Management's Assertion

 

Report on Assessment ofCompliance with Applicable Servicing Criteria

 

 

Management of U.S. BankNational Association and U.S. Bank Trust Company, National Association(collectively “U.S. Bank”) is responsible for assessing compliance as of andfor the year ended December 31, 2022 with the servicing criteria set forth inItem 1122 (d) of Regulation AB applicable to it as set forth on Exhibit Ahereto. This report covers asset backed securities transactions within the **U.S.Bank Corporate Trust Asset-Backed Securities****Platform1****(the “Platform”)**

 

U.S. Bank hereby provides thefollowing report on its assessment of compliance with the servicing criteriaset forth in Item 1122 of Regulation AB applicable to it and as described onExhibit A hereto:

 

1. U.S. Bank is responsiblefor assessing its compliance with the servicing criteria applicable to it asnoted on the accompanying Exhibit A;

 

2. Except as set forth inparagraph 3 below, U.S. Bank used the criteria set forth in paragraph (d) ofItem 1122 of Regulation AB to assess its compliance with the applicableservicing criteria;

 

3. The criteria listed in thecolumn titled “Inapplicable Servicing Criteria” on Exhibit A hereto areinapplicable to U.S. Bank based on the servicing activities it performsdirectly with respect to the Platform;

 

4. U.S. Bank has complied, inall material respects, with the applicable servicing criteria as of and for theyear ended December 31, 2022; and

 

5. Ernst & Young, LLP, aregistered public accounting firm, has issued an attestation report on U.S.Bank’s assessment of compliance with the applicable servicing criteria as ofand for the year ended December 31, 2022.

 

 

 

 

1The U.S. Bank Corporate Trust Asset-BackedSecurities Platform (the "Platform") consists of the activitiesinvolved in the performance of servicing functions for which the Companyprovides trustee, securities administration, registrar, paying agent anddocument custody services for (i) publicly issued asset-backed andmortgage-backed transactions the securities of which were offered on or afterJanuary 1, 2006 and (ii) certain asset-backed transactions for which the Issuerhas voluntarily elected to make Regulation AB compliant filings under theSecurities Exchange Act of 1934, as amended.

 

U.S. BANK NATIONALASSOCIATION 

/s/ John Stern

Name: John Stern

Title: Executive VicePresident

 

 

U.S. BANK TRUST COMPANY,NATIONAL ASSOCIATION 

/s/ John Stern

Name: John Stern

Title: Executive Vice President

 

  

Dated: February 27, 2023

 

 

**EXHIBIT********A********to********Management’s****Assertion**

 

| **Reference**                                                           | **Servicing********Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | **Applicable**

**Servicing   Criteria** | **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  proceduresareinstitutedtomonitorthethirdparty’sperformanceandcompliance with such servicing  activities.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | ** **

**X****2**                   |                                     |
| ** **

1122(d)(1)(iii)                                             | Anyrequirementsinthetransactionagreementstomaintainaback-upservicerfor the Pool Assets are maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |                                     | ** **

**X**                        |
| ** **

1122(d)(1)(iv)                                              | A  fidelity bond and errors and omissions policy is in effect on the party  participatingintheservicingfunctionthroughoutthereportingperiodintheamount of coverage required by and otherwise  in accordance with the terms of the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                | ** **

**X**                        |                                     |
| ** **

1122(d)(1)(v)                                               | Aggregationofinformation,asapplicable,ismathematicallyaccurateandthe information  conveyed accurately reflects the information.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | ** **

**X****3**                   |                                     |
| ** **

**Cash********Collection********and********Administration** |
| ** **

1122(d)(2)(i)                                               |  

Paymentsonpoolassetsaredepositedintotheappropriatecustodialbankaccounts 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)                                              |  

Disbursementsmadeviawiretransferonbehalfofanobligorortoaninvestorare made only by authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | ** **

**X**                        |                                     |
| ** **

1122(d)(2)(iii)                                             |  

Advancesoffundsorguaranteesregardingcollections,cashflowsordistributions, and any  interest or other fees charged for such advances, are made, reviewed and  approved as specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | ** **

**X****4**                   |                                     |
| ** **

1122(d)(2)(iv)                                              |  

The  related accounts forthe  transaction, such as cash reserveaccounts  or accounts establishedasaformofovercollateralization,areseparatelymaintained(e.g.,with respect to commingling of cash) as set forth in the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                    | ** **

**X**                        |                                     |
| ** **

1122(d)(2)(v)                                               |  

Eachcustodialaccountismaintainedatafederallyinsureddepositoryinstitutionas set forth in the transaction agreements. For purposes of  this criterion, “federally insureddepositoryinstitution”withrespecttoaforeignfinancialinstitutionmeansa foreign financial institution that meets the requirements of Rule  13k-1(b)(1) of the Securities Exchange Act.                                                                                                                                                                                                                                                                                                                          | ** **

**X**                        |                                     |
| ** **

1122(d)(2)(vi)                                              |  

Unissuedchecksaresafeguardedsoastopreventunauthorized 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 calendardaysoftheiroriginalidentification,orsuchothernumberofdaysspecified in the transaction agreements. |  

**X**                            |                                     |
|  

**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 Commissionrequirements.Specifically,suchreports(A)arepreparedinaccordance withtimeframesandothertermssetforthinthe  transactionagreements; (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)agreewithinvestors’orthetrustee’srecordsastothetotal unpaid principal balance and  number of Pool Assets serviced by the Servicer.                                                        |  

**X**                            |                                     |
|  

1122(d)(3)(ii)                                                  |  

Amountsduetoinvestorsareallocatedandremittedinaccordancewithtimeframes, distribution priority and other terms set forth in the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |  

**X**                            |                                     |
|  

1122(d)(3)(iii)                                                 |  

Disbursementsmadetoaninvestorarepostedwithintwobusinessdaystothe Servicer’s investor records, or such  other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |  

**X**                            |                                     |
|  

1122(d)(3)(iv)                                                  |  

Amountsremittedtoinvestorspertheinvestorreportsagreewithcancelledchecks, or other form of payment, or custodial bank  statements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |  

**X**                            |                                     |
|  

**Pool********Asset********Administration**                     |
|  

1122(d)(4)(i)                                                   |  

Collateralorsecurityonpoolassetsismaintainedasrequiredbythetransaction agreements or related pool  asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |  

**X**                            |                                     |
|  

1122(d)(4)(ii)                                                  |  

Poolassetsandrelateddocumentsaresafeguardedasrequiredbythetransaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |  

**X**                            |                                     |
|  

1122(d)(4)(iii)                                                 |  

Anyadditions,removalsorsubstitutionstotheassetpoolaremade,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 therelatedpoolassetdocumentsarepostedtotheServicer’sobligorrecordsmaintained no more than two business  days after receipt, or such other number of daysspecified in the transaction agreements, and allocated to  principal, interest or other items (e.g., escrow) in accordance with the  related pool asset documents.                                                                                                                                                                                                                                                                                        |                                     |  

**X**                            |
|  

1122(d)(4)(v)                                                   |  

TheServicer’srecordsregardingthepoolassetsagreewiththeServicer’srecords with respect to an obligor’s  unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                     |  

**X**                            |
|  

1122(d)(4)(vi)                                                  |  

Changeswithrespecttothetermsorstatusof anobligor'spoolassets(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)                                                 |  

Lossmitigationorrecoveryactions(e.g.,forbearanceplans,modificationsand deeds in  lieu of foreclosure, foreclosures and repossessions, as applicable) are  initiated,conductedandconcluded  inaccordancewiththetimeframesorother  requirements established by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                         |                                     |  

**X**                            |
|  

1122(d)(4)(viii)                                                |  

Records  documenting collection efforts are maintained during the period a pool assetisdelinquentinaccordancewiththetransactionagreements.Suchrecordsare maintained on at least a monthly  basis, or such other period specified in the transactionagreements,anddescribetheentity’sactivitiesinmonitoringdelinquent 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)                                                  |  

Adjustmentstointerestratesorratesofreturnforpoolassetswithvariableratesare computed based on the related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |                                     |  

**X**                            |
|  

1122(d)(4)(x)                                                   |  

Regardinganyfundsheldintrustforanobligor(suchasescrowaccounts):(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 applicablepoolassetdocumentsandstatelaws;and(C)suchfundsarereturnedto theobligorwithin 30 calendardaysoffullrepaymentoftherelated 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  appropriatebillsornoticesforsuchpayments,provided thatsuchsupporthasbeen receivedbytheserviceratleast30calendardayspriortothesedates,orsuchother number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                         |                                     |  

**X**                            |
|  

1122(d)(4)(xii)                                                 |  

Anylatepaymentpenaltiesinconnectionwithanypaymenttobemadeon behalfof 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)                                                |  

Disbursementsmadeonbehalfofanobligorarepostedwithintwobusinessdaysto the obligor’s records maintained by the servicer, or such other  number of days specifiedinthetransaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |                                     |  

**X**                            |
|  

1122(d)(4)(xiv)                                                 |  

Delinquencies,charge-offsanduncollectibleaccountsarerecognizedandrecorded  in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |                                     |  

**X**                            |
|  

1122(d)(4)(xv)                                                  |  

Anyexternalenhancementorothersupport,identifiedinItem1114(a)(1)through (3)orItem1115ofRegulationAB,ismaintainedassetforthinthetransaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |  

**X**                            |                                     |

 

 

2NoservicingactivitieswereperformedbytheCompanythatrequiredtheservicingcriteriatobecompliedwith.

3NoservicingactivitieswereperformedbytheCompanythatrequiredtheservicingcriteriatobecompliedwith.

4NoservicingactivitieswereperformedbytheCompanythatrequiredtheservicingcriteriato becompliedwith.

 

 

Corporate Trust ABS Platform(B)