**UNITED STATESSECURITIES AND EXCHANGE COMMISSION**

**Washington, D.C. 20549**

**FORM 10-K**

(Mark One)

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

**For the fiscal year ended December 31, 2021or**

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

**For the transition period from _____ to _____Commission file number of the issuing entity: 333-226943-05**

**Central Index Key Number of the issuing entity:0001792157**

**COMM 2019-GC44 Mortgage Trust**

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

** **

**Central Index Key Number of the depositor: 0001013454**

**Deutsche Mortgage & AssetReceiving Corporation**

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

** **

**Central Index Key Number of the sponsor: 0001541294**

**German American Capital Corporation**

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

** **

**Central Index Key Number of the sponsor: 0001541502**

**Goldman Sachs Mortgage Company**

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

** **

**Central Index Key Number of the sponsor: 0001701238**

**Citi Real Estate Funding Inc.**

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

** **

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

**the issuing entity)** | **38-4129062**

**38-4129063**

**38-4129064**

**38-7235632**

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

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

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

**as Certificate Administrator**

**9062 Old Annapolis Road**

**Columbia, MD**

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

**21045**

**(Zip Code)**

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

**(212) 250-2500**

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

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

 

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

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

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

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

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

Not applicable.

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

Not applicable.

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

Large acceleratedfiler        o                                                                                                       Acceleratedfiler                                     o

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

                                                                                                                                                       Emerging growthcompany                    o

If an emerging growth company, indicate by check mark if theregistrant has elected not to use the extended transition period for complying withany new or revised financial accounting standards provided pursuant to Section13(a) of the Exchange Act.  o

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

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

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

Not applicable.

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

Not applicable.

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

Not applicable.

**DOCUMENTS INCORPORATED BY REFERENCE**

** **

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

Not applicable.

 

** **

**EXPLANATORY NOTES**

The 180 Water Mortgage Loan, The Shoppes atBlackstone Valley Mortgage Loan, the Elston Retail Collection Mortgage Loan,the PCI Pharma Portfolio Mortgage Loan, the Broadcasting Square Mortgage Loanand the Cobb Place Mortgage Loan, which constituted approximately 6.1%, 5.4%,3.9%, 3.9%, 3.1% and 2.4%, respectively, of the asset pool of the issuingentity as of its cut-off date, are each an asset of the issuing entity and areeach part of a loan combination that includes (a) with respect to the 180 WaterMortgage Loan, two other *pari passu* loans, which are not assets of theissuing entity, (b) with respect to The Shoppes at Blackstone Valley MortgageLoan, eight other *pari passu* loans, which are not assets of the issuingentity, (c) with respect to the Elston Retail Collection Mortgage Loan, oneother *pari passu* loan, which is not an asset of the issuing entity, (d)with respect to the PCI Pharma Portfolio Mortgage Loan, six other *pari passu*loans, which are not assets of the issuing entity, (e) with respect to theBroadcasting Square Mortgage Loan, one other *pari passu* loan, which isnot an asset of the issuing entity and (f) with respect to the Cobb PlaceMortgage Loan, one other *pari passu* loan, which is not an asset of theissuing entity. These loan combinations, including the 180 Water Mortgage Loan,The Shoppes at Blackstone Valley Mortgage Loan, the Elston Retail CollectionMortgage Loan, the PCI Pharma Portfolio Mortgage Loan, the Broadcasting SquareMortgage Loan and the Cobb Place Mortgage Loan, are being serviced andadministered pursuant to the Pooling and Servicing Agreement, which isincorporated by reference as Exhibit 4.1 to this Annual Report on Form 10-K. 

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the USAA Office Portfolio Mortgage Loan and the MillenniumPark Plaza Mortgage Loan, which constituted approximately 4.4% and 1.5%,respectively, of the asset pool of the issuing entity as of its cut-offdate.  The USAA Office Portfolio Mortgage Loan and the Millennium ParkPlaza Mortgage Loan are each an asset of the issuing entity and are each partof a loan combination that includes the USAA Office Portfolio Mortgage Loan orthe Millennium Park Plaza Mortgage Loan and five other *pari passu* loans,each of which are not assets of the issuing entity. A *pari passu* portionof each loan combination was securitized in the Citigroup Commercial MortgageTrust 2019-GC41 transaction, Commission File Number 333-228597-02 (the “CGCMT2019-GC41 Transaction”). These loan combinations, including the USAA OfficePortfolio Mortgage Loan and the Millennium Park Plaza Mortgage Loan, are beingserviced and administered pursuant to the pooling and servicing agreement forthe CGCMT 2019-GC41 Transaction, which is incorporated by reference as Exhibit4.2 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Wind Creek Leased Fee Mortgage Loan, whichconstituted approximately 1.9% of the asset pool of the issuing entity as ofits cut-off date.  The Wind Creek Leased Fee Mortgage Loan is an asset ofthe issuing entity and is part of a loan combination that includes the WindCreek Leased Fee Mortgage Loan and six other *pari passu* loans, which arenot assets of the issuing entity. A *pari passu* portion of the loancombination was securitized in the Benchmark 2019-B13 Mortgage Trusttransaction, Commission File Number 333-226943-04 (the “Benchmark 2019-B13Transaction”). This loan combination, including the Wind Creek Leased FeeMortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the Benchmark 2019-B13 Transaction, which isincorporated by reference as Exhibit 4.3 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Midtown Center Mortgage Loan, whichconstituted approximately 3.2% of the asset pool of the issuing entity as ofits cut-off date.  The Midtown Center Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the MidtownCenter Mortgage Loan, eight other *pari passu* loans and three subordinatecompanion loans, which are not assets of the issuing entity. A *pari passu*portion of the loan combination was securitized in the DC Office Trust 2019-MTCtransaction (the “DCOT 2019-MTC Transaction”). This loan combination,including the Midtown Center Mortgage Loan, is being serviced and administeredpursuant to the trust and servicing agreement for the DCOT 2019-MTCTransaction, which is incorporated by reference as Exhibit 4.4 to this AnnualReport on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on the ExhibitIndex) with respect to the Century Plaza Towers Mortgage Loan, whichconstituted approximately 7.3% of the asset pool of the issuing entity as ofits cut-off date.  The Century Plaza Towers Mortgage Loan is an asset ofthe issuing entity and is part of a loan combination that includes the CenturyPlaza Towers Mortgage Loan, twenty-seven other *pari passu* loans andthree subordinate companion loans, which are not assets of the issuing entity.A *pari passu* portion of the loan combination was securitized in the CPTS2019-CPT Mortgage Trust transaction (the “CPTS 2019-CPT Transaction”).This loan combination, including the Century Plaza Towers Mortgage Loan, isbeing serviced and administered pursuant to the trust and servicing agreementfor the CPTS 2019-CPT Transaction, which is incorporated by reference asExhibit 4.5 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the 225 Bush Mortgage Loan, The Essex Site 2Mortgage Loan and the Legends at Village West Mortgage Loan, which constitutedapproximately 4.9%, 3.4% and 3.4%, respectively, of the asset pool of theissuing entity as of its cut-off date.  The 225 Bush Mortgage Loan, TheEssex Site 2 Mortgage Loan and the Legends at Village West Mortgage Loan areeach an asset of the issuing entity and are each part of a loan combinationthat includes (a) with respect to the 225 Bush Mortgage Loan, five other *paripassu* loans and one subordinate companion loan, which are not assets of theissuing entity, (b) with respect to The Essex Site 2 Mortgage Loan, three other*pari passu* loans and two subordinate companion loans, which are notassets of the issuing entity or (c) with respect to the Legends at Village WestMortgage Loan, two other *pari passu* loans, which are not assets of theissuing entity. A *pari passu* portion of each loan combination wassecuritized in the Benchmark 2019-B14 Mortgage Trust transaction, CommissionFile Number 333-226123-05 (the “Benchmark 2019-B14 Transaction”). Theseloan combinations, including the 225 Bush Mortgage Loan, The Essex Site 2Mortgage Loan and the Legends at Village West Mortgage Loan, are being servicedand administered pursuant to the pooling and servicing agreement for theBenchmark 2019-B14 Transaction, which is incorporated by reference as Exhibit4.6 to this Annual Report on Form 10-K.

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

Midland Loan Services, a Divisionof PNC Bank, National Association is the master servicer of the mortgage loansserviced under the Pooling and Servicing Agreement, the primary servicer of theUSAA Office Portfolio Mortgage Loan, the Wind Creek Leased Fee Mortgage Loanand the Millennium Park Plaza Mortgage Loan and the primary servicer andspecial servicer of the 225 Bush Mortgage Loan, The Essex Site 2 Mortgage Loanand the Legends at Village West Mortgage Loan. As a result, Midland LoanServices, a Division of PNC Bank, National Association is a “servicer” asdefined in Item 1108(a)(2)(iii) of Regulation AB, in the capacities describedabove, because it is servicing mortgage loans that constituted 10% or more ofthe assets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria, accountants’ attestation reportsand servicer compliance statements delivered by Midland Loan Services, aDivision of PNC Bank, National Association in the capacities described aboveare listed in the Exhibit Index.

Rialto Capital Advisors, LLC isthe special servicer of the mortgage loans serviced under the Pooling andServicing Agreement, the USAA Office Portfolio Mortgage Loan and the MillenniumPark Plaza Mortgage Loan. As a result, Rialto Capital Advisors, LLC is a“servicer” as defined in Item 1108(a)(2)(iii) of Regulation AB, in thecapacities described above, because it is servicing mortgage loans thatconstituted 10% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby Rialto Capital Advisors, LLC in the capacities described above are listed inthe Exhibit Index.

Wells Fargo Bank, NationalAssociation is the certificate administrator of the mortgage loans servicedunder the Pooling and Servicing Agreement and the primary servicer of theCentury Plaza Towers Mortgage Loan and the Midtown Center Mortgage Loan. As aresult, Wells Fargo Bank, National Association is a “servicer” as defined inItem 1108(a)(2)(iii) of Regulation AB, in the capacities described above,because it is servicing mortgage loans that constituted 10% or more of theassets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria, accountants’ attestation reportsand servicer compliance statements delivered by Wells Fargo Bank, NationalAssociation in the capacities described above are listed in the Exhibit Index.

Wells Fargo Bank,National Association is the custodian of the mortgage loans serviced under thePooling and Servicing Agreement, the 225 Bush Mortgage Loan, The Essex Site 2Mortgage Loan, the Legends at Village West Mortgage Loan, the Wind Creek LeasedFee Mortgage Loan, the Century Plaza Towers Mortgage Loan and the MidtownCenter Mortgage Loan.  As a result, Wells Fargo Bank, National Associationis a servicing function participant in the capacities described above, becauseit is servicing mortgage loans that constituted 5% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria and accountants’ attestation reports delivered byWells Fargo Bank, National Association in the capacities described above arelisted in the Exhibit Index.

Park Bridge Lender Services LLC is the operating advisor ofthe mortgage loans serviced under the Pooling and Servicing Agreement, the USAAOffice Portfolio Mortgage Loan, the Wind Creek Leased Fee Mortgage Loan and theMillennium Park Plaza Mortgage Loan.  As a result, Park Bridge LenderServices LLC is a servicing function participant in the capacities describedabove, because it is servicing mortgage loans that constituted 5% or more ofthe assets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria and accountants’ attestationreports delivered by Park Bridge Lender Services LLC in the capacitiesdescribed above are listed in the Exhibit Index.

Citibank, N.A.is an affiliate of Citi Real Estate Funding Inc., one of the sponsors.Therefore, the Depositor included in this Annual Report on Form 10-K a servicercompliance statement for Citibank, N.A. pursuant to Item 1123. Citibank, N.A.is the custodian of the USAA Office Portfolio Mortgage Loan and the MillenniumPark Plaza Mortgage Loan.  As a result, Citibank, N.A. is a servicingfunction participant in the capacities described above, because it is servicingmortgage loans that constituted 5% or more of the assets of the issuing entityas of its cut-off date. The assessments of compliance with applicable servicingcriteria and accountants’ attestation reports delivered by Citibank, N.A. inthe capacities described above are listed in the Exhibit Index, and exclude theservicing criteria set forth in Items 1122(d)(4)(i) and 1122(d)(4)(ii) ofRegulation AB,  relating to the maintenance of collateral or security onpool assets as required by the pooling and servicing agreement  for theCGCMT 2019-GC41 Transaction  and the safeguarding of pool assets andrelated documents as required by the pooling and servicing agreement for theCGCMT 2019-GC41 Transaction, which servicing criteria have been assessed byU.S. Bank National Association, as a servicing function participant, asdescribed below in these Explanatory Notes.

This AnnualReport on Form 10-K includes an assessment of compliance with applicableservicing criteria and an accountant’s attestation report from U.S. BankNational Association. This entity was engaged by Citibank, N.A., as custodianof the USAA Office Portfolio Mortgage Loan and the Millennium Park PlazaMortgage Loan to perform certain custodial services. These custodial servicesare servicing functions included within the servicing criteria set forth inItems 1122(d)(4)(i) and 1122(d)(4)(ii) of Regulation AB. Therefore, under theprinciples-based definition of “servicer” set forth in Item 1101(j) orRegulation AB that looks to the functions that an entity performs, this vendoris a “servicer” for the purposes of Item 1122 of Regulation AB. See Complianceand Disclosure Interpretations, Section 301.01 (Item 1101(j)).

CWCapital Asset Management LLC isthe special servicer of the Century Plaza Towers Mortgage Loan, the MidtownCenter Mortgage Loan, the Wind Creek Leased Fee Mortgage Loan and the 180 WaterMortgage Loan. As a result, CWCapital Asset Management LLC is a “servicer” asdefined in Item 1108(a)(2)(iii) of Regulation AB, in the capacities describedabove, because it is servicing mortgage loans that constituted 10% or more ofthe assets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria, accountants’ attestation reportsand servicer compliance statements delivered by CWCapital Asset Management LLCin the capacities described above are listed in the Exhibit Index.

Pentalpha Surveillance LLC is the operating advisor of the225 Bush Mortgage Loan, The Essex Site 2 Mortgage Loan and the Legends atVillage West Mortgage Loan.  As a result, Pentalpha Surveillance LLC is aservicing function participant in the capacities described above, because it isservicing mortgage loans that constituted 5% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria and accountants’ attestation reports delivered byPentalpha Surveillance LLC in the capacities described above are listed in theExhibit Index.

Wells FargoBank, National Association acts as trustee of the 180 Water Mortgage Loan, TheShoppes at Blackstone Valley Mortgage Loan, the Elston Retail CollectionMortgage Loan, the PCI Pharma Portfolio Mortgage Loan, the Broadcasting SquareMortgage Loan, the Cobb Place Mortgage Loan, the 225 Bush Mortgage Loan, theLegends at Village West Mortgage Loan, The Essex Site 2 Mortgage Loan and theWind Creek Leased Fee Mortgage Loan.  Pursuant to the Pooling andServicing Agreement, the pooling and servicing agreement for the Benchmark2019-B14 Transaction and the pooling and servicing agreement for the Benchmark2019-B13 Transaction, the trustee is required to provide an assessment ofcompliance with applicable servicing criteria solely with respect to Item1122(d)(2)(iii) of Regulation AB (regarding advances of funds or guaranteesregarding collections, cash flows or distributions, and any interest or otherfees charged for such advances, are made, reviewed and approved as specified inthe transaction agreements). However, during the reporting period, the trusteedid not perform any servicing function with respect to the servicing criteriaspecified in Item 1122(d)(2)(iii) of Regulation AB.  The master serviceror the special servicer, to the extent required, performed the servicingfunction identified with respect to Item 1122(d)(2)(iii) of Regulation AB, andeach such party included Item 1122(d)(2)(iii) of Regulation AB in theassessment of compliance with applicable servicing criteria and accountant’sattestation report for the subject transaction.  As a result, this AnnualReport on Form 10-K does not include an assessment of compliance withapplicable servicing criteria of the trustee. One or more other servicers ofthe 180 Water Mortgage Loan, The Shoppes at Blackstone Valley Mortgage Loan,the Elston Retail Collection Mortgage Loan, the PCI Pharma Portfolio MortgageLoan, the Broadcasting Square Mortgage Loan, the Cobb Place Mortgage Loan, the225 Bush Mortgage Loan, the Legends at Village West Mortgage Loan, The EssexSite 2 Mortgage Loan and the Wind Creek Leased Fee Mortgage Loan have deliveredone or more assessments of compliance with respect to Item 1122(d)(2)(iii) ofRegulation AB.

Wilmington Trust, NationalAssociation acts as trustee of the USAA Office Portfolio Mortgage Loan, theMillennium Park Plaza Mortgage Loan, the Midtown Center Mortgage Loan and theCentury Plaza Towers Mortgage Loan.  Pursuant to the pooling and servicingagreement for the CGCMT 2019-GC41 Transaction, the trust and servicingagreement for the DCOT 2019-MTC Transaction and the trust and servicing agreementfor the CPTS 2019-CPT Transaction, the trustee is required to provide anassessment of compliance with applicable servicing criteria solely with respectto Item 1122(d)(2)(iii) of Regulation AB (regarding advances of funds orguarantees regarding collections, cash flows or distributions, and any interestor other fees charged for such advances, are made, reviewed and approved asspecified in the transaction agreements). However, during the reporting period,the trustee did not perform any servicing function with respect to theservicing criteria specified in Item 1122(d)(2)(iii) of Regulation AB. The master servicer or the special servicer, to the extent required, performedthe servicing function identified with respect to Item 1122(d)(2)(iii) of RegulationAB, and each such party included Item 1122(d)(2)(iii) of Regulation AB in theassessment of compliance with applicable servicing criteria and accountant’sattestation report for the subject transaction.  As a result, this AnnualReport on Form 10-K does not include an assessment of compliance withapplicable servicing criteria of the trustee. One or more other servicers ofthe USAA Office Portfolio Mortgage Loan, the Millennium Park Plaza MortgageLoan, the Midtown Center Mortgage Loan and the Century Plaza Towers MortgageLoan have delivered one or more assessments of compliance with respect to Item1122(d)(2)(iii) of Regulation AB.

This Annual Report on Form 10-Kincludes assessments of compliance with applicable servicing criteria andaccountants’ attestation reports from CoreLogic Solutions, LLC.  Thisentity was engaged by the primary servicer of the Midtown Center Mortgage Loanand the Century Plaza Towers Mortgage Loan to remit tax payments received fromthe escrow accounts of borrowers to local taxing authorities, to report taxamounts due, to verify tax parcel information, and to verify non-escrow taxpayments. These servicing functions are included within the servicing criteriaset forth in Items 1122(d)(4)(xi) and 1122(d)(4)(xii) of Regulation AB. Therefore, under the principles-based definition of “servicer” set forth inItem 1101(j) of Regulation AB that looks to the functions that an entityperforms, this vendor is a “servicer” for the purposes of Item 1122 ofRegulation AB.  *See* Compliance and Disclosure Interpretations,Section 301.01 (Item 1101(j)).

This Annual Report on Form 10-Kincludes an assessment of compliance with applicable servicing criteria,accountants’ attestation report and servicer compliance statement fromComputershare Trust Company, National Association (“CTCNA”).  CTCNAwas engaged by Wells Fargo Bank, National Association (“Wells Fargo”),in its capacity as certificate administrator and custodian, to perform certainspecified servicing functions identified in the assessment of compliance withapplicable servicing criteria and accountants’ attestation reports.  WellsFargo engaged CTCNA in connection with the sale of Wells Fargo’s corporatetrust services business to CTCNA and its affiliates.  Further, under theprinciples-based definition of “servicer” set forth in Item 1101(j) ofRegulation AB that looks to the functions that an entity performs, this partyis a “servicer” for the purposes of Item 1123 of Regulation AB.  SeeCompliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

Theassessments of compliance with applicable servicing criteria, accountants’attestation reports and servicer compliance statements of the certificateadministrator of the Wind Creek Leased Fee Mortgage Loan, the Midtown Center MortgageLoan, the Century Plaza Towers Mortgage Loan, the 225 Bush Mortgage Loan, theUSAA Office Portfolio Mortgage Loan, the Millennium Park Plaza Mortgage Loan,the Legends at Village West Mortgage Loan and The Essex Site 2 Mortgage Loanare omitted from this Annual Report on Form 10-K as the certificateadministrator pursuant to the related pooling and servicing agreement or trustand servicing agreement does not perform any activities that address servicingcriteria with respect to the issuing entity and because they are each not a“servicer” that meets the criteria in Item 1108(a)(2)(i) through (iii) ofRegulation AB.

**PART I**

**Item 1.  Business.**

Omitted.

**Item 1A.  Risk Factors.**

Omitted.

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

None.

**Item 2.  Properties.**

Omitted.

**Item 3.  Legal Proceedings.**

Omitted.

**Item 4.  Mine Safety Disclosures.**

Not applicable.

**PART II**

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

Omitted.

**Item 6.  Selected Financial Data.**

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**Item 9B.  Other Information.**

None.

**PART III**

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

Omitted.

**Item 11.  Executive Compensation.**

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**ADDITIONAL DISCLOSURE ITEMS FOR REGULATION AB**

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

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

 

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

No entity or group of affiliated entities provides any external credit enhancementor other support for the certificates within this transaction as describedunder Item 1114(a) of Regulation AB.

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

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

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

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

From time to time, CWCapital Asset Management LLC, a Delawarelimited liability company (“CWCAM”), is a party to lawsuits and otherlegal proceedings as part of its duties as a special servicer (e.g.,enforcement of loan obligations) and/or arising in the ordinary course ofbusiness.  Other than as set forth in the following paragraphs, there arecurrently no legal proceedings pending, and no legal proceedings known to becontemplated by governmental authorities, against CWCAM or of which any of itsproperty is the subject, that are material to the certificateholders.

On December 17, 2015, U.S. Bank National Association, thetrustee under five pooling and servicing agreements for (i) Wachovia BankCommercial Mortgage Trust 2007-C30, (ii) COBALT CMBS Commercial Trust 2007-C2,(iii) Wachovia Bank Commercial Mortgage Trust 2007-C31, (iv) ML-CFC CommercialMortgage Trust 2007-5 and (v) ML-CFC Commercial Mortgage Trust 2007-6 commenceda proceeding with the Second Judicial District Court of Ramsey County,Minnesota (the “State Court”) for a declaratory judgment as to theproper allocation of certain proceeds (“Disputed Proceeds”) received byCWCAM in connection with the sale of the Peter Cooper Village and StuyvesantTown property in New York, New York securing loans held by those trusts. CWCAM was the special servicer of such property.  The petition requeststhe State Court to instruct the trustee, the trust beneficiaries, and any otherinterested parties as to the amount of the Disputed Proceeds, if any, thatconstitute penalty interest and/or the amount of the Disputed Proceeds, if any,that constitute gain-on-sale proceeds, with respect to each trust.  OnFebruary 24, 2016, CWCAM made a limited appearance with the State Court to filea motion to dismiss this proceeding based on lack of jurisdiction, mootness,standing and forum non conveniens.  On July 19, 2016, the State Courtdenied CWCAM’s motion to dismiss.  On July 22, 2016, the action was removedto federal court in Minnesota (“Federal Court”).  On October 21,2016, the Federal Court held a hearing on the motion to transfer the action tothe United States District Court for the Southern District of New York (“SDNYCourt”), a motion to remand to state court and a motion to hear CWCAM’srequest for reconsideration of the motion to dismiss.  On March 14, 2017,the Federal Court reserved the determination on the motion to hear CWCAM’srequest for reconsideration of the motion to dismiss, denied the motion toremand the matter to state court and granted the motion to transfer theproceeding to the SDNY Court.  Cross motions for judgment on the pleadingswere filed but the SDNY Court was unable to decide the case based on thepleadings and the SDNY Court ordered discovery.  All fact discovery wascompleted in December, 2018 and expert discovery was completed on March 15,2019.  The parties submitted cross motions for summary judgment, and onMarch 19, 2020, the SDNY Court entered an opinion andorder in which it granted summary judgment in CWCAM’s favor and held that CWCAMwas entitled to the entire amount of penalty interest and that CWCAM’sdetermination of Yield Maintenance was correct.  In the 127-page opinion,the SDNY Court found for CWCAM on every issue presented by the trustee’spetition, namely, that the funds in dispute constitute penalty interest andyield maintenance, not gain-on-sale proceeds, and that the amount of penaltyinterest and yield maintenance was correctly calculated. An appeal of the SDNYCourt’s decision was taken on April 29, 2020.  Oral argument on the appealoccurred on June 21, 2021. The parties await the decision of the appealscourt.  

On December 1, 2017, a complaint against CWCAM and others wasfiled in the United States District Court for the Southern District of New Yorkstyled as CWCapital Cobalt Vr Ltd. v. CWCapital Investments LLC, et al., No.17-cv-9463 (the “Original Complaint”). The gravamen of theOriginal  Complaint alleged breaches of a contract and fiduciary duties byCWCAM’s affiliate, CWCapital Investments LLC in its capacity as collateralmanager for the collateralized debt obligation transaction involving CWCapitalCobalt Vr, Ltd. In total, there are 14 counts pled in the Original Complaint.Of those 14, 5 claims were asserted against CWCAM for aiding and abettingbreach of fiduciary duty, conversion and unjust enrichment. On May 23, 2018,the Original Complaint was dismissed for lack of subject matterjurisdiction.   On June 28, 2018, CWCapital Cobalt Vr Ltd. filed asubstantially similar complaint in the Supreme Court of the State of New York,County of New York styled as CWCapital Cobalt Vr Ltd. v. CWCapital InvestmentsLLC, et al., Index No. 653277/2018 (the “New Complaint”).  Thegravamen of the New Complaint is the same as the previous complaint filed inthe United State District Court for the Southern District of New York.  Intotal there are 16 counts pled in the New Complaint. Of those 16 counts, 5claims were asserted against CWCAM for aiding and abetting breach of fiduciaryduty, conversion and unjust enrichment, 1 count seeks a declaratory judgementthat the plaintiff has the right to enforce the contracts in question and 1count seeks an injunction requiring the defendants to recognize the plaintiffas the directing holder for the trusts in question. On January 11, 2019, theplaintiff dismissed with prejudice the declaratory judgment and injunctioncounts.  The New Complaint and related summons was not served on thedefendants until July 13, 2018 and July 16, 2018.  The plaintiff’s motionfor a preliminary injunction was denied by the court on July 31, 2018.  OnAugust 3, 2018, the defendants, including CWCAM, filed a motion to dismiss theNew Complaint in its entirety. On August 20, 2019, the court entered an ordergranting defendants’ motion almost in its entirety, dismissing 11 of the 16counts and partially dismissing 2 additional counts.  Of the remainingcounts, 2 are asserted against CWCAM for aiding and abetting breach offiduciary duty and unjust enrichment.  On September 19, 2019, CWCapitalCobalt Vr Ltd. filed a notice of appeal relating to the August 20, 2019dismissal order and on September 26, 2019, filed an amended complaint againstCWCI and CWCAM attempting to address deficiencies relating to certain of theclaims dismissed by the August, 20, 2019 order.  CWCI and CWCAM filed itsMotion to Dismiss the amended complaint on October 28, 2019.  The courtheard argument on the Motion to Dismiss the amended complaint on January 22,2020 and on October 23, 2020, the court granted the motion dismissing theamended claims.  On November 30, 2020, CWCapital Cobalt Vr Ltd filed anotice of appeal relating to the October 23, 2020 dismissal order.  OnApril 27, 2021, the First Department affirmed the dismissal as to claimsagainst CWCAM that were part of the August 20, 2019 dismissal, but reversed thedismissal of two counts for breach of the Collateral Management Agreementagainst CWCI.  CWCI has sought leave to file an appeal of the decision. Both requests for leave were denied by the First Department.  Theplaintiff has also sought leave to appeal the dismissal of the claims againstCWCAM.  CWCAM believes that it has performed its obligations under therelated pooling and servicing agreements in good faith and the remainingallegations in the New Complaint are without merit.  

On January 24, 2016 PSW NYC LLC commenced a complaint (the“PSW Complaint”) with the Supreme Court of the State of New York, County of NewYork (the “PSW Court”) against Bank of America, N.A. as trustee under thepooling and servicing agreements for Wachovia Bank Commercial Mortgage Trust2007-C30 and COBALT CMBS Commercial Trust 2007-C2, U.S. Bank NationalAssociation as trustee under the pooling and servicing agreements for WachoviaBank Commercial Mortgage Trust 2007-C31, ML-CFC Commercial Mortgage Trust2007-5 and ML-CFC Commercial Mortgage Trust 2007-6 (collectively, the “PSWTrusts”), PCV-M Holdings LLC and CWCapital Asset Management LLC, individuallyand as special servicer for the PSW Trusts (collectively, the “Defendants”)seeking either (a) damages in an amount to be determined by the PSW Court butalleged by the plaintiffs to be approximately $500,000,000 – such amount beingthe amount PSW NYC LLC alleges would have been recovered on certain mezzanineloans (the “PCVST Mezzanine Loans”) related to the Peter Cooper Village andStuyvesant Town property (the “PCVST Property”) in New York City which PSW NYCLLC sold to an entity related to the Defendants pursuant to a settlementagreement related to certain prior litigation (the “2010 Settlement Agreement”)or (b) the rescission of the 2010 Settlement Agreement which would result in,among other things, the rescission of the sale of the PCVST Mezzanine Loans anda claim for certain proceeds from the sale of the PCVST Property. PSW NYC LLCalleges that the Defendants procured the 2010 Settlement Agreement by fraud andfurther that the terms of the 2010 Settlement Agreement were breached by theDefendants. On February 26, 2016, CWCAM on behalf of itself and the otherDefendants filed a motion to dismiss the PSW Complaint (the “CWCAM Motion toDismiss”). On April 11, 2016, PSW NYC LLC opposed the CWCAM Motion to Dismissand cross-moved for a partial summary judgment on liability regardingallegations of breach of the 2010 Settlement Agreement (the “PSWCross-Motion”). On May 5, 2016, the Defendants subsequently filed its reply andopposition to the PSW Cross-Motion. On August 23, 2016, oral arguments wereprovided to the PSW Court regarding the PSW Complaint, the CWCAM Motion toDismiss and the PSW Cross-Motion and the PSW Court took such arguments underadvisement. On October 31, 2016, the PSW Court issued an order granting theCWCAM Motion to Dismiss, denying the PSW Cross-Motion and dismissing the PSWComplaint with prejudice. Subsequently, PSW NYC LLC filed a notice of appealrelating to such order. On February 21, 2017, PSW NYC LLC filed its appeal andsupporting brief arguing that the PSW Court erred by finding no breach of theassignment agreement and no fraudulent inducement. Oral argument was heard onMay 4, 2017 at which point the court took the arguments under advisement. OnMay 25, 2017, the New York 1st Department appellate court affirmedthe dismissal of all PSW claims and denied a request for leave to appeal to theNew York Court of Appeals on September 12, 2017.  

On March 31, 2016, RAIT Preferred Funding II LTD. (“RAITPreferred Funding”) commenced a complaint (“RAIT Complaint”) withthe Supreme Court of the State of New York, County of New York (the “RAITCourt”), claiming it owns $18,500,000 of a mortgage loan secured by thedevelopment of the One Congress Street Property in Boston, Massachusetts (the “Loan”)and seeking (a) a declaratory judgment stating that RAIT Preferred Funding isthe directing lender under a co-lender agreement dated March 28, 2007 and apooling and servicing agreement dated March 1, 2007 (collectively, the “OperativeAgreements”) and was the directing lender at the time of the impropermodification of the Loan, (b) a declaratory judgment stating that RAITPreferred Funding has the right to terminate the special servicer, (c) monetarydamages for the value of the bonds and fees paid to CWCAM as the specialservicer of the Loan and (d) other things.  On May 17, 2016, CWCAM filed amotion to dismiss the RAIT Complaint (“Motion to Dismiss”) stating thatthe RAIT Complaint did not state a claim and the essential facts of the RAITComplaint are negated by affidavits and evidentiary materials submitted withthe RAIT Complaint.  On June 14, 2016, RAIT Preferred Funding filed aMemorandum of Law in Opposition to the Motion to Dismiss (“Opposition”)stating that the claims in the RAIT Complaint were properly stated.  OnJune 30, 2016, CWCAM filed a reply in support of the Motion to Dismiss and inresponse to the Opposition, stating that each of CWCAM’s arguments is supportedby the express language of the agreements between the parties, the documentaryevidence and New York case law.  On September 30, 2016, RAIT PreferredFunding and CWCAM entered into a confidential Settlement Agreement (the “2016Settlement”), which provides for a stay of the RAIT Preferred Fundinglitigation (the “Litigation Stay”) through August 25, 2017. Pursuant to the terms of the 2016 Settlement, upon satisfaction of a term ofthe 2016 Settlement by August 25, 2017 (or such later date agreed to by theparties), the RAIT Preferred Funding litigation will be dismissed, withprejudice.  On May 19, 2017 the Borrower repaid the Loan in accordancewith the terms of the notes and satisfied the condition to dismissal withprejudice.  RAIT has refused to dismiss the case and is claiming that theB Note should be paid in full.  CWCAM believes that it has performed itsobligations under the Operative Agreements in good faith, and that the actionshould be dismissed with prejudice.  On August 29, 2017, the RAIT Courtgranted leave to RAIT Preferred Funding to amend its complaint.  OnSeptember 20, 2017, RAIT Preferred Funding filed an Amended Complaint (the “RAITAmended Complaint”), which omits its original claims, adds Wells Fargo Bankas a defendant, and seeks (a) specific performance requiring repayment of the$18,500,000 principal amount of the B Note or, in the alternative, monetarydamages, including the $18,500,000 principal amount of the B Note, in an amountto be determined at trial, (b) monetary damages on any fees paid to CWCAM asspecial servicer or Wells Fargo Bank as master servicer in connection with theborrower’s repayment of the Loan, (c) a declaratory judgment that RAITPreferred Funding is entitled to recover the full $18,500,000 principal amountof the B Note, (d) punitive damages against CWCAM, and (e) other things. On October 11, 2017, CWCAM filed a motion to dismiss the RAIT Amended Complaint(“CWCAM Motion to Dismiss Amended Complaint”) stating that the RAITAmended Complaint did not state a claim and the essential facts of the RAITAmended Complaint are negated by the Operative Agreements and other admissibleevidentiary materials.  On November 13, 2017, Wells Fargo Bank filed amotion to dismiss the RAIT Amended Complaint (the “Wells Fargo Motion toDismiss Amended Complaint”) and joined the CWCAM Motion to Dismiss AmendedComplaint.  On January 29, 2018, the court dismissed all claims but forbreach of contract and discovery has commenced.  CWCAM filed a Motion forSummary Judgement on March 18, 2019.   This matter was settled andthe case dismissed on May 15, 2019.  

 

In December 2014, Phoenix LightSF Limited and certain related entities and the National Credit UnionAdministration (NCUA) filed complaints in the United States District Court forthe Southern District of New York against Wells Fargo Bank, alleging claimsagainst Wells Fargo Bank in its capacity as trustee for a number of residentialmortgage-backed securities trusts. Complaints raising similar allegations havebeen filed by Commerzbank AG in the Southern District of New York and by IKBInternational and IKB Deutsche Industriebank in New York state court. In eachcase, the plaintiffs allege that Wells Fargo Bank, as trustee, caused losses toinvestors, and plaintiffs assert causes of action based upon, among otherthings, the trustee’s alleged failure to notify and enforce repurchase obligationsof mortgage loan sellers for purported breaches of representations andwarranties, notify investors of alleged events of default, and abide byappropriate standards of care following alleged events of default. Wells FargoBank previously settled two class action lawsuits with similar allegations thatwere filed in November 2014 and December 2016 by institutional investors in theSouthern District of New York and New York state court, respectively. Inaddition, Park Royal I LLC and Park Royal II LLC have filed complaints in NewYork state court alleging Wells Fargo Bank, N.A., as trustee, failed to takeappropriate actions upon learning of defective mortgage loan documentation. InMarch 2021, the Company entered into an agreement to resolve the case filed bythe NCUA.

 

In addition to the foregoingcases, in August 2014 and August 2015 Nomura Credit & Capital Inc. (“Nomura”)and Natixis Real Estate Holdings, LLC (“Natixis”) filed a total of seventhird-party complaints against Wells Fargo Bank in New York state court. In theunderlying first-party actions, Nomura and Natixis have been sued for allegedbreaches of representations and warranties made in connection with residentialmortgage-backed securities sponsored by them. In the third-party actions,Nomura and Natixis allege that Wells Fargo Bank, as master servicer, primaryservicer or securities administrator, failed to notify Nomura and Natixis oftheir own breaches, failed to properly oversee the primary servicers, andfailed to adhere to accepted servicing practices. Natixis additionally allegesthat Wells Fargo Bank failed to perform default oversight duties. Wells FargoBank has asserted counterclaims alleging that Nomura and Natixis failed toprovide Wells Fargo Bank notice of their representation and warranty breaches.

With respect to each of the foregoing litigations, WellsFargo Bank believes plaintiffs' claims are without merit and intends to contestthe claims vigorously, but there can be no assurances as to the outcome of thelitigations or the possible impact of the litigations on Wells Fargo Bank orthe related RMBS trusts.

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

The information regarding this Item has been previouslyprovided in the prospectus of the Registrant relating to the issuing entityfiled on December 12, 2019 pursuant to Rule 424(b)(2).

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

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the mortgage loans are attachedhereto under Item 15 to this Annual Report on Form 10-K. Attached as ScheduleII to the Pooling and Servicing Agreement incorporated by reference as Exhibit4.1 to this Annual Report on Form 10-K is a chart identifying the entitiesparticipating in a servicing function for the transaction responsible for eachapplicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the USAA Office Portfolio MortgageLoan and the Millennium Park Plaza Mortgage Loan, which are being serviced andadministered pursuant to the pooling and servicing agreement for the CGCMT2019-GC41 Transaction, are attached hereto under Item 15 to this Annual Reporton Form 10-K. Attached as Exhibit O to the pooling and servicing agreement forthe CGCMT 2019-GC41 Transaction incorporated by reference as Exhibit 4.2 tothis Annual Report on Form 10-K is a chart identifying the entitiesparticipating in a servicing function for the CGCMT 2019-GC41 Transactionresponsible for each applicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Wind Creek Leased Fee MortgageLoan, which is being serviced and administered pursuant to the pooling andservicing agreement for the Benchmark 2019-B13 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Schedule II tothe pooling and servicing agreement for the Benchmark 2019-B13 Transactionincorporated by reference as Exhibit 4.3 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theBenchmark 2019-B13 Transaction responsible for each applicable servicingcriteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Midtown Center Mortgage Loan,which is being serviced and administered pursuant to the trust and servicingagreement for the DCOT 2019-MTC Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit L to the trust andservicing agreement for the DCOT 2019-MTC Transaction incorporated by referenceas Exhibit 4.4 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the DCOT 2019-MTCTransaction responsible for each applicable servicing criteria set forth inItem 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Century Plaza Towers MortgageLoan, which is being serviced and administered pursuant to the trust andservicing agreement for the CPTS 2019-CPT Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Schedule I to thetrust and servicing agreement for the CPTS 2019-CPT Transaction incorporated byreference as Exhibit 4.5 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the CPTS2019-CPT Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the 225 Bush Mortgage Loan, theLegends at Village West Mortgage Loan and The Essex Site 2 Mortgage Loan, whichare being serviced and administered pursuant to the pooling and servicingagreement for the Benchmark 2019-B14 Transaction, are attached hereto underItem 15 to this Annual Report on Form 10-K. Attached as Exhibit AA to thepooling and servicing agreement for the Benchmark 2019-B14 Transactionincorporated by reference as Exhibit 4.6 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theBenchmark 2019-B14 Transaction responsible for each applicable servicingcriteria set forth in Item 1122(d).

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

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

**PART IV**

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

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

(1) Not applicable

(2) Not applicable

(3) See below

 

4.1          Poolingand Servicing Agreement, dated as of December 1, 2019, between DeutscheMortgage & Asset Receiving Corporation, as Depositor, Midland Loan Services,a Division of PNC Bank, National Association, as Master Servicer, RialtoCapital Advisors, LLC, as Special Servicer, Wells Fargo Bank, NationalAssociation, as Trustee, Wells Fargo Bank, National Association, as CertificateAdministrator, Paying Agent and Custodian, and Park Bridge Lender Services LLC,as Operating Advisor and Asset Representations Reviewer (filed as Exhibit 4.1to the registrant’s Current Report on Form 8-K/A filed on January 31, 2020under Commission File No. 333-226943-05 and incorporated by reference herein).

4.2          Poolingand Servicing Agreement, dated as of August 1, 2019, among Citigroup CommercialMortgage Securities Inc., as Depositor, Midland Loan Services, a Division ofPNC Bank, National Association, as Master Servicer, Rialto Capital Advisors,LLC, as Special Servicer, Park Bridge Lender Services LLC, as Operating Advisorand Asset Representations Reviewer, Citibank, N.A., as CertificateAdministrator, and Wilmington Trust, National Association, as Trustee (filed asExhibit 4.4 to the registrant’s Current Report on Form 8-K filed on December12, 2019 under Commission File No. 333-226943-05 and incorporated by reference herein).

4.3          Poolingand Servicing Agreement, dated as of October 1, 2019, between Deutsche Mortgage& Asset Receiving Corporation, as Depositor, Midland Loan Services, aDivision of PNC Bank, National Association, as Master Servicer, CWCapital AssetManagement LLC, as Special Servicer, Wells Fargo Bank, National Association, asTrustee, Wells Fargo Bank, National Association, as Certificate Administrator,Paying Agent and Custodian, and Park Bridge Lender Services LLC, as OperatingAdvisor and Asset Representations Reviewer (filed as Exhibit 4.6 to theregistrant’s Current Report on Form 8-K filed on December 12, 2019 underCommission File No. 333-226943-05 and incorporated by reference herein).

4.4          Trustand Servicing Agreement, dated as of October 30, 2019, among Wells Fargo CommercialMortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Servicer, CWCapital Asset Management LLC, as Special Servicer,Wells Fargo Bank, National Association, as Certificate Administrator andWilmington Trust, National Association, as Trustee (filed as Exhibit 4.5 to theregistrant’s Current Report on Form 8-K filed on December 12, 2019 underCommission File No. 333-226943-05 and incorporated by reference herein).

4.5          Trustand Servicing Agreement, dated as of November 9, 2019, between DeutscheMortgage & Asset Receiving Corporation, as Depositor, Wells Fargo Bank,National Association, as Master Servicer, CWCapital Asset Management LLC, asSpecial Servicer, Wilmington Trust, National Association, as Trustee, and WellsFargo Bank, National Association, as Certificate Administrator, Paying Agentand Custodian (filed as Exhibit 4.2 to the registrant’s Current Report on Form8-K filed on December 12, 2019 under Commission File No. 333-226943-05 andincorporated by reference herein).

4.6          Poolingand Servicing Agreement, dated as of November 1, 2019, between J.P. MorganChase Commercial Mortgage Securities Corp., as Depositor, Midland LoanServices, a Division of PNC Bank, National Association, as Master Servicer,Midland Loan Services, a Division of PNC Bank, National Association, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administrator,Wells Fargo Bank, National Association, as Trustee, and Pentalpha SurveillanceLLC, as Operating Advisor and as Asset Representations Reviewer (filed asExhibit 4.3 to the registrant’s Current Report on Form 8-K filed on December12, 2019 under Commission File No. 333-226943-05 and incorporated by referenceherein).

4.7          Co-LenderAgreement, dated as of October 21, 2019, by and between Deutsche Bank AG, NewYork Branch, as an Initial Note A Holder, Wells Fargo Bank, NationalAssociation, as an Initial Note A Holder, Morgan Stanley Bank, NationalAssociation, as an Initial Note A Holder, Deutsche Bank AG, New York Branch, asInitial Note B-1 Holder, Morgan Stanley Bank, National Association, as InitialNote B-2 Holder and Wells Fargo Bank, National Association,  as InitialNote B-3 Holder (filed as Exhibit 4.12 to the registrant’s Current Report onForm 8-K filed on December 12, 2019 under Commission File No. 333-226943-05 andincorporated by reference herein).

4.8          AgreementBetween Noteholders, dated as of November 21, 2019, by and between DBRInvestments Co. Limited, as Initial Note A-1 Holder, DBR Investments Co.Limited, as Initial Note A-2 Holder, DBR Investments Co. Limited, as InitialNote A-3 Holder, DBR Investments Co. Limited, as Initial Note A-4 Holder, DBRInvestments Co. Limited, as Initial Note A-5 Holder and DBR Investments Co.Limited, as Initial Note B Holder (filed as Exhibit 4.8 to the registrant’s CurrentReport on Form 8-K filed on December 12, 2019 under Commission File No.333-226943-05 and incorporated by reference herein).

4.9          AgreementBetween Noteholders, dated as of November 12, 2019, by and among Goldman SachsBank USA, as Initial Note A-1 Holder, Initial Note A-2 Holder, Initial Note A-3Holder, Initial Note A-4 Holder, Initial Note A-5 Holder, Initial A-6 Holder,Initial Note A-7 Holder, Initial Note A-8 Holder and Initial Note A-9 Holder(filed as Exhibit 4.9 to the registrant’s Current Report on Form 8-K filed onDecember 12, 2019 under Commission File No. 333-226943-05 and incorporated byreference herein).

4.10         AgreementBetween Noteholders, dated as of November 18, 2019, by and between DBRInvestments Co. Limited, as Initial Note A-1 Holder,  DBR Investments Co.Limited, as Initial Note A-2 Holder, UBS AG, by and through its branch officeat 1285 Avenue of the Americas, New York, New York, as Initial Note A-3 Holder,UBS AG, by and through its branch office at 1285 Avenue of the Americas, NewYork, New York, as Initial Note A-4 Holder, DBR Investments Co. Limited, asInitial Note A-5 Holder, DBR Investments Co. Limited, as Initial Note A-6Holder and DBR Investments Co. Limited, as Initial Note B Holder (filed asExhibit 4.10 to the registrant’s Current Report on Form 8-K filed on December12, 2019 under Commission File No. 333-226943-05 and incorporated by referenceherein).

4.11         Amendedand Restated Agreement Between Noteholders, dated as of November 8, 2019, byand among Wilmington Trust, National Association, as Trustee, for the benefitof the registered holders of Citigroup Commercial Mortgage Trust 2019-GC41,Commercial Mortgage Pass-Through Certificates, Series 2019-GC41, as Note A-1Holder, Wells Fargo Bank, National Association, as Trustee, for the benefit ofthe Registered Holders of GS Mortgage Securities Trust 2019-GC42, CommercialMortgage Pass-Through Certificates, Series 2019-GC42, as Note A-2 Holder andGoldman Sachs Bank USA, as 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 (filed as Exhibit 4.11 to the registrant’s CurrentReport on Form 8-K filed on December 12, 2019 under Commission File No.333-226943-05 and incorporated by reference herein).

4.12         AgreementBetween Noteholders, dated as of November 12, 2019, by and among Goldman SachsBank USA, as Initial Note A-1 Holder, Initial Note A-2 Holder, Initial Note A-3Holder, Initial Note A-4 Holder, Initial Note A-5 Holder, Initial A-6 Holderand Initial Note A-7 Holder (filed as Exhibit 4.12 to the registrant’s CurrentReport on Form 8-K filed on December 12, 2019 under Commission File No.333-226943-05 and incorporated by reference herein).

4.13         Co-LenderAgreement, dated as of October 31, 2019, by and between Citi Real EstateFunding Inc., as Initial Note A-1 Holder and Citi Real Estate Funding Inc., as InitialNote A-2 Holder (filed as Exhibit 4.13 to the registrant’s Current Report onForm 8-K filed on December 12, 2019 under Commission File No. 333-226943-05 andincorporated by reference herein).

4.14         AgreementBetween Noteholders, dated as of November 1, 2019, by and among JPMorgan ChaseBank, National Association, as Initial Note A-1-1 Holder, Initial Note A-1-2Holder, Initial Note A-1-3 and Initial Note B-1-1 Holder, and Goldman SachsBank USA, as Initial Note A-1-4 Holder and Initial Note B-1-2 Holder (filed asExhibit 4.14 to the registrant’s Current Report on Form 8-K filed on December12, 2019 under Commission File No. 333-226943-05 and incorporated by referenceherein).

4.15         Co-LenderAgreement, dated as of November 1, 2019, by and between Citi Real EstateFunding Inc., as Initial Note A-1 Holder, Citi Real Estate Funding Inc., asInitial Note A-2 Holder, and Citi Real Estate Funding Inc., as Initial Note A-3Holder (filed as Exhibit 4.15 to the registrant’s Current Report on Form 8-Kfiled on December 12, 2019 under Commission File No. 333-226943-05 andincorporated by reference herein).

4.16         Co-LenderAgreement, dated as of September 30, 2019, by and among Wells Fargo Bank,National Association, as Initial Note Holder of Note A-1-1, Note A-2-1, NoteA-2-2, Note A-2-3 and Note B-1-1, Bank of America, N.A., as Initial Note Holderof Note A-1-2, Note A-2-4, Note A-2-5 and Note B-1-2 and Goldman Sachs Bank USA,as Initial Note Holder of Note A-1-3, Note A-2-6, Note A-2-7 and Note B-1-3(filed as Exhibit 4.16 to the registrant’s Current Report on Form 8-K filed onDecember 12, 2019 under Commission File No. 333-226943-05 and incorporated byreference herein).

4.17         Co-LenderAgreement, dated as of  November 12, 2019, by and between Citi Real EstateFunding Inc., as Initial Note A-1 Holder and Citi Real Estate Funding Inc., asInitial Note A-2 Holder (filed as Exhibit 4.17 to the registrant’s CurrentReport on Form 8-K filed on December 12, 2019 under Commission File No.333-226943-05 and incorporated by reference herein).

4.18         AgreementBetween Noteholder, dated as of November 12, 2019, by and among Goldman SachsBank USA, as Initial Note A-1 Holder and Initial Note A-2 Holder (filed as Exhibit4.18 to the registrant’s Current Report on Form 8-K filed on December 12, 2019under Commission File No. 333-226943-05 and incorporated by reference herein).

4.19         Co-LenderAgreement, dated as of August 20, 2019, between Cantor Commercial Real EstateLending, L.P., as Note A-1 Holder, DBR Investments Co. Limited, as Note A-2Holder, DBR Investments Co. Limited, as Note A-3 Holder, DBR Investments Co.Limited, as Note A-4 Holder, DBR Investments Co. Limited, as Note A-5 Holderand DBR Investments Co. Limited, as Note A-6 Holder (filed as Exhibit 4.19 tothe registrant’s Current Report on Form 8-K filed on December 12, 2019 underCommission File No. 333-226943-05 and incorporated by reference herein).

4.20         Amendedand Restated Agreement Between Noteholders, dated as of November 8, 2019, byand among Wilmington Trust, National Association, as Trustee, for the benefitof the registered holders of Citigroup Commercial Mortgage Trust 2019-GC41,Commercial Mortgage Pass-Through Certificates, Series 2019-GC41, as Note A-1Holder, Wells Fargo Bank, National Association, as Trustee, for the benefit ofthe Registered Holders of GS Mortgage Securities Trust 2019-GC42, CommercialMortgage Pass-Through Certificates, Series 2019-GC42, as Note A-2 Holder andGoldman Sachs Bank USA, as Initial Note A-3 Holder, Initial Note A-4 Holder,Initial Note A-5 Holder, Initial Note A-6 Holder and Initial Note A-7 Holder(filed as Exhibit 4.20 to the registrant’s Current Report on Form 8-K filed onDecember 12, 2019 under Commission File No. 333-226943-05 and incorporated byreference herein).

 

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

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

33.1        Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer

33.2        Rialto Capital Advisors, LLC, as Special Servicer

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

33.4        Wells Fargo Bank, National Association, asCustodian

33.5        Park Bridge Lender Services LLC, as OperatingAdvisor

33.6        Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator on andafter November 1, 2021

33.7        Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021

33.8        Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 180 Water Mortgage Loan (seeExhibit 33.1)

33.9        CWCapital Asset Management LLC, as Special Servicerof the 180 Water Mortgage Loan

33.10      Wells Fargo Bank, National Association, as Trustee of the 180 Water MortgageLoan (Omitted. See Explanatory Notes.)

33.11      Wells Fargo Bank, National Association, asCustodian of the 180 Water Mortgage Loan (see Exhibit 33.4)

33.12      Park Bridge Lender Services LLC, as OperatingAdvisor of the 180 Water Mortgage Loan (see Exhibit 33.5)

33.13      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.14      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of The Shoppes at Blackstone ValleyMortgage Loan (see Exhibit 33.1)

33.15      Rialto Capital Advisors, LLC, as Special Servicerof The Shoppes at Blackstone Valley Mortgage Loan (see Exhibit 33.2)

33.16      Wells Fargo Bank, National Association, as Trustee of The Shoppes at BlackstoneValley Mortgage Loan (Omitted. See Explanatory Notes.)

33.17      Wells Fargo Bank, National Association, asCustodian of The Shoppes at Blackstone Valley Mortgage Loan (see Exhibit 33.4)

33.18      Park Bridge Lender Services LLC, as OperatingAdvisor of The Shoppes at Blackstone Valley Mortgage Loan (see Exhibit 33.5)

33.19      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.20      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Elston Retail CollectionMortgage Loan (see Exhibit 33.1)

33.21      Rialto Capital Advisors, LLC, as Special Servicerof the Elston Retail Collection Mortgage Loan (see Exhibit 33.2)

33.22      Wells Fargo Bank, National Association, as Trustee of the Elston RetailCollection Mortgage Loan (Omitted. See Explanatory Notes.)

33.23      Wells Fargo Bank, National Association, asCustodian of the Elston Retail Collection Mortgage Loan (see Exhibit 33.4)

33.24      Park Bridge Lender Services LLC, as OperatingAdvisor of the Elston Retail Collection Mortgage Loan (see Exhibit 33.5)

33.25      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.26      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the PCI Pharma Portfolio MortgageLoan (see Exhibit 33.1)

33.27      Rialto Capital Advisors, LLC, as Special Servicerof the PCI Pharma Portfolio Mortgage Loan (see Exhibit 33.2)

33.28      Wells Fargo Bank, National Association, as Trustee of the PCI Pharma PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.29      Wells Fargo Bank, National Association, as Custodianof the PCI Pharma Portfolio Mortgage Loan (see Exhibit 33.4)

33.30      Park Bridge Lender Services LLC, as OperatingAdvisor of the PCI Pharma Portfolio Mortgage Loan (see Exhibit 33.5)

33.31      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.32      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Broadcasting Square MortgageLoan (see Exhibit 33.1)

33.33      Rialto Capital Advisors, LLC, as Special Servicerof the Broadcasting Square Mortgage Loan (see Exhibit 33.2)

33.34      Wells Fargo Bank, National Association, as Trustee of the Broadcasting SquareMortgage Loan (Omitted. See Explanatory Notes.)

33.35      Wells Fargo Bank, National Association, asCustodian of the Broadcasting Square Mortgage Loan (see Exhibit 33.4)

33.36      Park Bridge Lender Services LLC, as OperatingAdvisor of the Broadcasting Square Mortgage Loan (see Exhibit 33.5)

33.37      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.38      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Cobb Place Mortgage Loan (seeExhibit 33.1)

33.39      Rialto Capital Advisors, LLC, as Special Servicerof the Cobb Place Mortgage Loan (see Exhibit 33.2)

33.40      Wells Fargo Bank, National Association, as Trustee of the Cobb Place MortgageLoan (Omitted. See Explanatory Notes.)

33.41      Wells Fargo Bank, National Association, asCustodian of the Cobb Place Mortgage Loan (see Exhibit 33.4)

33.42      Park Bridge Lender Services LLC, as OperatingAdvisor of the Cobb Place Mortgage Loan (see Exhibit 33.5)

33.43      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.44      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the USAA Office Portfolio MortgageLoan (see Exhibit 33.1)

33.45      Rialto Capital Advisors, LLC, as Special Servicerof the USAA Office Portfolio Mortgage Loan (see Exhibit 33.2)

33.46      Wilmington Trust, National Association, as Trustee of the USAA Office PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.47      Citibank, N.A., as Custodian of the USAA OfficePortfolio Mortgage Loan

33.48      Park Bridge Lender Services LLC, as OperatingAdvisor of the USAA Office Portfolio Mortgage Loan (see Exhibit 33.5)

33.49      U.S. Bank National Association, as ServicingFunction Participant of the USAA Office Portfolio Mortgage Loan

33.50      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Millennium Park Plaza MortgageLoan (see Exhibit 33.1)

33.51      Rialto Capital Advisors, LLC, as Special Servicerof the Millennium Park Plaza Mortgage Loan (see Exhibit 33.2)

33.52      Wilmington Trust, National Association, as Trustee of the Millennium Park PlazaMortgage Loan (Omitted. See Explanatory Notes.)

33.53      Citibank, N.A., as Custodian of the MillenniumPark Plaza Mortgage Loan (see Exhibit 33.47)

33.54      Park Bridge Lender Services LLC, as OperatingAdvisor of the Millennium Park Plaza Mortgage Loan (see Exhibit 33.5)

33.55      U.S. Bank National Association, as ServicingFunction Participant of the Millennium Park Plaza Mortgage Loan (see Exhibit33.49)

33.56      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Wind Creek Leased Fee MortgageLoan (see Exhibit 33.1)

33.57      CWCapital Asset Management LLC, as Special Servicerof the Wind Creek Leased Fee Mortgage Loan (see Exhibit 33.9)

33.58      Wells Fargo Bank, National Association, as Trustee of the Wind Creek Leased FeeMortgage Loan (Omitted. See Explanatory Notes.)

33.59      Wells Fargo Bank, National Association, asCustodian of the Wind Creek Leased Fee Mortgage Loan (see Exhibit 33.4)

33.60      Park Bridge Lender Services LLC, as OperatingAdvisor of the Wind Creek Leased Fee Mortgage Loan (see Exhibit 33.5)

33.61      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.62      Wells Fargo Bank, National Association, as PrimaryServicer of the Midtown Center Mortgage Loan

33.63      CWCapital Asset Management LLC, as Special Servicerof the Midtown Center Mortgage Loan (see Exhibit 33.9)

33.64      Wilmington Trust, National Association, as Trustee of the Midtown CenterMortgage Loan (Omitted. See Explanatory Notes.)

33.65      Wells Fargo Bank, National Association, as Custodianof the Midtown Center Mortgage Loan (see Exhibit 33.4)

33.66      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Midtown Center Mortgage Loan

33.67      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.68      Wells Fargo Bank, National Association, as PrimaryServicer of the Century Plaza Towers Mortgage Loan (see Exhibit 33.62)

33.69      CWCapital Asset Management LLC, as Special Servicerof the Century Plaza Towers Mortgage Loan (see Exhibit 33.9)

33.70      Wilmington Trust, National Association, as Trustee of the Century Plaza TowersMortgage Loan (Omitted. See Explanatory Notes.)

33.71      Wells Fargo Bank, National Association, asCustodian of the Century Plaza Towers Mortgage Loan (see Exhibit 33.4)

33.72      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Century Plaza Towers Mortgage Loan (see Exhibit 33.66)

33.73      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.74      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 225 Bush Mortgage Loan (seeExhibit 33.1)

33.75      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the 225 Bush Mortgage Loan (seeExhibit 33.1)

33.76      Wells Fargo Bank, National Association, as Trustee of the 225 Bush MortgageLoan (Omitted. See Explanatory Notes.)

33.77      Wells Fargo Bank, National Association, asCustodian of the 225 Bush Mortgage Loan (see Exhibit 33.4)

33.78      Pentalpha Surveillance LLC, as Operating Advisorof the 225 Bush Mortgage Loan

33.79      Computershare Trust Company, National Association, asServicing Function Participant for the Custodian on and after November 1, 2021(see Exhibit 33.7)

33.80      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Legends at Village WestMortgage Loan (see Exhibit 33.1)

33.81      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Legends at Village WestMortgage Loan (see Exhibit 33.1)

33.82      Wells Fargo Bank, National Association, as Trustee of the Legends at VillageWest Mortgage Loan (Omitted. See Explanatory Notes.)

33.83      Wells Fargo Bank, National Association, asCustodian of the Legends at Village West Mortgage Loan (see Exhibit 33.4)

33.84      Pentalpha Surveillance LLC, as Operating Advisorof the Legends at Village West Mortgage Loan (see Exhibit 33.78)

33.85      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.86      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of The Essex Site 2 Mortgage Loan(see Exhibit 33.1)

33.87      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of The Essex Site 2 Mortgage Loan(see Exhibit 33.1)

33.88      Wells Fargo Bank, National Association, as Trustee of The Essex Site 2 MortgageLoan (Omitted. See Explanatory Notes.)

33.89      Wells Fargo Bank, National Association, asCustodian of The Essex Site 2 Mortgage Loan (see Exhibit 33.4)

33.90      Pentalpha Surveillance LLC, as Operating Advisorof The Essex Site 2 Mortgage Loan (see Exhibit 33.78)

33.91      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

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

34.1        Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer

34.2        Rialto Capital Advisors, LLC, as Special Servicer

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

34.4        Wells Fargo Bank, National Association, asCustodian

34.5        Park Bridge Lender Services LLC, as OperatingAdvisor

34.6        Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator on andafter November 1, 2021

34.7        Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021

34.8        Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 180 Water Mortgage Loan (seeExhibit 34.1)

34.9        CWCapital Asset Management LLC, as Special Servicerof the 180 Water Mortgage Loan

34.10      Wells Fargo Bank, National Association, as Trustee of the 180 Water MortgageLoan (Omitted. See Explanatory Notes.)

34.11      Wells Fargo Bank, National Association, asCustodian of the 180 Water Mortgage Loan (see Exhibit 34.4)

34.12      Park Bridge Lender Services LLC, as OperatingAdvisor of the 180 Water Mortgage Loan (see Exhibit 34.5)

34.13      Computershare Trust Company, National Association, asServicing Function Participant for the Custodian on and after November 1, 2021(see Exhibit 34.7)

34.14      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of The Shoppes at Blackstone ValleyMortgage Loan (see Exhibit 34.1)

34.15      Rialto Capital Advisors, LLC, as Special Servicerof The Shoppes at Blackstone Valley Mortgage Loan (see Exhibit 34.2)

34.16      Wells Fargo Bank, National Association, as Trustee of The Shoppes at BlackstoneValley Mortgage Loan (Omitted. See Explanatory Notes.)

34.17      Wells Fargo Bank, National Association, asCustodian of The Shoppes at Blackstone Valley Mortgage Loan (see Exhibit 34.4)

34.18      Park Bridge Lender Services LLC, as OperatingAdvisor of The Shoppes at Blackstone Valley Mortgage Loan (see Exhibit 34.5)

34.19      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.20      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Elston Retail CollectionMortgage Loan (see Exhibit 34.1)

34.21      Rialto Capital Advisors, LLC, as Special Servicerof the Elston Retail Collection Mortgage Loan (see Exhibit 34.2)

34.22      Wells Fargo Bank, National Association, as Trustee of the Elston RetailCollection Mortgage Loan (Omitted. See Explanatory Notes.)

34.23      Wells Fargo Bank, National Association, asCustodian of the Elston Retail Collection Mortgage Loan (see Exhibit 34.4)

34.24      Park Bridge Lender Services LLC, as OperatingAdvisor of the Elston Retail Collection Mortgage Loan (see Exhibit 34.5)

34.25      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.26      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the PCI Pharma Portfolio MortgageLoan (see Exhibit 34.1)

34.27      Rialto Capital Advisors, LLC, as Special Servicerof the PCI Pharma Portfolio Mortgage Loan (see Exhibit 34.2)

34.28      Wells Fargo Bank, National Association, as Trustee of the PCI Pharma PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.29      Wells Fargo Bank, National Association, asCustodian of the PCI Pharma Portfolio Mortgage Loan (see Exhibit 34.4)

34.30      Park Bridge Lender Services LLC, as OperatingAdvisor of the PCI Pharma Portfolio Mortgage Loan (see Exhibit 34.5)

34.31      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.32      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Broadcasting Square MortgageLoan (see Exhibit 34.1)

34.33      Rialto Capital Advisors, LLC, as Special Servicerof the Broadcasting Square Mortgage Loan (see Exhibit 34.2)

34.34      Wells Fargo Bank, National Association, as Trustee of the Broadcasting SquareMortgage Loan (Omitted. See Explanatory Notes.)

34.35      Wells Fargo Bank, National Association, asCustodian of the Broadcasting Square Mortgage Loan (see Exhibit 34.4)

34.36      Park Bridge Lender Services LLC, as OperatingAdvisor of the Broadcasting Square Mortgage Loan (see Exhibit 34.5)

34.37      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.38      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Cobb Place Mortgage Loan (seeExhibit 34.1)

34.39      Rialto Capital Advisors, LLC, as Special Servicerof the Cobb Place Mortgage Loan (see Exhibit 34.2)

34.40      Wells Fargo Bank, National Association, as Trustee of the Cobb Place MortgageLoan (Omitted. See Explanatory Notes.)

34.41      Wells Fargo Bank, National Association, asCustodian of the Cobb Place Mortgage Loan (see Exhibit 34.4)

34.42      Park Bridge Lender Services LLC, as OperatingAdvisor of the Cobb Place Mortgage Loan (see Exhibit 34.5)

34.43      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.44      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the USAA Office Portfolio MortgageLoan (see Exhibit 34.1)

34.45      Rialto Capital Advisors, LLC, as Special Servicerof the USAA Office Portfolio Mortgage Loan (see Exhibit 34.2)

34.46      Wilmington Trust, National Association, as Trustee of the USAA Office PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.47      Citibank, N.A., as Custodian of the USAA OfficePortfolio Mortgage Loan

34.48      Park Bridge Lender Services LLC, as OperatingAdvisor of the USAA Office Portfolio Mortgage Loan (see Exhibit 34.5)

34.49      U.S. Bank National Association, as ServicingFunction Participant of the USAA Office Portfolio Mortgage Loan

34.50      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Millennium Park Plaza MortgageLoan (see Exhibit 34.1)

34.51      Rialto Capital Advisors, LLC, as Special Servicerof the Millennium Park Plaza Mortgage Loan (see Exhibit 34.2)

34.52      Wilmington Trust, National Association, as Trustee of the Millennium Park PlazaMortgage Loan (Omitted. See Explanatory Notes.)

34.53      Citibank, N.A., as Custodian of the MillenniumPark Plaza Mortgage Loan (see Exhibit 34.47)

34.54      Park Bridge Lender Services LLC, as OperatingAdvisor of the Millennium Park Plaza Mortgage Loan (see Exhibit 34.5)

34.55      U.S. Bank National Association, as ServicingFunction Participant of the Millennium Park Plaza Mortgage Loan (see Exhibit34.49)

34.56      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Wind Creek Leased Fee MortgageLoan (see Exhibit 34.1)

34.57      CWCapital Asset Management LLC, as Special Servicerof the Wind Creek Leased Fee Mortgage Loan (see Exhibit 34.9)

34.58      Wells Fargo Bank, National Association, as Trustee of the Wind Creek Leased FeeMortgage Loan (Omitted. See Explanatory Notes.)

34.59      Wells Fargo Bank, National Association, asCustodian of the Wind Creek Leased Fee Mortgage Loan (see Exhibit 34.4)

34.60      Park Bridge Lender Services LLC, as OperatingAdvisor of the Wind Creek Leased Fee Mortgage Loan (see Exhibit 34.5)

34.61      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.62      Wells Fargo Bank, National Association, as PrimaryServicer of the Midtown Center Mortgage Loan

34.63      CWCapital Asset Management LLC, as Special Servicerof the Midtown Center Mortgage Loan (see Exhibit 34.9)

34.64      Wilmington Trust, National Association, as Trustee of the Midtown CenterMortgage Loan (Omitted. See Explanatory Notes.)

34.65      Wells Fargo Bank, National Association, asCustodian of the Midtown Center Mortgage Loan (see Exhibit 34.4)

34.66      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Midtown Center Mortgage Loan

34.67      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.68      Wells Fargo Bank, National Association, as PrimaryServicer of the Century Plaza Towers Mortgage Loan (see Exhibit 34.62)

34.69      CWCapital Asset Management LLC, as Special Servicerof the Century Plaza Towers Mortgage Loan (see Exhibit 34.9)

34.70      Wilmington Trust, National Association, as Trustee of the Century Plaza TowersMortgage Loan (Omitted. See Explanatory Notes.)

34.71      Wells Fargo Bank, National Association, asCustodian of the Century Plaza Towers Mortgage Loan (see Exhibit 34.4)

34.72      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Century Plaza Towers Mortgage Loan (see Exhibit 34.66)

34.73      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.74      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 225 Bush Mortgage Loan (seeExhibit 34.1)

34.75      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the 225 Bush Mortgage Loan (seeExhibit 34.1)

34.76      Wells Fargo Bank, National Association, as Trustee of the 225 Bush MortgageLoan (Omitted. See Explanatory Notes.)

34.77      Wells Fargo Bank, National Association, asCustodian of the 225 Bush Mortgage Loan (see Exhibit 34.4)

34.78      Pentalpha Surveillance LLC, as Operating Advisorof the 225 Bush Mortgage Loan

34.79      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.80      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Legends at Village WestMortgage Loan (see Exhibit 34.1)

34.81      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Legends at Village WestMortgage Loan (see Exhibit 34.1)

34.82      Wells Fargo Bank, National Association, as Trustee of the Legends at VillageWest Mortgage Loan (Omitted. See Explanatory Notes.)

34.83      Wells Fargo Bank, National Association, asCustodian of the Legends at Village West Mortgage Loan (see Exhibit 34.4)

34.84      Pentalpha Surveillance LLC, as Operating Advisorof the Legends at Village West Mortgage Loan (see Exhibit 34.78)

34.85      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.86      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of The Essex Site 2 Mortgage Loan(see Exhibit 34.1)

34.87      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of The Essex Site 2 Mortgage Loan(see Exhibit 34.1)

34.88      Wells Fargo Bank, National Association, as Trustee of The Essex Site 2 MortgageLoan (Omitted. See Explanatory Notes.)

34.89      Wells Fargo Bank, National Association, asCustodian of The Essex Site 2 Mortgage Loan (see Exhibit 34.4)

34.90      Pentalpha Surveillance LLC, as Operating Advisorof The Essex Site 2 Mortgage Loan (see Exhibit 34.78)

34.91      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

35           Servicer compliance statements.

35.1        Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer

35.2        Rialto Capital Advisors, LLC, as Special Servicer

35.3        Wells Fargo Bank, National Association, asCertificate Administrator

35.4        Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator on andafter November 1, 2021

35.5        Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 180 Water Mortgage Loan (seeExhibit 35.1)

35.6        CWCapital Asset Management LLC, as Special Servicerof the 180 Water Mortgage Loan

35.7        Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of The Shoppes at Blackstone ValleyMortgage Loan (see Exhibit 35.1)

35.8        Rialto Capital Advisors, LLC, as Special Servicerof The Shoppes at Blackstone Valley Mortgage Loan (see Exhibit 35.2)

35.9        Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Elston Retail CollectionMortgage Loan (see Exhibit 35.1)

35.10      Rialto Capital Advisors, LLC, as Special Servicerof the Elston Retail Collection Mortgage Loan (see Exhibit 35.2)

35.11      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the PCI Pharma Portfolio MortgageLoan (see Exhibit 35.1)

35.12      Rialto Capital Advisors, LLC, as Special Servicerof the PCI Pharma Portfolio Mortgage Loan (see Exhibit 35.2)

35.13      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Broadcasting Square MortgageLoan (see Exhibit 35.1)

35.14      Rialto Capital Advisors, LLC, as Special Servicerof the Broadcasting Square Mortgage Loan (see Exhibit 35.2)

35.15      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Cobb Place Mortgage Loan (seeExhibit 35.1)

35.16      Rialto Capital Advisors, LLC, as Special Servicerof the Cobb Place Mortgage Loan (see Exhibit 35.2)

35.17      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the USAA Office Portfolio MortgageLoan (see Exhibit 35.1)

35.18      Rialto Capital Advisors, LLC, as Special Servicerof the USAA Office Portfolio Mortgage Loan (see Exhibit 35.2)

35.19      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Millennium Park Plaza MortgageLoan (see Exhibit 35.1)

35.20      Rialto Capital Advisors, LLC, as Special Servicerof the Millennium Park Plaza Mortgage Loan (see Exhibit 35.2)

35.21      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Wind Creek Leased Fee MortgageLoan (see Exhibit 35.1)

35.22      CWCapital Asset Management LLC, as Special Servicerof the Wind Creek Leased Fee Mortgage Loan (see Exhibit 35.6)

35.23      Wells Fargo Bank, National Association, as PrimaryServicer of the Midtown Center Mortgage Loan

35.24      CWCapital Asset Management LLC, as Special Servicerof the Midtown Center Mortgage Loan (see Exhibit 35.6)

35.25      Wells Fargo Bank, National Association, as PrimaryServicer of the Century Plaza Towers Mortgage Loan (see Exhibit 35.23)

35.26      CWCapital Asset Management LLC, as Special Servicerof the Century Plaza Towers Mortgage Loan (see Exhibit 35.6)

35.27      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 225 Bush Mortgage Loan (seeExhibit 35.1)

35.28      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the 225 Bush Mortgage Loan (seeExhibit 35.1)

35.29      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Legends at Village WestMortgage Loan (see Exhibit 35.1)

35.30      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Legends at Village WestMortgage Loan (see Exhibit 35.1)

35.31      Midland Loan Services, a Division of PNC Bank, NationalAssociation, as Primary Servicer of The Essex Site 2 Mortgage Loan (see Exhibit35.1)

35.32      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of The Essex Site 2 Mortgage Loan(see Exhibit 35.1)

99.1         MortgageLoan Purchase Agreement, dated and effective November 19, 2019, betweenDeutsche Mortgage & Asset Receiving Corporation and German American CapitalCorporation (filed as Exhibit 99.1 to the registrant’s Current Report on Form8-K filed on December 12, 2019 under Commission File No. 333-226943-05 andincorporated by reference herein).

99.2         MortgageLoan Purchase Agreement, dated and effective November 19, 2019, betweenDeutsche Mortgage & Asset Receiving Corporation and Goldman Sachs MortgageCompany (filed as Exhibit 99.2 to the registrant’s Current Report on Form 8-Kfiled on December 12, 2019 under Commission File No. 333-226943-05 andincorporated by reference herein).

99.3         MortgageLoan Purchase Agreement, dated and effective November 19, 2019, betweenDeutsche Mortgage & Asset Receiving Corporation and Citi Real EstateFunding Inc. (filed as Exhibit 99.3 to the registrant’s Current Report on Form8-K filed on December 12, 2019 under Commission File No. 333-226943-05 andincorporated by reference herein).

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

(c)    Not Applicable.

 

**SIGNATURES**

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

Deutsche Mortgage & AssetReceiving Corporation(Depositor)

/s/ HelaineM. Kaplan

Helaine M.Kaplan, President

(senior officer in charge ofsecuritization of the depositor)

Date: March 15, 2022

/s/ MattSmith

Matt Smith, Director

Date: March 15, 2022