**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, 2023or**

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

**For the transition period from _____ to _____Commission file number of the issuing entity: 333-228375-03**

**Central Index Key Number of the issuing entity:0001793165**

**BANK 2019-BNK24**

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

** **

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

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

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

** **

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

**Bank of America, NationalAssociation**

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

** **

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

**Morgan Stanley Mortgage CapitalHoldings LLC**

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

** **

**Central Index Key Number of the sponsor: 0000740906**

**Wells Fargo Bank, NationalAssociation**

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

** **

**Central Index Key Number of the sponsor: 0001577313**

**National Cooperative Bank, N.A.**

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

** **

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

**the issuing entity)** | **38-4129068**

**38-4129069**

**38-7235634**

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

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

**c/o Computershare Trust Company, National Association, as agent for**

**Wells Fargo Bank, National Association**

**as Certificate Administrator**

**9062 Old Annapolis Road**

**Columbia, MD**

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

**21045**

**(Zip Code)**

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

**(646) 855-3953**

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

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

 

 

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

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

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

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

Indicate by check mark whether the registrant has submittedelectronically every Interactive Data File required to be submitted pursuant toRule 405 of Regulation S-T (Section 232.405 of this chapter) during thepreceding 12 months (or for such shorter period that the registrant wasrequired to submit such files).

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          ⌧                                                                                                      Smaller reporting company                    o

                                                                                                                                                       Emerging growthcompany                    o

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

Indicate by check mark whether the registrant 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

If securities are registered pursuant to Section 12(b) of theAct, indicate by check mark whether the financial statements of the registrantincluded in the filing reflect the correction of an error to previously issuedfinancial statements. o

Indicate by check mark whether any of those error correctionsare restatements that required a recovery analysis of incentive-basedcompensation received by any of the registrant’s executive officers during therelevant recovery period pursuant to §240.10D-1(b). o

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

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

Not applicable.

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

Not applicable.

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

Not applicable.

**DOCUMENTS INCORPORATED BY REFERENCE**

** **

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

Not applicable.

 

** **

**EXPLANATORY NOTES**

The 1412 Broadway Mortgage Loan, whichconstituted approximately 8.2% of the asset pool of the issuing entity as ofits cut-off date, is an asset of the issuing entity and is part of a loancombination that includes the 1412 Broadway Mortgage Loan and two other *paripassu* loans, which are not assets of the issuing entity. This loancombination, including the 1412 Broadway Mortgage Loan, is 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 Park Tower at Transbay Mortgage Loan, whichconstituted approximately 4.1% of the asset pool of the issuing entity as ofits cut-off date.  The Park Tower at Transbay Mortgage Loan is an asset ofthe issuing entity and is part of a loan combination that includes the ParkTower at Transbay Mortgage Loan and nine other *pari passu* loans, whichare not assets of the issuing entity. A *pari passu* portion of the loancombination was securitized in the BANK 2019-BNK21 transaction, Commission FileNumber 333-228375-02 (the “BANK 2019-BNK21 Transaction”). This loancombination, including the Park Tower at Transbay Mortgage Loan, is beingserviced and administered pursuant to the pooling and servicing agreement forthe BANK 2019-BNK21 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 the ExhibitIndex) with respect to the Jackson Park Mortgage Loan, which constitutedapproximately 8.2% of the asset pool of the issuing entity as of its cut-offdate.  The Jackson Park Mortgage Loan is an asset of the issuing entityand is part of a loan combination that includes the Jackson Park Mortgage Loanand eight other *pari passu* loans and two subordinate companion loans,which are not assets of the issuing entity. A *pari passu* portion of theloan combination was securitized in the Jackson Park Trust 2019-LIC transaction(the “JAX 2019-LIC Transaction”). This loan combination, including theJackson Park Mortgage Loan, is being serviced and administered pursuant to thetrust and servicing agreement for the JAX 2019-LIC 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 Parklawn Building Mortgage Loan and the ILPTIndustrial Portfolio Mortgage Loan, which constituted approximately 5.3% and2.0%, respectively, of the asset pool of the issuing entity as of its cut-offdate.  The Parklawn Building Mortgage Loan and the ILPT IndustrialPortfolio Mortgage Loan are each an asset of the issuing entity and are eachpart of a loan combination that includes (a) with respect to the ParklawnBuilding Mortgage Loan, four other *pari passu* loans, which are notassets of the issuing entity or (b) with respect to the ILPT IndustrialPortfolio Mortgage Loan, seven other *pari passu* loans and twelvesubordinate companion loans, which are not assets of the issuing entity. A *paripassu* portion of each loan combination was securitized in the MorganStanley Capital I Trust 2019-L3 transaction, Commission File Number333-227446-07 (the “MSC 2019-L3 Transaction”). These loan combinations,including the Parklawn Building Mortgage Loan and the ILPT Industrial PortfolioMortgage Loan, are being serviced and administered pursuant to the pooling andservicing agreement for the MSC 2019-L3 Transaction, which is incorporated byreference as Exhibit 4.4 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 55 Hudson Yards Mortgage Loan, whichconstituted approximately 8.2% of the asset pool of the issuing entity as ofits cut-off date.  The 55 Hudson Yards Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the 55 HudsonYards Mortgage Loan, thirty-one other *pari passu* loans and threesubordinate companion loans, which are not assets of the issuing entity. A *paripassu* portion of the loan combination was securitized in the Hudson Yards2019-55HY Mortgage Trust transaction (the “Hudson Yards 2019-55HYTransaction”). This loan combination, including the 55 Hudson YardsMortgage Loan, is being serviced and administered pursuant to the trust andservicing agreement for the Hudson Yards 2019-55HY Transaction, which isincorporated by reference as Exhibit 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 Giant Anchored Portfolio Mortgage Loan,which constituted approximately 2.4% of the asset pool of the issuing entity asof its cut-off date.  The Giant Anchored Portfolio Mortgage Loan is anasset of the issuing entity and is part of a loan combination that includes theGiant Anchored Portfolio Mortgage Loan and three other *pari passu* loans,which are not assets of the issuing entity. A *pari passu* portion of theloan combination was securitized in the Citigroup Commercial Mortgage Trust2019-C7 transaction, Commission File Number 333-228597-05 (the “CGCMT2019-C7 Transaction”). This loan combination, including the Giant AnchoredPortfolio Mortgage Loan, is being serviced and administered pursuant to thepooling and servicing agreement for the CGCMT 2019-C7 Transaction, which isincorporated by reference as Exhibit 4.6 to this Annual Report on Form 10-K.

The master servicer of a poolingand servicing agreement or trust and servicing agreement also functions as the primaryservicer of the related mortgage loans serviced and administered pursuant tosuch agreement unless a separate primary servicer is identified herein. If this report does not identify a separate primary servicer, the servicercompliance statement provided by the master servicer under any such agreementalso encompasses its responsibilities as primary servicer of the relatedmortgage loan or mortgage loans.

Wells Fargo Bank, NationalAssociation is the general master servicer (exceptwith respect to those mortgage loans for which National Cooperative Bank, N.A.is the master servicer) and certificate administrator of the mortgage loansserviced under the Pooling and Servicing Agreement and the primary servicer ofthe 55 Hudson Yards Mortgage Loan, the Jackson Park Mortgage Loan, thePark Tower at Transbay Mortgage Loan, the Giant Anchored Portfolio MortgageLoan and the ILPT Industrial Portfolio Mortgage Loan. As a result, Wells FargoBank, National Association is a “servicer” as defined in Item 1108(a)(2)(iii)of Regulation AB, in the capacities described above, because it is servicingmortgage loans that constituted 10% or more of the assets of the issuing entityas of its cut-off date. The assessments of compliance with applicable servicingcriteria, accountants’ attestation reports and servicer compliance statementsdelivered by Wells Fargo Bank, National Association in the capacities describedabove are listed in the Exhibit Index.

Wells Fargo Bank, NationalAssociation is the custodian of the mortgage loans serviced under the Poolingand Servicing Agreement, the 55 Hudson Yards MortgageLoan, the Jackson Park Mortgage Loan, the Parklawn Building MortgageLoan, the Park Tower at Transbay Mortgage Loan and the ILPT IndustrialPortfolio Mortgage Loan.  As a result, Wells Fargo Bank, NationalAssociation 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 Wells Fargo Bank, National Association in the capacitiesdescribed above are listed in the Exhibit Index.

LNR Partners, LLC is the general special servicer (exceptwith respect to those mortgage loans for which National Cooperative Bank, N.A.is the special servicer) of the mortgage loans serviced under the Pooling andServicing Agreement, the Parklawn Building Mortgage Loan and the Giant AnchoredPortfolio Mortgage Loan. As a result, LNR Partners, LLCis 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 LNR Partners, LLC in the capacities described above are listed in theExhibit Index.

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

Situs Holdings, LLC is the specialservicer of the Jackson Park Mortgage Loan and the ILPT Industrial PortfolioMortgage Loan.  As a result, Situs Holdings, 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 Situs Holdings, LLC in thecapacities described above are listed in the Exhibit Index.

Wilmington Trust, NationalAssociation acts as trustee of the mortgage loans serviced under the Poolingand Servicing Agreement, the Park Tower at Transbay Mortgage Loan, the JacksonPark Mortgage Loan, the Parklawn Building Mortgage Loan, the ILPT IndustrialPortfolio Mortgage Loan, the 55 Hudson Yards Mortgage Loan and the GiantAnchored Portfolio Mortgage Loan.  Pursuant to the Pooling and ServicingAgreement, the pooling and servicing agreement for the BANK 2019-BNK21Transaction, the trust and servicing agreement for the JAX 2019-LICTransaction, the pooling and servicing agreement for the MSC 2019-L3Transaction, the trust and servicing agreement for the Hudson Yards 2019-55HYTransaction and the pooling and servicing agreement for the CGCMT 2019-C7Transaction, the trustee is required to provide an assessment of compliancewith applicable servicing criteria solely with respect to Item 1122(d)(2)(iii)of Regulation AB (regarding advances of funds or guarantees regardingcollections, cash flows or distributions, and any interest or other feescharged for such advances, are made, reviewed and approved as specified in thetransaction agreements). However, during the reporting period, the trustee didnot 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 mortgage loans serviced under the Pooling and Servicing Agreement, the ParkTower at Transbay Mortgage Loan, the Jackson Park Mortgage Loan, the ParklawnBuilding Mortgage Loan, the ILPT Industrial Portfolio Mortgage Loan, the 55Hudson Yards Mortgage Loan and the Giant Anchored Portfolio Mortgage Loan havedelivered 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 master servicer under the Pooling and ServicingAgreement and the primary servicer of the Jackson Park Mortgage Loan, the ParkTower at Transbay Mortgage Loan, the ILPT Industrial Portfolio Mortgage Loan,the 55 Hudson Yards Mortgage Loan and the Giant Anchored Portfolio MortgageLoan to remit tax payments received from the escrow accounts of borrowers tolocal taxing authorities, to report tax amounts due, to verify tax parcelinformation, and to verify non-escrow tax payments. These servicing functionsare included within the servicing criteria set forth in Items 1122(d)(4)(xi)and 1122(d)(4)(xii) of Regulation AB.  Therefore, under theprinciples-based definition of “servicer” set forth in Item 1101(j) ofRegulation AB that looks to the functions that an entity performs, this vendoris a “servicer” for the purposes of Item 1122 of Regulation 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 Park Tower at Transbay Mortgage Loan, the Jackson ParkMortgage Loan, the ILPT Industrial Portfolio Mortgage Loan, the 55 Hudson YardsMortgage Loan, the Parklawn Building Mortgage Loan and the Giant AnchoredPortfolio Mortgage Loan are omitted from this Annual Report on Form 10-K as thecertificate administrator pursuant to the related pooling and servicingagreement or trust and servicing agreement does not perform any activities thataddress servicing criteria with respect to the issuing entity and because theyare each not a “servicer” that meets the criteria in Item 1108(a)(2)(i) through(iii) of Regulation AB.

With respect to the *pari passu*loan combinations that include the Parklawn Building Mortgage Loan, the ParkTower at Transbay Mortgage Loan, the 55 Hudson Yards Mortgage Loan and theGiant Anchored Portfolio Mortgage Loan, (i) the reports on assessment ofcompliance with servicing criteria and attestation reports on assessment of compliancewith servicing criteria of Rialto Capital Advisors, LLC as special servicer ofthe Park Tower at Transbay Mortgage Loan, Citibank, N.A. as custodian of theGiant Anchored Portfolio Mortgage Loan and Pentalpha Surveillance LLC asoperating advisor of the Giant Anchored Portfolio Mortgage Loan, listed on theExhibit Index are omitted from this Annual Report on Form 10-K as they are notrequired to be included on this Annual Report on Form 10-K per Instruction 3 toItem 1122 of Regulation AB because they are parties performing activities thataddress servicing criteria relating to 5% or less of the assets of the issuingentity; and (ii) the servicer compliance statements of Rialto Capital Advisors,LLC as special servicer of the Park Tower at Transbay Mortgage Loan, KeyBankNational Association as primary servicer of the Parklawn Building Mortgage Loanand CWCapital Asset Management LLC as special servicer of the 55 Hudson YardsMortgage Loan, listed on the Exhibit Index are omitted from this Annual Reporton Form 10-K as they are not required by Item 1123 of Regulation AB to beincluded on this Annual Report on Form 10-K because they are each anunaffiliated party that is not a “servicer” that meets the criteria in Item1108(a)(2)(i) through (iii) of Regulation AB.

**PART I**

**Item 1.  Business.**

Omitted.

**Item 1A.  Risk Factors.**

Omitted.

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

None.

**Item 1C.  Cybersecurity.**

Omitted.

**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. **

[Reserved]

**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.

**Item 9C.  Disclosure Regarding Foreign Jurisdictionsthat Prevent Inspections.**

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 Accountant Fees and Services.**

Omitted.

**ADDITIONAL DISCLOSURE ITEMS FOR REGULATION AB**

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

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

 

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

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

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

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

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

The registrant knows of no materialpending legal proceeding involving the trust or any party related to the trust,other than routine litigation incidental to the duties of those respectiveparties, and the following, with respect to Wells Fargo Bank, NationalAssociation, as certificate administrator and as custodian.

In December 2014, Phoenix Light SF Limited (Phoenix Light)and certain related entities filed a complaint in the United States DistrictCourt for the Southern District of New York alleging claims against Wells FargoBank, N.A., in its capacity as trustee for a number of residentialmortgage-backed securities (RMBS) trusts. Complaints raising similarallegations have been filed by Commerzbank AG in the Southern District of NewYork, IKB International and IKB Deutsche Industriebank (together, IKB) in NewYork state court, and Park Royal I LLC and Park Royal II LLC in New York statecourt. In each case, the plaintiffs allege that Wells Fargo Bank, N.A., astrustee, caused losses to investors, and plaintiffs assert causes of actionbased upon, among other things, the trustee’s alleged failure to notify andenforce repurchase obligations of mortgage loan sellers for purported breachesof representations and warranties, notify investors of alleged events ofdefault, and abide by appropriate standards of care following alleged events ofdefault. In July 2022, the district court dismissed Phoenix Light’s claims andcertain of the claims asserted by Commerzbank AG, and subsequently enteredjudgment in each case in favor of Wells Fargo Bank, N.A. In August 2022,Phoenix Light and Commerzbank AG each appealed the district court’s decision tothe United States Court of Appeals for the Second Circuit. Phoenix Lightdismissed its appeal in May 2023, terminating its case. In November 2023, WellsFargo Bank, N.A. entered into an agreement with IKB to resolve IKB’s claims.Wells Fargo Bank, N.A. previously settled two class actions filed byinstitutional investors and an action filed by the National Credit UnionAdministration with similar allegations.

**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 19, 2019 pursuant to Rule 424(b)(2).

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

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the mortgage loans are attachedhereto under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit Zto the Pooling and Servicing Agreement incorporated by reference as Exhibit 4.1to this Annual Report on Form 10-K is a chart identifying the entitiesparticipating in a servicing function for the transaction responsible for eachapplicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Park Tower at Transbay MortgageLoan, which is being serviced and administered pursuant to the pooling andservicing agreement for the BANK 2019-BNK21 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit Z to thepooling and servicing agreement for the BANK 2019-BNK21 Transactionincorporated by reference as Exhibit 4.2 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theBANK 2019-BNK21 Transaction responsible for each applicable servicing criteriaset 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 Jackson Park Mortgage Loan, whichis being serviced and administered pursuant to the trust and servicing agreementfor the JAX 2019-LIC Transaction, are attached hereto under Item 15 to thisAnnual Report on Form 10-K. Attached as Exhibit K to the trust and servicingagreement for the JAX 2019-LIC Transaction incorporated by reference as Exhibit4.3 to this Annual Report on Form 10-K is a chart identifying the entitiesparticipating in a servicing function for the JAX 2019-LIC 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 Parklawn Building Mortgage Loanand the ILPT Industrial Portfolio Mortgage Loan, which are being serviced andadministered pursuant to the pooling and servicing agreement for the MSC2019-L3 Transaction, are attached hereto under Item 15 to this Annual Report onForm 10-K. Attached as Exhibit AA to the pooling and servicing agreement forthe MSC 2019-L3 Transaction incorporated by reference as Exhibit 4.4 to thisAnnual Report on Form 10-K is a chart identifying the entities participating ina servicing function for the MSC 2019-L3 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 55 Hudson Yards Mortgage Loan,which is being serviced and administered pursuant to the trust and servicingagreement for the Hudson Yards 2019-55HY Transaction, are attached hereto underItem 15 to this Annual Report on Form 10-K. Attached as Schedule I to the trustand servicing agreement for the Hudson Yards 2019-55HY Transaction incorporatedby reference as Exhibit 4.5 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the HudsonYards 2019-55HY Transaction responsible for each applicable servicing criteriaset 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 Giant Anchored Portfolio MortgageLoan, which is being serviced and administered pursuant to the pooling andservicing agreement for the CGCMT 2019-C7 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit O to thepooling and servicing agreement for the CGCMT 2019-C7 Transaction incorporatedby reference as Exhibit 4.6 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the CGCMT2019-C7 Transaction responsible for each applicable servicing criteria set forthin Item 1122(d).

**Item1123 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. Exhibit and 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 and effective as of December 1, 2019, among Bancof America Merrill Lynch Commercial Mortgage Inc., as Depositor, Wells FargoBank, National Association, as General Master Servicer, Midland Loan Services,a Division of PNC Bank, National Association, as General Special Servicer,National Cooperative Bank, N.A., as NCB Master Servicer and as NCB SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Park Bridge LenderServices LLC, as Operating Advisor and as Asset Representations Reviewer (filedas Exhibit 4.1 to the registrant’s Current Report on Form 8-K filed on December19, 2019 under Commission File No. 333-228375-03 and incorporated by referenceherein).

4.2          Poolingand Servicing Agreement, dated and effective as of October 1, 2019, among Bancof America Merrill Lynch Commercial Mortgage Inc., as Depositor, Wells FargoBank, National Association, as Master Servicer, Rialto Capital Advisors, LLC,as Special Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator, Wilmington Trust, National Association, as Trustee, and ParkBridge Lender Services LLC, as Operating Advisor and as Asset RepresentationsReviewer (filed as Exhibit 4.5 to the registrant’s Current Report on Form 8-Kfiled on December 19, 2019 under Commission File No. 333-228375-03 andincorporated by reference herein).

4.3          Trustand Servicing Agreement, dated as of November 15, 2019, among Banc of AmericaMerrill Lynch Large Loan, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Servicer, AEGON USA Realty Advisors, LLC, as Special Servicer,Wilmington Trust, National Association, as Trustee, and Wells Fargo Bank,National Association, as Certificate Administrator (filed as Exhibit 4.3 to theregistrant’s Current Report on Form 8-K filed on December 19, 2019 underCommission File No. 333-228375-03 and incorporated by reference herein).

4.4          Poolingand Servicing Agreement, dated and effective as of November 1, 2019, betweenMorgan Stanley Capital I Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, LNR Partners, LLC, as General SpecialServicer, Situs Holdings, LLC, as ILPT Industrial Portfolio Special Servicer,Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Park Bridge LenderServices LLC, as Operating Advisor and as Asset Representations Reviewer (filedas Exhibit 4.4 to the registrant’s Current Report on Form 8-K/A filed onJanuary 6, 2020 under Commission File No. 333-228375-03 and incorporated byreference herein).

4.5          Trustand Servicing Agreement, dated as of December 6, 2019, between Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, CWCapital Asset Management LLC, as SpecialServicer, Wilmington Trust, National Association, as Trustee, and Wells FargoBank, National Association, as Certificate Administrator, as Paying Agent andas Custodian (filed as Exhibit 4.2 to the registrant’s Current Report on Form8-K filed on December 19, 2019 under Commission File No. 333-228375-03 andincorporated by reference herein).

4.6          Poolingand Servicing Agreement, dated as of December 1, 2019, among CitigroupCommercial Mortgage Securities Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, LNR Partners, LLC, as Special Servicer,Pentalpha Surveillance LLC, as Operating Advisor and as Asset RepresentationsReviewer, Citibank, N.A., as Certificate Administrator, and Wilmington Trust,National Association, as Trustee (filed as Exhibit 4.6 to the registrant’sCurrent Report on Form 8-K/A filed on January 6, 2020 under Commission File No.333-228375-03 and incorporated by reference herein).

4.7          Co-LenderAgreement, dated as of November 21, 2019, by and between Wells Fargo Bank,National Association, as Initial Note A Holder, DBR Investments Co. Limited, asInitial Note A Holder, Morgan Stanley Bank, National Association, as InitialNote A Holder, Wells Fargo Bank, National Association, as Initial Note B-1Holder, DBR Investments Co. Limited, as Initial Note B-2 Holder, and MorganStanley Bank, National Association, as Initial Note B-3 Holder (filed asExhibit 4.7 to the registrant’s Current Report on Form 8-K filed on December19, 2019 under Commission File No. 333-228375-03 and incorporated by referenceherein).

4.8          Co-LenderAgreement, dated as of September 27, 2019, by and between Bank of America,N.A., as Initial Note Holder of Note A-1, Note A-3, Note A-5, Note A-7, Note A-9and Note B-1, and Wells Fargo Bank, National Association, as Initial NoteHolder of Note A-2, Note A-4, Note A-6, Note A-8, Note A-10 and Note B-2 (filedas Exhibit 4.8 to the registrant’s Current Report on Form 8-K filed on December19, 2019 under Commission File No. 333-228375-03 and incorporated by referenceherein).

4.9          AgreementBetween Note Holders, dated as of December 19, 2019, by and between MorganStanley Bank, N.A., as Initial Note A-1 Holder, Morgan Stanley Bank, N.A., asInitial Note A-2 Holder, Morgan Stanley Bank, N.A., as Initial Note A-3 Holder,and Morgan Stanley Mortgage Capital Holdings LLC, as Initial Agent (filed asExhibit 4.9 to the registrant’s Current Report on Form 8-K filed on December19, 2019 under Commission File No. 333-228375-03 and incorporated by referenceherein).

4.10         AgreementBetween Note Holders, dated as of October 24, 2019, by and between KeyBankNational Association, as Initial Note A-1 Holder, KeyBank National Association,as Initial Note A-2 Holder, KeyBank National Association, as Initial Note A-3Holder, Bank of America, N.A., as Initial Note A-4 Holder, and Bank of America,N.A., as Initial Note A-5 Holder (filed as Exhibit 4.10 to the registrant’sCurrent Report on Form 8-K filed on December 19, 2019 under Commission File No.333-228375-03 and incorporated by reference herein).

4.11         AgreementBetween Note Holders, dated as of September 16, 2019, by and between Bank ofAmerica, N.A., as Initial Note A-1 Holder, Bank of America, N.A., as InitialNote A-2 Holder, Bank of America, N.A., as Initial Note A-3 Holder, Bank ofAmerica, N.A., as Initial Note A-4 Holder, Bank of America, N.A., as InitialNote A-5 Holder, Bank of America, N.A., as Initial Note A-6 Holder, Bank ofAmerica, N.A., as Initial Note A-7 Holder, Bank of America, N.A., as InitialNote A-8 Holder, Bank of America, N.A., as Initial Note A-9 Holder, and Bank ofAmerica, N.A., as Initial Note A-10 Holder (filed as Exhibit 4.11 to theregistrant’s Current Report on Form 8-K filed on December 19, 2019 underCommission File No. 333-228375-03 and incorporated by reference herein).

4.12         AgreementBetween Note Holders, dated as of November 26, 2019, by and between Citi RealEstate Funding Inc., as Initial Note A-1-A Holder, Citi Real Estate FundingInc., as Initial Note A-1-B Holder, Wells Fargo Bank, National Association, asInitial Note A-2-A Holder, and Wells Fargo Bank, National Association, asInitial Note A-2-B Holder (filed as Exhibit 4.12 to the registrant’s CurrentReport on Form 8-K filed on December 19, 2019 under Commission File No.333-228375-03 and incorporated by reference herein).

4.13         IntercreditorAgreement, dated as of November 15, 2019, by and between Morgan Stanley Bank,N.A., as Note A-1 Holder and Note A-2 Holder, Morgan Stanley Mortgage CapitalHoldings LLC, as Note B-1-A Holder, Note B-1-B Holder, Note B-1-C Holder andNote B-1-D Holder, Bank of America, National Association, as Note A-3 Holder,Note A-4 Holder, Note B-2-A Holder, Note B-2-B Holder, Note B-2-C Holder andNote B-2-D Holder, and UBS AG, by and through its branch office at 1285 Avenueof the Americas, New York, New York, as Note A-5 Holder, Note A-6 Holder, NoteA-7 Holder, Note A-8 Holder, Note B-3-A Holder, Note B-3-B Holder, Note B-3-CHolder and Note B-3-D Holder (filed as Exhibit 4.13 to the registrant’s CurrentReport on Form 8-K filed on December 19, 2019 under Commission File No.333-228375-03 and incorporated by reference herein).

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

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

33.1        Wells Fargo Bank, National Association, as GeneralMaster Servicer

33.2        National Cooperative Bank, N.A., as NCB MasterServicer

33.3        LNR Partners, LLC, as General Special Servicer

33.4        National Cooperative Bank, N.A., as NCB SpecialServicer (see Exhibit 33.2)

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

33.6        Wells Fargo Bank, National Association, asCertificate Administrator

33.7        Wells Fargo Bank, National Association, asCustodian

33.8        Park Bridge Lender Services LLC, as OperatingAdvisor

33.9        CoreLogic Solutions, LLC, as Servicing FunctionParticipant

33.10      Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator

33.11      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian

33.12      Wells Fargo Bank, National Association, as PrimaryServicer of the 1412 Broadway Mortgage Loan (see Exhibit 33.1)

33.13      LNR Partners, LLC, as Special Servicer of the 1412Broadway Mortgage Loan (see Exhibit 33.3)

33.14      Wilmington Trust, National Association, as Trustee of the 1412 BroadwayMortgage Loan (Omitted. See Explanatory Notes.)

33.15      Wells Fargo Bank, National Association, asCustodian of the 1412 Broadway Mortgage Loan (see Exhibit 33.7)

33.16      Park Bridge Lender Services LLC, as OperatingAdvisor of the 1412 Broadway Mortgage Loan (see Exhibit 33.8)

33.17      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 1412 Broadway Mortgage Loan (see Exhibit 33.9)

33.18       Computershare Trust Company, National Association, asServicing Function Participant for the Custodian (see Exhibit 33.11)

33.19      Wells Fargo Bank, National Association, as PrimaryServicer of the Park Tower at Transbay Mortgage Loan (see Exhibit 33.1)

33.20      Rialto Capital Advisors, LLC, as Special Servicer of the Park Tower at TransbayMortgage Loan (Omitted. See Explanatory Notes.)

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

33.22      Wells Fargo Bank, National Association, asCustodian of the Park Tower at Transbay Mortgage Loan (see Exhibit 33.7)

33.23      Park Bridge Lender Services LLC, as OperatingAdvisor of the Park Tower at Transbay Mortgage Loan (see Exhibit 33.8)

33.24      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Park Tower at Transbay Mortgage Loan (see Exhibit 33.9)

33.25      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

33.26      Wells Fargo Bank, National Association, as PrimaryServicer of the Jackson Park Mortgage Loan (see Exhibit 33.1)

33.27      Situs Holdings, LLC, as Special Servicer of theJackson Park Mortgage Loan

33.28      Wilmington Trust, National Association, as Trustee of the Jackson Park MortgageLoan (Omitted. See Explanatory Notes.)

33.29      Wells Fargo Bank, National Association, asCustodian of the Jackson Park Mortgage Loan (see Exhibit 33.7)

33.30      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Jackson Park Mortgage Loan (see Exhibit 33.9)

33.31      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

33.32      KeyBank National Association, as Primary Servicerof the Parklawn Building Mortgage Loan

33.33      LNR Partners, LLC, as Special Servicer of the ParklawnBuilding Mortgage Loan (see Exhibit 33.3)

33.34      Wilmington Trust, National Association, as Trustee of the Parklawn BuildingMortgage Loan (Omitted. See Explanatory Notes.)

33.35      Wells Fargo Bank, National Association, asCustodian of the Parklawn Building Mortgage Loan (see Exhibit 33.7)

33.36      Park Bridge Lender Services LLC, as OperatingAdvisor of the Parklawn Building Mortgage Loan (see Exhibit 33.8)

33.37      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

33.38      Wells Fargo Bank, National Association, as PrimaryServicer of the ILPT Industrial Portfolio Mortgage Loan (see Exhibit 33.1)

33.39      Situs Holdings, LLC, as Special Servicer of theILPT Industrial Portfolio Mortgage Loan (see Exhibit 33.27)

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

33.41      Wells Fargo Bank, National Association, asCustodian of the ILPT Industrial Portfolio Mortgage Loan (see Exhibit 33.7)

33.42      Park Bridge Lender Services LLC, as OperatingAdvisor of the ILPT Industrial Portfolio Mortgage Loan (see Exhibit 33.8)

33.43      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the ILPT Industrial Portfolio Mortgage Loan (see Exhibit 33.9)

33.44      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

33.45      Wells Fargo Bank, National Association, as PrimaryServicer of the 55 Hudson Yards Mortgage Loan (see Exhibit 33.1)

33.46      CWCapital Asset Management LLC, as SpecialServicer of the 55 Hudson Yards Mortgage Loan

33.47      Wilmington Trust, National Association, as Trustee of the 55 Hudson YardsMortgage Loan (Omitted. See Explanatory Notes.)

33.48      Wells Fargo Bank, National Association, asCustodian of the 55 Hudson Yards Mortgage Loan (see Exhibit 33.7)

33.49      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 55 Hudson Yards Mortgage Loan (see Exhibit 33.9)

33.50      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

33.51      Wells Fargo Bank, National Association, as PrimaryServicer of the Giant Anchored Portfolio Mortgage Loan (see Exhibit 33.1)

33.52      LNR Partners, LLC, as Special Servicer of the GiantAnchored Portfolio Mortgage Loan (see Exhibit 33.3)

33.53      Wilmington Trust, National Association, as Trustee of the Giant AnchoredPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.54      Citibank, N.A., as Custodian of the Giant Anchored Portfolio Mortgage Loan(Omitted. See Explanatory Notes.)

33.55      Pentalpha Surveillance LLC, as Operating Advisor of the Giant AnchoredPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.56      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Giant Anchored Portfolio Mortgage Loan (see Exhibit 33.9)

34           Attestationreports on assessment of compliance with servicing criteria for asset-backedsecurities.

34.1        Wells Fargo Bank, National Association, as GeneralMaster Servicer

34.2        National Cooperative Bank, N.A., as NCB MasterServicer

34.3        LNR Partners, LLC, as General Special Servicer

34.4        National Cooperative Bank, N.A., as NCB SpecialServicer (see Exhibit 34.2)

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

34.6        Wells Fargo Bank, National Association, asCertificate Administrator

34.7        Wells Fargo Bank, National Association, asCustodian

34.8        Park Bridge Lender Services LLC, as OperatingAdvisor

34.9        CoreLogic Solutions, LLC, as Servicing FunctionParticipant

34.10      Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator

34.11      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian

34.12      Wells Fargo Bank, National Association, as PrimaryServicer of the 1412 Broadway Mortgage Loan (see Exhibit 34.1)

34.13      LNR Partners, LLC, as Special Servicer of the 1412Broadway Mortgage Loan (see Exhibit 34.3)

34.14      Wilmington Trust, National Association, as Trustee of the 1412 BroadwayMortgage Loan (Omitted. See Explanatory Notes.)

34.15      Wells Fargo Bank, National Association, asCustodian of the 1412 Broadway Mortgage Loan (see Exhibit 34.7)

34.16      Park Bridge Lender Services LLC, as OperatingAdvisor of the 1412 Broadway Mortgage Loan (see Exhibit 34.8)

34.17      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 1412 Broadway Mortgage Loan (see Exhibit 34.9)

34.18      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

34.19      Wells Fargo Bank, National Association, as PrimaryServicer of the Park Tower at Transbay Mortgage Loan (see Exhibit 34.1)

34.20      Rialto Capital Advisors, LLC, as Special Servicer of the Park Tower at TransbayMortgage Loan (Omitted. See Explanatory Notes.)

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

34.22      Wells Fargo Bank, National Association, asCustodian of the Park Tower at Transbay Mortgage Loan (see Exhibit 34.7)

34.23      Park Bridge Lender Services LLC, as OperatingAdvisor of the Park Tower at Transbay Mortgage Loan (see Exhibit 34.8)

34.24      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Park Tower at Transbay Mortgage Loan (see Exhibit 34.9)

34.25      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

34.26      Wells Fargo Bank, National Association, as PrimaryServicer of the Jackson Park Mortgage Loan (see Exhibit 34.1)

34.27      Situs Holdings, LLC, as Special Servicer of theJackson Park Mortgage Loan

34.28      Wilmington Trust, National Association, as Trustee of the Jackson Park MortgageLoan (Omitted. See Explanatory Notes.)

34.29      Wells Fargo Bank, National Association, asCustodian of the Jackson Park Mortgage Loan (see Exhibit 34.7)

34.30      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Jackson Park Mortgage Loan (see Exhibit 34.9)

34.31      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

34.32      KeyBank National Association, as Primary Servicerof the Parklawn Building Mortgage Loan

34.33      LNR Partners, LLC, as Special Servicer of theParklawn Building Mortgage Loan (see Exhibit 34.3)

34.34      Wilmington Trust, National Association, as Trustee of the Parklawn BuildingMortgage Loan (Omitted. See Explanatory Notes.)

34.35      Wells Fargo Bank, National Association, asCustodian of the Parklawn Building Mortgage Loan (see Exhibit 34.7)

34.36      Park Bridge Lender Services LLC, as OperatingAdvisor of the Parklawn Building Mortgage Loan (see Exhibit 34.8)

34.37      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

34.38      Wells Fargo Bank, National Association, as PrimaryServicer of the ILPT Industrial Portfolio Mortgage Loan (see Exhibit 34.1)

34.39      Situs Holdings, LLC, as Special Servicer of theILPT Industrial Portfolio Mortgage Loan (see Exhibit 34.27)

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

34.41      Wells Fargo Bank, National Association, asCustodian of the ILPT Industrial Portfolio Mortgage Loan (see Exhibit 34.7)

34.42      Park Bridge Lender Services LLC, as OperatingAdvisor of the ILPT Industrial Portfolio Mortgage Loan (see Exhibit 34.8)

34.43      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the ILPT Industrial Portfolio Mortgage Loan (see Exhibit 34.9)

34.44      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

34.45      Wells Fargo Bank, National Association, as PrimaryServicer of the 55 Hudson Yards Mortgage Loan (see Exhibit 34.1)

34.46      CWCapital Asset Management LLC, as SpecialServicer of the 55 Hudson Yards Mortgage Loan

34.47      Wilmington Trust, National Association, as Trustee of the 55 Hudson YardsMortgage Loan (Omitted. See Explanatory Notes.)

34.48      Wells Fargo Bank, National Association, asCustodian of the 55 Hudson Yards Mortgage Loan (see Exhibit 34.7)

34.49      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 55 Hudson Yards Mortgage Loan (see Exhibit 34.9)

34.50      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

34.51      Wells Fargo Bank, National Association, as PrimaryServicer of the Giant Anchored Portfolio Mortgage Loan (see Exhibit 34.1)

34.52      LNR Partners, LLC, as Special Servicer of the GiantAnchored Portfolio Mortgage Loan (see Exhibit 34.3)

34.53      Wilmington Trust, National Association, as Trustee of the Giant AnchoredPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.54      Citibank, N.A., as Custodian of the Giant Anchored Portfolio Mortgage Loan(Omitted. See Explanatory Notes.)

34.55      Pentalpha Surveillance LLC, as Operating Advisor of the Giant AnchoredPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.56      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Giant Anchored Portfolio Mortgage Loan (see Exhibit 34.9)

35           Servicer compliance statements.

35.1        Wells Fargo Bank, National Association, as GeneralMaster Servicer

35.2        National Cooperative Bank, N.A., as NCB MasterServicer

35.3        LNR Partners, LLC, as General Special Servicer

35.4        National Cooperative Bank, N.A., as NCB SpecialServicer (see Exhibit 35.2)

35.5        Wells Fargo Bank, National Association, asCertificate Administrator

35.6        Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator

35.7        Wells Fargo Bank, National Association, as PrimaryServicer of the 1412 Broadway Mortgage Loan (see Exhibit 35.1)

35.8        LNR Partners, LLC, as Special Servicer of the 1412Broadway Mortgage Loan (see Exhibit 35.3)

35.9        Wells Fargo Bank, National Association, as PrimaryServicer of the Park Tower at Transbay Mortgage Loan (see Exhibit 35.1)

35.10      Rialto Capital Advisors, LLC, as Special Servicer of the Park Tower at TransbayMortgage Loan (Omitted. See Explanatory Notes.)

35.11      Wells Fargo Bank, National Association, as PrimaryServicer of the Jackson Park Mortgage Loan (see Exhibit 35.1)

35.12      Situs Holdings, LLC, as Special Servicer of theJackson Park Mortgage Loan

35.13      KeyBank National Association, as Primary Servicer of the Parklawn BuildingMortgage Loan (Omitted. See Explanatory Notes.) 

35.14      LNR Partners, LLC, as Special Servicer of theParklawn Building Mortgage Loan (see Exhibit 35.3)

35.15      Wells Fargo Bank, National Association, as PrimaryServicer of the ILPT Industrial Portfolio Mortgage Loan (see Exhibit 35.1)

35.16      Situs Holdings, LLC, as Special Servicer of theILPT Industrial Portfolio Mortgage Loan (see Exhibit 35.12)

35.17      Wells Fargo Bank, National Association, as PrimaryServicer of the 55 Hudson Yards Mortgage Loan (see Exhibit 35.1)

35.18      CWCapital Asset Management LLC, as Special Servicer of the 55 Hudson YardsMortgage Loan (Omitted. See Explanatory Notes.)

35.19      Wells Fargo Bank, National Association, as PrimaryServicer of the Giant Anchored Portfolio Mortgage Loan (see Exhibit 35.1)

35.20      LNR Partners, LLC, as Special Servicer of the GiantAnchored Portfolio Mortgage Loan (see Exhibit 35.3)

99.1         MortgageLoan Purchase Agreement, dated and effective as of December 11, 2019, betweenBank of America, National Association and Banc of America Merrill LynchCommercial Mortgage Inc. (filed as Exhibit 99.1 to the registrant’s CurrentReport on Form 8-K filed on December 19, 2019 under Commission File No.333-228375-03 and incorporated by reference herein).

99.2         MortgageLoan Purchase Agreement, dated and effective as of December 11, 2019, betweenWells Fargo Bank, National Association and Banc of America Merrill LynchCommercial Mortgage Inc. (filed as Exhibit 99.2 to the registrant’s CurrentReport on Form 8-K filed on December 19, 2019 under Commission File No.333-228375-03 and incorporated by reference herein).

99.3         MortgageLoan Purchase Agreement, dated and effective as of December 11, 2019, betweenMorgan Stanley Mortgage Capital Holdings LLC and Banc of America Merrill LynchCommercial Mortgage Inc. (filed as Exhibit 99.3 to the registrant’s CurrentReport on Form 8-K filed on December 19, 2019 under Commission File No.333-228375-03 and incorporated by reference herein).

99.4         MortgageLoan Purchase Agreement, dated and effective as of December 11, 2019, betweenNational Cooperative Bank, N.A. and Banc of America Merrill Lynch CommercialMortgage Inc. (filed as Exhibit 99.4 to the registrant’s Current Report on Form8-K filed on December 19, 2019 under Commission File No. 333-228375-03 andincorporated by reference herein).

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

(c)    Not Applicable.

 

**SIGNATURES**

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

Banc of America Merrill LynchCommercial Mortgage Inc.(Depositor)

/s/ Leland F. Bunch, III

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

(senior officer in charge of securitizationof the depositor)

Date: March 13, 2024