable, is mathematically accurate and the information conveyed  accurately reflects the information.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | Applicable                                                                                                                                             |
|             | **Cash Collection and Administration**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                                                                                                                                   |
| 1122(d)(2)(i)    | Payments on mortgage loans  are deposited into the appropriate custodial bank accounts and related bank  clearing accounts no more than two business days following receipt, or such  other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | Applicable                                                                                                                                             |
| 1122(d)(2)(ii)   | Disbursements made via wire  transfer on behalf of an obligor or to an investor are made only by  authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | Applicable                                                                                                                                             |
| 1122(d)(2)(iii)  | Advances of funds or  guarantees regarding collections, cash flows or distributions, and any  interest or other fees charged for such advances, are made, reviewed and  approved as specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | Applicable                                                                                                                                             |
| 1122(d)(2)(iv)   | The related accounts for the  transaction, such as cash reserve accounts or accounts established as a form  of overcollateralization, are separately maintained (e.g., with respect to  commingling of cash) as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                              | Applicable                                                                                                                                             |
| 1122(d)(2)(v)    | Each custodial account is  maintained at a federally insured depository institution as set forth in the  transaction agreements. For purposes of this criterion, "federally  insured depository institution" with respect to a foreign financial  institution means a foreign financial institution that meets the requirements  of Rule 13k-l(b)(l) of the Securities Exchange Act.                                                                                                                                                                                                                                                                                                                        | Applicable                                                                                                                                             |
| 1122(d)(2)(vi)   | Unissued checks are  safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | Applicable                                                                                                                                             |
| 1122(d)(2)(vii)  | Reconciliations are prepared  on a monthly basis for all asset-backed securities related bank accounts,  including custodial accounts and related bank clearing accounts. These  reconciliations (A) are mathematically accurate; (B) are prepared within 30  calendar days after the bank statement cutoff date, or such other number of  days specified in the transaction agreements; (C) are reviewed and approved  by someone other than the person who prepared the reconciliation; and (D)  contain explanations for reconciling items. These reconciling items are  resolved within 90 calendar days of their original identification, or such  other number of days specified in the transaction agreements. | Applicable                                                                                                                                             |
|             | **Investor Remittances and Reporting**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                                                                                                                                   |
| 1122(d)(3)(i)    | Reports to investors,  including those to be filed with the Commission, are maintained in accordance  with the transaction agreements and applicable Commission requirements.  Specifically, such reports (A) are prepared in accordance with timeframes and  other terms set forth in the transaction agreements; (B) provide information  calculated in accordance with the terms specified in the transaction  agreements; (C) are filed with the Commission as required by its rules and  regulations; and (D) agree with investors' or the trustee's records as to the  total unpaid principal balance and number of mortgage loans serviced by the  Servicer.                                                   | (A)     Applicable

(B)     Not Applicable

(C)     Not Applicable

(D)     Not Applicable |
| 1122(d)(3)(ii)   | Amounts due to investors are  allocated and remitted in accordance with timeframes, distribution priority  and other terms set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | Not Applicable                                                                                                                                         |
| 1122(d)(3)(iii)  | Disbursements made to an  investor are posted within two business days to the Servicer's investor  records, or such other number of days specified in the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | Not Applicable                                                                                                                                         |
| 1122(d)(3)(iv)   | Amounts remitted to  investors per the investor reports agree with cancelled checks, or other form  of payment, or custodial bank statements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | Not Applicable                                                                                                                                         |
|             | **Pool Asset Administration**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |                                                                                                                                                   |
| 1122(d)(4)(i)    | Collateral or security on  mortgage loans is maintained as required by the transaction agreements or  related mortgage loan documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | Applicable                                                                                                                                             |
| 1122(d)(4)(ii)   | Mortgage loan and related  documents are safeguarded as required by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | Applicable                                                                                                                                             |
| 1122(d)(4)(iii)  | Any additions, removals or  substitutions to the asset pool are made, reviewed and approved in accordance  with any conditions or requirements in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | Applicable                                                                                                                                             |
| 1122(d)(4)(iv)   | Payments on mortgage loans,  including any payoffs, made in accordance with the related mortgage loan  documents are posted to the Servicer's obligor records maintained no more  than two business days after receipt, or such other number of days specified  in the transaction agreements, and allocated to principal, interest or other  items (e.g., escrow) in accordance with the related mortgage loan documents.                                                                                                                                                                                                                                                                                            | Applicable                                                                                                                                             |
| 1122(d)(4)(v)    | The Servicer's records  regarding the mortgage loans agree with the Servicer's records with respect  to an obligor's unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | Not Applicable                                                                                                                                         |
| 1122(d)(4)(vi)   | Changes with respect to the  terms or status of an obligor's mortgage loans (e.g., loan modifications or  re-agings) are made, reviewed and approved by authorized personnel in  accordance with the transaction agreements and related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                         | Applicable                                                                                                                                             |
| 1122(d)(4)(vii)  | Loss mitigation or recovery  actions (e.g., forbearance plans, modifications and deeds in lieu of  foreclosure, foreclosures and repossessions, as applicable) are initiated,  conducted and concluded in accordance with the timeframes or other  requirements established by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                            | Applicable                                                                                                                                             |
| 1122(d)(4)(viii) | Records documenting  collection efforts are maintained during the period a mortgage loan is  delinquent in accordance with the transaction agreements. Such records are  maintained on at least a monthly basis, or such other period specified in the  transaction agreements, and describe the entity's activities in monitoring  delinquent mortgage loans including, for example, phone calls, letters and  payment rescheduling plans in cases where delinquency is deemed temporary (  e.g., illness or unemployment).                                                                                                                                                                                          | Applicable                                                                                                                                             |
| 1122(d)(4)(ix)   | Adjustments to interest  rates or rates of return for mortgage loans with variable rates are computed  based on the related mortgage loan documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | Not Applicable                                                                                                                                         |
| 1122(d)(4)(x)    | Regarding any funds held in  trust for an obligor (such as escrow accounts): (A) such funds are analyzed,  in accordance with the obligor's mortgage loan documents, on at least an  annual basis, or such other period specified in the transaction agreements;  (8) interest on such funds is paid, or credited, to obligors in accordance with  applicable mortgage loan documents and state laws; and (C) such funds are  returned to the obligor within 30 calendar days of full repayment of the  related mortgage loans, or such other number of days specified in the  transaction agreements.                                                                                                                | Not Applicable                                                                                                                                         |
| 1122(d)(4)(xi)   | Payments made on behalf of  an obligor (such as tax or insurance payments) are made on or before the  related penalty or expiration dates, as indicated on the appropriate bills or  notices for such payments, provided that such support has been received by  the servicer at least 30 calendar days prior to these dates, or such other  number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                  | Not Applicable                                                                                                                                         |
| 1122(d)(4)(xii)  | Any late payment penalties  in connection with any payment to be made on behalf of an obligor are paid  from the servicer's funds and not charged to the obligor, unless the late  payment was due to the obligor's error or omission.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | Not Applicable                                                                                                                                         |
| 1122(d)(4)(xiii) | Disbursements made on behalf  of an obligor are posted within two business days to the obligor's records  maintained by the servicer, or such other number of days specified in the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | Not Applicable                                                                                                                                         |
| 1122(d)(4)(xiv)  | Delinquencies, charge-offs  and uncollectible accounts are recognized and recorded in accordance with the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | Not Applicable                                                                                                                                         |
| 1122(d)(4)(xv)   | Any external enhancement or  other support, identified in Item 1114(a)(1) through (3) or Item 1115 of  Regulation AB, is maintained as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | Not Applicable                                                                                                                                         |
|             |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |                                                                                                                                                   |   |   |

 

 

Appendix B (Amended as of March 23, 2020)

 

 

| AVENTURA 2018-AVM       | CSAIL 2017-CX10        | MLCFC 2007-5          |
|-------------------------|------------------------|-----------------------|
| BACM 2007-1             | CSMC 2008-C1           | MLMT 2006-C1          |
| BACM 2007-2             | CSMC 2014-USA          | MSBAM 2015-C27        |
| BACM 2007-5             | DBUBS 2011-LC3         | MSC 2016-UBS11        |
| BACM 2008-1             | DCOT 2019-MTC          | MSCI 2016-UBS9        |
| BANCORP 2019-CRE6       | GRACE 2014-GRCE        | MSCI 2019-PLND        |
| BANK 2017-BNK5          | GSMC 2019 BOCA         | UBS 2012-C2           |
| BHMS 2018-ATLS          | GSMS 2012-GCJ7         | UBS 2017-Cl           |
| BMARK2018-B2            | GSMS 2014-GC22         | WBCMT 2006-C23        |
| BENCHMARK 2018-B4       | GSMSC 2014-GC26        | WBCMT 2006-C25        |
| BENCHMARK 2018-B8       | GSMS 2015-GC32         | WBCMT 2006-C26        |
| BENCHMARK 2019-B13      | GSMS 2018-RIVR         | WBCMT 2006-C28        |
| BX 2019-ATL             | HILT 2016-HHV          | WBCMT 2007-C30        |
| CF 2019-MFl             | Hudson Yards 2019-55HY | WBCMT 2007-C33        |
| CD 2007-CD4             | JPMBB 2014-C23         | WBCMT 2007-C34        |
| CFCRE 2016-C3           | JPMBB 2015-C33         | WBHT 2019-WBM         |
| CGCMT 2016-P4           | JPMC 2006-CIBC17       | WFCM 2016-C35         |
| CGCMT 2016-P6           | JPMC 2006-LDP9         | WFCM 2016-NXS6        |
| CLNY 2019-IKPR          | JPMC 2007-CIBC18       | WFCM 2019-JWDR        |
| COBALT 2007-C2          | JPMC 2008-C2           | WFRBS 2013-C11        |
| COBALT 2007-C3          | JPMC 2018-LAQ          | WFRBS 2013-Cl5        |
| COMM 2013 –CCRE11 | JPMCC 2013-C16         | WFRBS 2013-UBSl       |
| COMM 2015-CCRE23        | JPMCC 2015-FL7         | WFRBS 2014-C21        |
| COMM 2015-CCRE25        | JPMCC 2016-H2FL        | WFRBS 2014-C22        |
| COMM 2015-CCRE26        | JPMCC 2017-JP7         | WFRBS 2014-C23        |
| COMM 2016-CCRE28        | JPMCC 2019-ICON UES    | WFRBS 2014-C25        |
| COMM 2016-DC2           | JPMDB 2017-C5          |                  |
| CPTS 2019-CPT           | LBUBS 2006-C4          |  MSBAM 2014-C19* |
| CSFB 2006-TFL2          | MBR 2018-MBR           |  MSBAM 2015-C21* |
| CSFB 2007-C4            | MLCFC 2006-1           |                  |

 

 * Additional securitizationsadded and included in Appendix B as amended, dated March 23, 2020 in accordancewith Assertion 3.