Exhibit 33.19

 

 

 

Management’s Assertion on Compliance with Applicable 

Regulation AB Servicing Criteria

 

 

|   | 1. | Rialto Capital Advisors, LLC (the “Asserting Party”) is responsible for assessing compliance with the servicing criteria applicable to it under paragraph (d) of Item 1122 of Regulation AB, as of and for the 12-month period ending December 31, 2021 (the “Reporting Period”), as set forth in Appendix A hereto. The transactions covered by this report, include commercial mortgage-asset-backed securities transactions, as listed on Exhibit 1 hereto, for which the Asserting Party served as special servicer, and that were registered with the Securities and Exchange Commission pursuant to the Securities Act of 1933 (the “Platform”); |
|--------|----|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|

 

|   | 2. | The Asserting Party has engaged certain vendors, which are not servicers as defined in Item 1101(j) of Regulation AB (the “Vendors”), to perform specific, limited or scripted activities, and the Asserting Party elects to take responsibility for assessing compliance with the servicing criteria or portion of the servicing criteria applicable to such Vendors’ activities as set forth in Appendix A hereto; |
|--------|----|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|

 

|   | 3. | Except as set forth in paragraph 4 below, the Asserting Party used the criteria set forth in paragraph (d) of Item 1122 of Regulation AB to assess the compliance with the applicable servicing criteria; |
|--------|----|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|

 

|   | 4. | The criteria listed in the column titled “Inapplicable Servicing Criteria” on Appendix A hereto are inapplicable to the Asserting Party based on the activities it performs, directly or through its Vendors, with respect to the Platform; |
|--------|----|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|

 

|   | 5. | The Asserting Party has complied, in all material respects, with the applicable servicing criteria as of December 31, 2021 and for the Reporting Period with respect to the Platform taken as a whole; |
|--------|----|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|

 

|   | 6. | The Asserting Party has not identified and is not aware of any material instance of noncompliance by the Vendors with the applicable servicing criteria as of December 31, 2021 and for the Reporting Period with respect to the Platform taken as a whole; |
|--------|----|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|

 

|   | 7. | The Asserting Party has not identified any material deficiency in its policies and procedures to monitor the compliance by the Vendors with the applicable servicing criteria as of December 31, 2021 and for the Reporting Period with respect to the Platform taken as a whole; and |
|--------|----|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|

 

|   | 8. | Deloitte & Touche LLP, an independent registered public accounting firm, has issued an attestation report on the Asserting Party’s assessment of compliance with the applicable servicing criteria for the Reporting Period. |
|--------|----|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|

 

 

February 17, 2022

 

Name: Adam Singer

Title: Managing Director

 

Signature: /s/ Adam Singer

 

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|                                  |                                      |
|----------------------------------|--------------------------------------|
| Exhibit 1                        |
| Pooling and Servicing Agreements | Applicable Certification Period      |
| WFRBS 2012-C8                    | January 1, 2021 to December 31, 2021 |
| WFCM 2012-LC5                    | January 1, 2021 to December 31, 2021 |
| UBS-Barclays 2012-C3             | January 1, 2021 to December 31, 2021 |
| UBS-Barclays 2012-C4             | January 1, 2021 to December 31, 2021 |
| GSMS 2012-GCJ9                   | January 1, 2021 to December 31, 2021 |
| JPMCC 2012-LC9                   | January 1, 2021 to December 31, 2021 |
| COMM 2013-LC6                    | January 1, 2021 to December 31, 2021 |
| WFRBS 2013-C12                   | January 1, 2021 to December 31, 2021 |
| UBS-Barclays 2013-C6             | January 1, 2021 to December 31, 2021 |
| GSMS 2013-GCJ12                  | January 1, 2021 to December 31, 2021 |
| WFRBS 2013-C14                   | January 1, 2021 to December 31, 2021 |
| WFRBS 2011-C5                    | January 1, 2021 to December 31, 2021 |
| WFCM 2013-LC12                   | January 1, 2021 to December 31, 2021 |
| WFRBS 2011-C2                    | January 1, 2021 to December 31, 2021 |
| WFRBS 2011-C3                    | January 1, 2021 to December 31, 2021 |
| WFRBS 2011-C4                    | January 1, 2021 to December 31, 2021 |
| UBS-Citigroup 2011-C1            | January 1, 2021 to December 31, 2021 |
| UBSCM 2012-C1                    | January 1, 2021 to December 31, 2021 |
| WFRBS 2012-C6                    | January 1, 2021 to December 31, 2021 |
| GSMS 2011-GC3                    | January 1, 2021 to December 31, 2021 |
| COMM 2013-LC13                   | January 1, 2021 to December 31, 2021 |
| WFRBS 2013-C16                   | January 1, 2021 to December 31, 2021 |
| GSMS 2013-GCJ16                  | January 1, 2021 to December 31, 2021 |
| WFRBS 2013-C17                   | January 1, 2021 to December 31, 2021 |
| GSMS 2012-GC6                    | January 1, 2021 to December 31, 2021 |
| MSBAM 2013-C13                   | January 1, 2021 to December 31, 2021 |
| COMM 2014-CCRE14                 | January 1, 2021 to December 31, 2021 |
| MSBAM 2014-C14                   | January 1, 2021 to December 31, 2021 |
| WFRBS 2014-LC14                  | January 1, 2021 to December 31, 2021 |
| COMM 2014-LC15                   | January 1, 2021 to December 31, 2021 |
| WFRBS 2014-C20                   | January 1, 2021 to December 31, 2021 |
| COMM 2014-CCRE18                 | January 1, 2021 to December 31, 2021 |
| CGCMT 2014-GC23                  | January 1, 2021 to December 31, 2021 |

 

----

|                  |                                      |
|------------------|--------------------------------------|
| MSBAM 2014-C17   | January 1, 2021 to December 31, 2021 |
| COMM 2014-UBS5   | January 1, 2021 to December 31, 2021 |
| MSBAM 2014-C18   | January 1, 2021 to December 31, 2021 |
| COMM 2012-CCRE4  | January 1, 2021 to December 31, 2021 |
| WFRBS 2014-C24   | January 1, 2021 to December 31, 2021 |
| JPMBB 2014-C25   | January 1, 2021 to December 31, 2021 |
| LCCM 2014-909    | January 1, 2021 to December 31, 2021 |
| WFCM 2014-LC18   | January 1, 2021 to December 31, 2021 |
| COMM 2015-DC1    | January 1, 2021 to December 31, 2021 |
| GSMS 2015-GC28   | January 1, 2021 to December 31, 2021 |
| WFCM 2015-C27    | January 1, 2021 to December 31, 2021 |
| WFCM 2015-LC20   | January 1, 2021 to December 31, 2021 |
| WFCM 2015-NXS1   | January 1, 2021 to December 31, 2021 |
| CSAIL 2015-C2    | January 1, 2021 to December 31, 2021 |
| WFCM 2015-NXS2   | January 1, 2021 to December 31, 2021 |
| COMM 2015-PC1    | January 1, 2021 to December 31, 2021 |
| CSAIL 2015-C3    | January 1, 2021 to December 31, 2021 |
| WFCM 2015-SG1    | January 1, 2021 to December 31, 2021 |
| WFCM 2015-LC22   | January 1, 2021 to December 31, 2021 |
| COMM 2015-CCRE27 | January 1, 2021 to December 31, 2021 |
| WFCM 2015-NXS4   | January 1, 2021 to December 31, 2021 |
| MSCI 2015-UBS8   | January 1, 2021 to December 31, 2021 |
| CSAIL 2016-C5    | January 1, 2021 to December 31, 2021 |
| WFCM 2016-C32    | January 1, 2021 to December 31, 2021 |
| WFCM 2016-NXS5   | January 1, 2021 to December 31, 2021 |
| CGCMT 2015-GC27  | January 1, 2021 to December 31, 2021 |
| WFCM 2016-C33    | January 1, 2021 to December 31, 2021 |
| MSBAM 2015-C20   | January 1, 2021 to December 31, 2021 |
| CFCRE 2016-C4    | January 1, 2021 to December 31, 2021 |
| BACM 2016-UBS10  | January 1, 2021 to December 31, 2021 |
| SGCMS 2016-C5    | January 1, 2021 to December 31, 2021 |
| WFCM 2016-BNK1   | January 1, 2021 to December 31, 2021 |
| CD 2016-CD1      | January 1, 2021 to December 31, 2021 |
| GSMS 2016-GS3    | January 1, 2021 to December 31, 2021 |
| MSBAM 2016-C31   | January 1, 2021 to December 31, 2021 |
| CGCMT 2016-C3    | January 1, 2021 to December 31, 2021 |
| CFCRE 2016-C6    | January 1, 2021 to December 31, 2021 |

 

----

|                 |                                      |
|-----------------|--------------------------------------|
| CSAIL 2016-C7   | January 1, 2021 to December 31, 2021 |
| MSCI 2016-UBS12 | January 1, 2021 to December 31, 2021 |
| BBCMS 2017-C1   | January 1, 2021 to December 31, 2021 |
| GSMS 2017-GS5   | January 1, 2021 to December 31, 2021 |
| CGCMT 2017-P7   | January 1, 2021 to December 31, 2021 |
| BANK 2017-BNK4  | January 1, 2021 to December 31, 2021 |
| CD 2017-CD4     | January 1, 2021 to December 31, 2021 |
| CFCRE 2017-C8   | January 1, 2021 to December 31, 2021 |
| JPMCC 2017-JP6  | January 1, 2021 to December 31, 2021 |
| CD 2017-CD5     | January 1, 2021 to December 31, 2021 |
| GSMS 2017-GS7   | January 1, 2021 to December 31, 2021 |
| BANK 2017-BNK7  | January 1, 2021 to December 31, 2021 |
| CSAIL 2017-CX9  | January 1, 2021 to December 31, 2021 |
| UBSCM 2017-C4   | January 1, 2021 to December 31, 2021 |
| UBSCM 2017-C6   | January 1, 2021 to December 31, 2021 |
| BANK 2017-BNK9  | January 1, 2021 to December 31, 2021 |
| GSMS 2018-GS9   | January 1, 2021 to December 31, 2021 |
| UBSCM 2018-C9   | January 1, 2021 to December 31, 2021 |
| MSBAM 2012-C5   | January 1, 2021 to December 31, 2021 |
| WFCM 2018-C44   | January 1, 2021 to December 31, 2021 |
| UBSCM 2018-C10  | January 1, 2021 to December 31, 2021 |
| WFCM 2015-C30   | January 1, 2021 to December 31, 2021 |
| JPMBB 2014-C23  | January 1, 2021 to December 31, 2021 |
| MSBAM 2014-C19  | January 1, 2021 to December 31, 2021 |
| COMM 2015-LC21  | January 1, 2021 to December 31, 2021 |
| MSBAM 2016-C29  | January 1, 2021 to December 31, 2021 |
| JPMBB 2015-C31  | January 1, 2021 to December 31, 2021 |
| GSMS 2018-GS10  | January 1, 2021 to December 31, 2021 |
| CD 2018-CD7     | January 1, 2021 to December 31, 2021 |
| GSMS 2018-3PCK  | January 1, 2021 to December 31, 2021 |
| BANK 2018-BNK14 | January 1, 2021 to December 31, 2021 |
| DBGS 2018-C1    | January 1, 2021 to December 31, 2021 |
| CSAIL 2018-C14  | January 1, 2021 to December 31, 2021 |
| UBSCM 2018-C14  | January 1, 2021 to December 31, 2021 |
| ILPT 2019-SURF  | January 1, 2021 to December 31, 2021 |
| MSCI 2019-L2    | January 1, 2021 to December 31, 2021 |
| WFCM 2019-C50   | January 1, 2021 to December 31, 2021 |

 

----

|                  |                                        |
|------------------|----------------------------------------|
| BANK 2019-BNK18  | January 1, 2021 to December 31, 2021   |
| WFCM 2015-P2     | January 1, 2021 to December 31, 2021   |
| BMARK 2019-B11   | January 1, 2021 to December 31, 2021   |
| CGCMT 2019-GC41  | January 1, 2021 to December 31, 2021   |
| BBCMS 2019-C4    | January 1, 2021 to December 31, 2021   |
| COMM 2014-CCRE15 | January 1, 2021 to December 31, 2021   |
| UBSCM 2019-C17   | January 1, 2021 to December 31, 2021   |
| BANK 2019-BNK21  | January 1, 2021 to December 31, 2021   |
| CGCMT 2019-GC43  | January 1, 2021 to December 31, 2021   |
| CSAIL 2019-C18   | January 1, 2021 to December 31, 2021   |
| COMM 2019-GC44   | January 1, 2021 to December 31, 2021   |
| UBSCM 2019-C18   | January 1, 2021 to December 31, 2021   |
| WFCM 2020-C55    | January 1, 2021 to December 31, 2021   |
| UBSBB 2012-C2    | January 1, 2021 to December 31, 2021   |
| BBCMS 2020-C7    | January 1, 2021 to December 31, 2021   |
| CSMC 2020-NET    | January 1, 2021 to December 31, 2021   |
| BMARK 2020-B19   | January 1, 2021 to December 31, 2021   |
| BMARK 2020-B22   | January 1, 2021 to December 31, 2021   |
| CSMC 2020-FACT   | January 1, 2021 to December 31, 2021   |
| CLNY 2019-IKPR   | January 1, 2021 to December 31, 2021   |
| BANK 2020-BNK29  | January 1, 2021 to December 31, 2021   |
| WFCM 2020-C58    | January 1, 2021 to December 31, 2021   |
| FSRIA 2019-FL1   | January 1, 2021 to December 31, 2021   |
| BANK 2021-BNK32  | March 24, 2021 to December 31, 2021    |
| BSST 2021-1818   | March 30, 2021 to December 31, 2021    |
| BMARK 2021-B25   | April 29, 2021 to December 31, 2021    |
| FSRIA 2021-FL2   | May 5, 2021 to December 31, 2021       |
| MSC 2007-T27     | May 19, 2021 to December 31, 2021      |
| BANK 2021-BNK33  | May 20, 2021 to December 31, 2021      |
| BBCMS 2021-C10   | July 15, 2021 to December 31, 2021     |
| CSMC 2021-ADV    | August 5, 2021 to December 31, 2021    |
| BANK 2021-BNK36  | October 7, 2021 to December 31, 2021   |
| FSRIA 2021-FL3   | November 4, 2021 to December 31, 2021  |
| BACM 2017-BNK3   | November 15, 2021 to December 31, 2021 |
| BMARK 2021-B31   | December 22, 2021 to December 31, 2021 |

 

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APPENDIX A

|                    |                                                                                                                                                                                                                                                                   |                           |                                 |  |
|--------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------|---------------------------------|--|
| Servicing Criteria |                                                                                                                                                                                                                                                              |                      |
| Reference          | Criteria                                                                                                                                                                                                                                                          | Performed by Servicer     | Inapplicable Servicing Criteria |
|               | General Servicing Considerations                                                                                                                                                                                                                                  |                      |                            |
| 1122(d)(1)(i)      | Policies and procedures are instituted to monitor any performance or other triggers and events of default in accordance with the transaction agreements.                                                                                                          | X                         |                            |
| 1122(d)(1)(ii)     | If any material servicing activities are outsourced to third parties, policies and procedures are instituted to monitor the third party’s performance and compliance with such servicing activities.                                                        |  

X1                |                            |
| 1122(d)(1)(iii)    | Any requirements in the transaction agreements to maintain a back-up servicer for the pool assets are maintained.                                                                                                                                                 |                      | X                               |
| 1122(d)(1)(iv)     | A fidelity bond and errors and omissions policy is in effect on the party participating in the servicing function throughout the reporting period in the amount of coverage required by and otherwise in accordance with the terms of the transaction agreements. |  

 

X

  |                            |
| 1122(d)(i)(v)      | Aggregation of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information.                                                                                                                           |  

X

          |                            |

 

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|                 |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                           |        |
|-----------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------|--------|
|            | Cash Collection and Administration                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |                                      |   |
| 1122(d)(2)(i)   | Payments on pool assets are deposited into the appropriate custodial bank accounts and related bank clearing accounts no more than two business days following receipt, or such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                        |  

 

X                         |   |
| 1122(d)(2)(ii)  | Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                      | X3     |
| 1122(d)(2)(iii) | Advances of funds or guarantees regarding collections, cash flows or distributions, and any interest or other fees charged for such advances, are made, reviewed and approved as specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |                                           | X3     |
| 1122(d)(2)(iv)  | The related accounts for the transaction, such as cash reserve accounts or accounts established as a form of overcollateralization, are separately maintained (e.g., with respect to commingling of cash) as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                |  

X                                 |   |
| 1122(d)(2)(v)   | Each custodial account is maintained at a federally insured depository institution as set forth in the transaction agreements. For purposes of this criterion, “federally insured depository institution” with respect to a foreign financial institution means a foreign financial institution that meets the requirements of Rule 13k-1(b)(1) of the Securities Exchange Act.                                                                                                                                                                                                                                                                                                          |  

 

 

X                 |   |
| 1122(d)(2)(vi)  | Unissued checks are safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | X                                         |   |
| 1122(d)(2)(vii) | Reconciliations are prepared on a monthly basis for all asset-backed securities related bank accounts, including custodial accounts and related bank clearing accounts. These reconciliations are (A) mathematically accurate; (B) prepared within 30 calendar days after the bank statement cutoff date, or such other number of days specified in the transaction agreements; (C) reviewed and approved by someone other than the person who prepared the reconciliation; and (D) contain explanations for reconciling items. These reconciling items are resolved within 90 calendar days of their original identification, or such other number of days specified in the transaction agreements. |  

 

 

 

 

X |   |

 

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|                 |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |        |        |
|-----------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------|--------|
|            | Investor Remittances and Reporting                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |   |   |
| 1122(d)(3)(i)   | Reports to investors, including those to be filed with the Commission, are maintained in accordance with the transaction agreements and applicable Commission requirements. Specifically, such reports (A) are prepared in accordance with timeframes and other terms set forth in the transaction agreements; (B) provide information calculated in accordance with the terms specified in the transaction agreements; (C) are filed with the Commission as required by its rules and regulations; and (D) agree with investors’ or the trustee’s records as to the total unpaid principal balance and number of pool assets serviced by the Servicer. | X4     |   |
| 1122(d)(3)(ii)  | Amounts due to investors are allocated and remitted in accordance with timeframes, distribution priority and other terms set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |   | X      |
| 1122(d)(3)(iii) | Disbursements made to an investor are posted within two business days to the Servicer’s investor records, or such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |   | X      |
| 1122(d)(3)(iv)  | Amounts remitted to investors per the investor reports agree with cancelled checks, or other form of payment, or custodial bank statements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |   | X      |

 

 

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|                  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                           |        |
|------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------|--------|
|             | Pool Asset Administration                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |                                      |   |
| 1122(d)(4)(i)    | Collateral or security on Pool assets is maintained as required by the transaction agreements or related mortgage loan documents.                                                                                                                                                                                                                                                                                                                                                                                    |  

X                                 |   |
| 1122(d)(4)(ii)   | Pool asset and related documents are safeguarded as required by the transaction agreements                                                                                                                                                                                                                                                                                                                                                                                                                           | X                                         |   |
| 1122(d)(4)(iii)  | Any additions, removals or substitutions to the asset pool are made, reviewed and approved in accordance with any conditions or requirements in the transaction agreements.                                                                                                                                                                                                                                                                                                                                          | X                                         |   |
| 1122(d)(4)(iv)   | Payments on pool assets, including any payoffs, made in accordance with the related pool asset documents are posted to the Servicer’s obligor records maintained no more than two business days after receipt, or such other number of days specified in the transaction agreements, and allocated to principal, interest or other items (e.g., escrow) in accordance with the related pool asset documents.                                                                                                   |  

X2                                |   |
| 1122(d)(4)(v)    | The Servicer’s records regarding the pool assets agree with the Servicer’s records with respect to an obligor’s unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                          |                                      | X      |
| 1122(d)(4)(vi)   | Changes with respect to the terms or status of an obligor's pool assets (e.g., loan modifications or re-agings) are made, reviewed and approved by authorized personnel in accordance with the transaction agreements and related pool asset documents.                                                                                                                                                                                                                                                              | X                                         |   |
| 1122(d)(4)(vii)  | Loss mitigation or recovery actions (e.g., forbearance plans, modifications and deeds in lieu of foreclosure, foreclosures and repossessions, as applicable) are initiated, conducted and concluded in accordance with the timeframes or other requirements established by the transaction agreements.                                                                                                                                                                                                               |  

 

X                         |   |
| 1122(d)(4)(viii) | Records documenting collection efforts are maintained during the period a pool asset is delinquent in accordance with the transaction agreements. Such records are maintained on at least a monthly basis, or such other period specified in the transaction agreements, and describe the entity’s activities in monitoring delinquent pool assets including, for example, phone calls, letters and payment rescheduling plans in cases where delinquency is deemed temporary (e.g., illness or unemployment). |  

 

 

 

 

X |   |
| 1122(d)(4)(ix)   | Adjustments to interest rates or rates of return for pool assets with variable rates are computed based on the related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                         |                                      | X      |

 

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|                  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             |                |           |
|------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------|-----------|
| 1122(d)(4)(x)    | Regarding any funds held in trust for an obligor (such as escrow accounts): (A) such funds are analyzed, in accordance with the obligor’s pool asset documents, on at least an annual basis, or such other period specified in the transaction agreements; (B) interest on such funds is paid, or credited, to obligors in accordance with applicable pool asset documents and state laws; and (C) such funds are returned to the obligor within 30 calendar days of full repayment of the related pool assets, or such other number of days specified in the transaction agreements. |           | X         |
| 1122(d)(4)(xi)   | Payments made on behalf of an obligor (such as tax or insurance payments) are made on or before the related penalty or expiration dates, as indicated on the appropriate bills or notices for such payments, provided that such support has been received by the Servicer at least 30 calendar days prior to these dates, or such other number of days specified in the transaction agreements.                                                                                                                                                                                             |           | X         |
| 1122(d)(4)(xii)  | Any late payment penalties in connection with any payment to be made on behalf of an obligor are paid from the Servicer’s funds and not charged to the obligor, unless the late payment was due to the obligor’s error or omission.                                                                                                                                                                                                                                                                                                                                             |           | X         |
| 1122(d)(4)(xiii) | Disbursements made on behalf of an obligor are posted within two business days to the obligor’s records maintained by the Servicer, or such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                             |           | X         |
| 1122(d)(4)(xiv)  | Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                            |  

  | X

  |
| 1122(d)(4)(xv)   | Any external enhancement or other support, identified in Item 1114(a)(1) through (3) or Item 1115 of Regulation AB, is maintained as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                               |           | X         |

X1- Rialto Capital Advisors, LLC performs the activities pertaining to this criterion, except for specific, limited activities performed by (a) its third-party property managers relating to REO Property, if any; and (b) RERC, LLC, a SitusAMC Company, pursuant to a Staffing Agreement, in which RERC provides RCA with real estate consultant and valuation professionals to perform support functions in connection with property appraisals. Rialto has elected to take responsibility for assessing compliance with these servicing criteria with respect to the activities of its third-party property managers and RERC, LLC.

X2-Primary responsibility for processing borrower payments rests with the Master Servicer, however, Rialto Capital Advisors, LLC may from time to time receive payments on an exception basis which are forwarded to the Master Servicer in accordance with such criteria. The criteria is marked applicable as Rialto Capital Advisors, LLC had instances or activity relating to this criteria for the calendar year of January 1, 2021 to December 31, 2021. 

X3-Rialto Capital Advisors, LLC performs the activities under the criteria, however the related criteria are marked inapplicable as Rialto did not have instances/activity during the calendar year of January 1, 2021 and ending on December 31, 2021 relating to the criteria.   

 

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X4-Only items (A) and (B) of the Servicing Criteria are applicable to Rialto Capital Advisors, LLC as special servicer.  Items (C) and (D) are inapplicable as the responsibility for filing reports with the Commission and agreeing totals to the Servicer records rests with the Trustee and/or Certificate Administrator, as applicable.