**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, 2019or**

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

Not applicable.

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

Not applicable.

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

Large accelerated filer       o                                                                                                 Acceleratedfiler                                  o

Non-acceleratedfiler         ⌧  (Do not check if a smaller reportingcompany)                        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 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 which is an asset ofthe issuing entity and two other *pari passu* loans, which are not assetsof the issuing entity. This loan combination, including the 1412 BroadwayMortgage Loan, is being serviced and administered pursuant to the Pooling andServicing Agreement, which is incorporated by reference as Exhibit 4.1 to thisAnnual 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 theExhibit Index) with respect to the Jackson Park Mortgage Loan, whichconstituted approximately 8.2% of the asset pool of the issuing entity as ofits cut-off date.  The Jackson Park Mortgage Loan is an asset of the issuingentity and is part of a loan combination that includes the Jackson ParkMortgage Loan and eight other *pari passu* loans and two subordinatecompanion loans, which are not assets of the issuing entity. A 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 and four other *pari passu* loans, which are notassets of the issuing entity or (b) with respect to the ILPT IndustrialPortfolio Mortgage Loan and 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 and thirty-one other *pari passu* loans and threesubordinate companion loans, which are not assets of the issuing entity. Aportion of the loan combination was securitized in the Hudson Yards 2019-55HYMortgage Trust transaction (the “Hudson Yards 2019-55HY Transaction”).This loan combination, including the 55 Hudson Yards Mortgage Loan, is beingserviced and administered pursuant to the trust and servicing agreement for theHudson Yards 2019-55HY Transaction, which is incorporated by reference asExhibit 4.5 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the 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 theprimary servicer of the related mortgage loans serviced and administeredpursuant to such agreement unless a separate primary servicer is identifiedherein.  If this report does not identify a separate primary servicer, theservicer compliance statement provided by the master servicer under any suchagreement also encompasses its responsibilities as primary servicer of therelated mortgage loan or mortgage loans.

Wells Fargo Bank, NationalAssociation is the master servicer and certificate administrator of themortgage loans serviced under the Pooling and Servicing Agreement and theprimary servicer of the 55 Hudson Yards Mortgage Loan, the Jackson ParkMortgage Loan, the Park Tower at Transbay Mortgage Loan, the Giant AnchoredPortfolio Mortgage Loan and the ILPT Industrial Portfolio Mortgage Loan. As aresult, Wells Fargo Bank, National Association is a “servicer” as defined inItem 1108(a)(2)(iii) of Regulation AB, in the capacities described above,because it is servicing mortgage loans that constituted 10% or more of theassets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria, accountants’ attestation reportsand servicer compliance statements delivered by Wells Fargo Bank, NationalAssociation in the capacities described above are listed in the Exhibit Index.

Wells Fargo Bank, National Association is the custodian ofthe mortgage loans serviced under the Pooling and Servicing Agreement, the 55Hudson Yards Mortgage Loan, the Jackson Park Mortgage Loan, the ParklawnBuilding Mortgage Loan, the Park Tower at Transbay Mortgage Loan and the ILPTIndustrial Portfolio Mortgage Loan.  As a result, Wells Fargo Bank,National Association is a servicing function participant in the capacitiesdescribed above, because it is servicing mortgage loans that constituted 5% ormore of the assets of the issuing entity as of its cut-off date. Theassessments of compliance with applicable servicing criteria and accountants’attestation reports delivered by Wells Fargo Bank, National Association in thecapacities described above are listed in the Exhibit Index.

Park Bridge Lender Services LLC is the operating advisor ofthe mortgage loans serviced under the Pooling and Servicing Agreement, theParklawn Building Mortgage Loan, the Park Tower at Transbay Mortgage Loan andthe ILPT Industrial Portfolio Mortgage Loan.  As a result, Park BridgeLender Services LLC is a servicing function participant in the capacitiesdescribed above, because it is servicing mortgage loans that constituted 5% ormore of the assets of the issuing entity as of its cut-off date. Theassessments of compliance with applicable servicing criteria and accountants’attestation reports delivered by Park Bridge Lender Services 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 Commercial Real EstateServices, Inc. and National Tax Search, LLC.  These entities were engagedby the master servicer under the Pooling and Servicing Agreement and theprimary servicer of the 55 Hudson Yards Mortgage Loan, the Jackson ParkMortgage Loan, the Park Tower at Transbay Mortgage Loan, the Giant AnchoredPortfolio Mortgage Loan and the ILPT Industrial Portfolio Mortgage Loan toremit tax payments received from the escrow accounts of borrowers to localtaxing 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, thesevendors are “servicers” for the purposes of Item 1122 of Regulation AB.  *See*Compliance 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 listed on the Exhibit Index are omitted from thisAnnual Report on Form 10-K as the certificate administrator pursuant to therelated pooling and servicing agreement or trust and servicing agreement doesnot perform any activities that address servicing criteria with respect to theissuing entity and because they are each not a “servicer” that meets thecriteria in Item 1108(a)(2)(i) through (iii) of Regulation AB.

With respect to the *pari passu*loan combinations that include the 55 Hudson Yards Mortgage Loan, the JacksonPark Mortgage Loan, the Parklawn Building Mortgage Loan, the Park Tower atTransbay Mortgage Loan, the Giant Anchored Portfolio Mortgage Loan, the ILPTIndustrial Portfolio Mortgage Loan, (i) the reports on assessment of compliancewith 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, Pentalpha Surveillance LLC as operatingadvisor of the Giant Anchored Portfolio Mortgage Loan and Situs Holdings, LLCas special servicer of the ILPT Industrial Portfolio Mortgage Loan, listed onthe Exhibit Index are omitted from this Annual Report on Form 10-K as they arenot required to be included on this Annual Report on Form 10-K per Instruction3 to Item 1122 of Regulation AB because they are parties performing activitiesthat address servicing criteria relating to 5% or less of the assets of theissuing entity; and (ii) the servicer compliance statements of CWCapital AssetManagement LLC as special servicer of the 55 Hudson Yards Mortgage Loan, AEGONUSA Realty Advisors, LLC as special servicer of the Jackson Park Mortgage Loan,KeyBank National Association as primary servicer of the Parklawn BuildingMortgage Loan, LNR Partners, LLC as special servicer of the Parklawn BuildingMortgage Loan and the Giant Anchored Portfolio Mortgage Loan, Rialto CapitalAdvisors, LLC as special servicer of the Park Tower at Transbay Mortgage Loanand Situs Holdings, LLC as special servicer of the ILPT Industrial PortfolioMortgage 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 2.  Properties.**

Omitted.

**Item 3.  Legal Proceedings.**

Omitted.

**Item 4.  Mine Safety Disclosures.**

Not applicable.

**PART II**

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

Omitted.

**Item 6.  Selected Financial Data.**

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**Item 9B.  Other Information.**

None.

**PART III**

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

Omitted.

**Item 11.  Executive Compensation.**

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**ADDITIONAL DISCLOSURE ITEMS FOR REGULATION AB**

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

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

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

No entity or group of affiliated entities provides any external 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 Derivatives Instruments(Financial Information).**

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

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

The registrant knows of no material pending legal proceedinginvolving the trust or any party related to the trust, other than routinelitigation incidental to the duties of those respective parties, and thefollowing, with respect to Wells Fargo Bank, National Association, ascertificate administrator and as custodian, and Citibank, N.A., as custodian.

Beginning on June 18, 2014, a group of institutionalinvestors filed civil complaints in the Supreme Court of the State of New York,New York County, and later the U.S. District Court for the Southern District ofNew York, against Wells Fargo Bank, N.A., (“Wells Fargo Bank”) in itscapacity as trustee for certain residential mortgage backed securities (“RMBS”)trusts.  The complaints against Wells Fargo Bank alleged that the trusteecaused losses to investors and asserted causes of action based upon, amongother things, the trustee's alleged failure to: (i) notify and enforcerepurchase obligations of mortgage loan sellers for purported breaches of representationsand warranties, (ii) notify investors of alleged events of default, and (iii)abide by appropriate standards of care following alleged events of default.Relief sought included money damages in an unspecified amount, reimbursement ofexpenses, and equitable relief. In November 2018, Wells Fargo Bank reached anagreement, in which it denied any wrongdoing, to resolve such claims on aclasswide basis for the 271 RMBS trusts at issue.  On May 6, 2019, thecourt entered an order approving the settlement agreement.  Separatelawsuits against Wells Fargo Bank making similar allegations filed by certainother institutional investors concerning several RMBS trusts in New Yorkfederal and state court are not covered by the agreement.  With respect tosuch litigations, Wells Fargo Bank believes plaintiffs' claims are withoutmerit and intends to contest the claims vigorously, but there can be noassurances as to the outcome of the litigations or the possible impact of thelitigations on Wells Fargo Bank or the RMBS trusts.

In the ordinary course of business, Citibank is involved in anumber of legal proceedings, including in connection with its role as trusteeof certain RMBS transactions.  Certain of these Citibank as trustee-relatedmatters are disclosed herein. 

On June 18, 2014, a civil action was filed against Citibankin the Supreme Court of the State of New York by a group of investors in 48private-label RMBS trusts for which Citibank allegedly serves or did serve astrustee, asserting claims for purported violations of the Trust Indenture Actof 1939 (the “Trust Indenture Act”), breach of contract, breach offiduciary duty and negligence based on Citibank’s alleged failure to performits duties as trustee for the 48 RMBS trusts.  On November 24, 2014,plaintiffs sought leave to withdraw this action.  On the same day, asmaller subset of similar plaintiff investors in 27 private-label RMBS trustsfor which Citibank allegedly serves or did serve as trustee, filed a new civilaction against Citibank in the United States District Court for the SouthernDistrict of New York asserting similar claims as the prior action filed instate court.  In January 2015, the court closed plaintiffs’ original statecourt action.  On September 8, 2015, the federal court dismissed allclaims as to 24 of the 27 trusts and allowed certain of the claims to proceedas to the other three trusts. Subsequently, plaintiffs voluntarily dismissedall claims with respect to two of the three trusts. On April 7, 2017, Citibankfiled a motion for summary judgment. Plaintiffs filed its consolidatedopposition brief and cross motion for partial summary judgment on May 22,2017.  Briefing on those motions was completed on August 4, 2017. On March22, 2018, the court granted Citibank’s motion for summary judgment in itsentirety, denied Plaintiffs’ motion for summary judgment and ordered the clerkto close the case. On April 20, 2018, plaintiffs filed a notice of appeal.Plaintiffs’ opening brief was filed on August 3, 2018. Citibank filed itsopposition on November 2, 2018.  Plaintiffs’ filed their reply on November16, 2018.  On June 7, 2019, the Second Circuit dismissed plaintiffs’appeal following the parties’ filing of a stipulation withdrawing the case withprejudice pursuant to Federal Rule of Appellate Procedure 42.

On November 24, 2015, the same investors that brought thefederal case brought a new civil action in the Supreme Court of the State ofNew York related to 25 private-label RMBS trusts for which Citibank allegedlyserves or did serve as trustee.  This case includes the 24 trustspreviously dismissed in the federal action, and one additional trust.  Theinvestors assert claims for breach of contract, breach of fiduciary duty, breachof duty to avoid conflicts of interest, and violation of New York’s Streit Act(the “Streit Act”).  Following oral argument on Citibank’s motion todismiss, Plaintiffs filed an amended complaint on August 5, 2016.  On June27, 2017, the state court issued a decision, dismissing the Event of Defaultclaims, mortgage-file-related claims, the fiduciary duty claims, and theconflict of interest claims.  The decision sustained certain breach ofcontract claims including the claim alleging discovery of breaches of representationsand warranties, a claim related to robo-signing, and the implied covenant ofgood faith claim.  Citibank appealed the lower court’s decision, and onJanuary 16, 2018, the Appellate Division, First Department, dismissed theclaims related to robo-signing and the implied covenant of good faith, butallowed plaintiffs’ claim alleging discovery of breaches of representations andwarranties to proceed.  On June 7, 2019, plaintiffs filed a motion fordiscontinuance of the action and dismissal of plaintiffs’ claims withprejudice.

On August 19, 2015, the Federal Deposit Insurance Corporation(“FDIC”) as Receiver for a failed financial institution filed a civilaction against Citibank in the Southern District of New York.  This actionrelates to one private-label RMBS trust for which Citibank formerly served astrustee.  FDIC asserts claims for breach of contract, violation of theStreit Act, and violation of the Trust Indenture Act. Citibank jointly briefeda motion to dismiss with The Bank of New York Mellon and U.S. Bank, N.A.,entities that have also been sued by FDIC in their capacity as trustee, andthese cases have all been consolidated in front of Judge Carter.  OnSeptember 30, 2016, the Court granted the motion to dismiss without prejudicefor lack of subject matter jurisdiction.  On October 14, 2016, FDIC fileda motion for reargument or relief from judgment from the Court’s dismissalorder.  On July 11, 2017, Judge Carter ruled on the motion forreconsideration regarding his dismissal of the action.  He deniedreconsideration of his decision on standing, but granted leave to amend thecomplaint by October 9, 2017.  The FDIC subsequently requested anextension of time to file its amended complaint, which was granted. The FDICfiled its amended complaint on December 8, 2017. Defendants’ jointly filed amotion to dismiss the amended complaint and that joint motion was fully briefedas of May 3, 2018.  On March 20, 2019, the Court granted Defendants’ jointmotion to dismiss the amended complaint. The FDIC's deadline to file a noticeof appeal was April 22, 2019. The FDIC has not appealed. 

There can be no assurances as to the outcome of litigation orthe possible impact of litigation on the trustee or the RMBS trusts. However, Citibank denies liability and continues to vigorously defend againstthese litigations.  Furthermore, neither the above-disclosed litigationsnor any other pending legal proceeding involving Citibank will materiallyaffect Citibank’s ability to perform its duties under the related servicingagreement for this CMBS transaction.

**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).

The report on assessment of compliance with applicableservicing criteria furnished pursuant to Item 1122 of Regulation AB by MidlandLoan Services, a Division of PNC Bank National Association (“Midland”)discloses that a material instance of noncompliance occurred, as describedbelow:

Material Instance of Noncompliance

In certain instances, the ScheduleAL Files (Item 1125 of Regulation AB) were not reported in accordance with theterms specified in the transaction agreements, in conflict with Item1122(d)(3)(i): “Reports to investors, including those to be filed with theCommission, are maintained in accordance with the transaction agreements andapplicable Commission requirements. Specifically, such reports: (A) Areprepared in accordance with timeframes and other terms set forth in thetransaction agreements”.  The noncompliance consisted of omitted orinaccurately reported fields as described in (1) and (2) below.  (1) Inconnection with other enhancements Midland made to its manual Schedule ALprocess, starting in April 2019, Midland developed and implemented new ScheduleAL reporting templates for each applicable CMBS transaction that closed priorto April 2019 and for each applicable CMBS transaction going forward. Related to this, Midland made certain template setup errors, along with relatedand other manual inputting of information errors, and the errors were notidentified prior to submission of the applicable Schedule AL Files in certaincases due to breakdowns in quality control.  (2) In one applicabletransaction, the related Schedule AL File for a given month was not savedproperly resulting in the prior month's Schedule AL File being submitted forthe given month instead of the correct Schedule AL File. 

The identified instances did notinvolve the servicing of assets included in this securitization.

Steps Taken to Remedy the Material Instance of Noncompliance

Midland’s Schedule AL reportingprocess was enhanced in April of 2019, however, the process remained manualthroughout the 2019 calendar year.  Errors relating to certain Schedule ALFiles during 2019 were identified during the related audit.  Followingidentification, Midland made staffing changes and additional enhancements andimprovements to its processes and procedures to support its Schedule ALreporting obligations and expects to move to an automated solution for thisprocess.  

Midland is currently remediating theSchedule AL reporting for certain of the CMBS transactions found to beincorrect. 

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

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

**PART IV**

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

(a) The following is a list of documents filed as part of thisAnnual 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 Special Servicer,Situs Holdings, LLC, as ILPT Industrial Portfolio Special Servicer, Wells FargoBank, National Association, as Certificate Administrator, Wilmington Trust,National Association, as Trustee, and Park Bridge Lender Services LLC, asOperating Advisor and Asset Representations Reviewer (filed as Exhibit 4.4 tothe registrant’s Current Report on Form 8-K/A filed on January 6, 2020 underCommission File No. 333-228375-03 and incorporated by reference 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, NoteA-9 and 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, NationalAssociation, as General Master Servicer

33.2       National Cooperative Bank,N.A., as NCB Master Servicer

33.3       Midland Loan Services, aDivision of PNC Bank, National Association, 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, NationalAssociation, as Certificate Administrator

33.7       Wells Fargo Bank, NationalAssociation, as Custodian

33.8       Park Bridge LenderServices LLC, as Operating Advisor

33.9       CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant

33.10     National Tax Search, LLC,as Servicing Function Participant

33.11     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 1412 Broadway Mortgage Loan (seeExhibit 33.1)

33.12     Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the 1412Broadway Mortgage Loan (see Exhibit 33.3)

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

33.14     Wells Fargo Bank, NationalAssociation, as Custodian of the 1412 Broadway Mortgage Loan (see Exhibit 33.7)

33.15     Park Bridge LenderServices LLC, as Operating Advisor of the 1412 Broadway Mortgage Loan (seeExhibit 33.8)

33.16     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the 1412 BroadwayMortgage Loan (see Exhibit 33.9)

33.17     National Tax Search, LLC,as Servicing Function Participant of the 1412 Broadway Mortgage Loan (seeExhibit 33.10)

33.18     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Park Tower at Transbay Mortgage Loan(see Exhibit 33.1)

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

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

33.21     Wells Fargo Bank, NationalAssociation, as Custodian of the Park Tower at Transbay Mortgage Loan (seeExhibit 33.7)

33.22     Park Bridge LenderServices LLC, as Operating Advisor of the Park Tower at Transbay Mortgage Loan(see Exhibit 33.8)

33.23     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Park Tower atTransbay Mortgage Loan (see Exhibit 33.9)

33.24     National Tax Search, LLC,as Servicing Function Participant of the Park Tower at Transbay Mortgage Loan(see Exhibit 33.10)

33.25     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Jackson Park Mortgage Loan (see Exhibit33.1)

33.26     AEGON USA RealtyAdvisors, LLC, as Special Servicer of the Jackson Park Mortgage Loan

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

33.28     Wells Fargo Bank, NationalAssociation, as Custodian of the Jackson Park Mortgage Loan (see Exhibit 33.7)

33.29     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Jackson Park MortgageLoan (see Exhibit 33.9)

33.30     National Tax Search, LLC,as Servicing Function Participant of the Jackson Park Mortgage Loan (seeExhibit 33.10)

33.31     KeyBank National Association,as Primary Servicer of the Parklawn Building Mortgage Loan

33.32     LNR Partners, LLC, asSpecial Servicer of the Parklawn Building Mortgage Loan

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

33.34     Wells Fargo Bank, NationalAssociation, as Custodian of the Parklawn Building Mortgage Loan (see Exhibit33.7)

33.35     Park Bridge LenderServices LLC, as Operating Advisor of the Parklawn Building Mortgage Loan (seeExhibit 33.8)

33.36     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the ILPT Industrial Portfolio Mortgage Loan(see Exhibit 33.1)

33.37     Situs Holdings, LLC, as Special Servicer of the ILPT Industrial PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

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

33.39     Wells Fargo Bank, NationalAssociation, as Custodian of the ILPT Industrial Portfolio Mortgage Loan (seeExhibit 33.7)

33.40     Park Bridge LenderServices LLC, as Operating Advisor of the ILPT Industrial Portfolio MortgageLoan (see Exhibit 33.8)

33.41     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the ILPT IndustrialPortfolio Mortgage Loan (see Exhibit 33.9)

33.42     National Tax Search, LLC,as Servicing Function Participant of the ILPT Industrial Portfolio MortgageLoan (see Exhibit 33.10)

33.43     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 55 Hudson Yards Mortgage Loan (seeExhibit 33.1)

33.44     CWCapital AssetManagement LLC, as Special Servicer of the 55 Hudson Yards Mortgage Loan

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

33.46     Wells Fargo Bank, NationalAssociation, as Custodian of the 55 Hudson Yards Mortgage Loan (see Exhibit33.7)

33.47     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the 55 Hudson YardsMortgage Loan (see Exhibit 33.9)

33.48     National Tax Search, LLC,as Servicing Function Participant of the 55 Hudson Yards Mortgage Loan (seeExhibit 33.10)

33.49     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Giant Anchored Portfolio Mortgage Loan(see Exhibit 33.1)

33.50     LNR Partners, LLC, asSpecial Servicer of the Giant Anchored Portfolio Mortgage Loan (see Exhibit33.32)

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

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

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

33.54     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Giant AnchoredPortfolio Mortgage Loan (see Exhibit 33.9)

33.55     National Tax Search, LLC,as Servicing Function Participant of the Giant Anchored Portfolio Mortgage Loan(see Exhibit 33.10)

34          Attestation reports onassessment of compliance with servicing criteria for asset-backed securities.

34.1       Wells Fargo Bank, NationalAssociation, as General Master Servicer

34.2       National Cooperative Bank,N.A., as NCB Master Servicer

34.3       Midland Loan Services, aDivision of PNC Bank, National Association, 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, NationalAssociation, as Certificate Administrator

34.7       Wells Fargo Bank, NationalAssociation, as Custodian

34.8       Park Bridge Lender ServicesLLC, as Operating Advisor

34.9       CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant

34.10     National Tax Search, LLC,as Servicing Function Participant

34.11     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 1412 Broadway Mortgage Loan (seeExhibit 34.1)

34.12     Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the 1412Broadway Mortgage Loan (see Exhibit 34.3)

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

34.14     Wells Fargo Bank, NationalAssociation, as Custodian of the 1412 Broadway Mortgage Loan (see Exhibit 34.7)

34.15     Park Bridge LenderServices LLC, as Operating Advisor of the 1412 Broadway Mortgage Loan (seeExhibit 34.8)

34.16     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the 1412 BroadwayMortgage Loan (see Exhibit 34.9)

34.17     National Tax Search, LLC,as Servicing Function Participant of the 1412 Broadway Mortgage Loan (seeExhibit 34.10)

34.18     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Park Tower at Transbay Mortgage Loan(see Exhibit 34.1)

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

34.20     Wilmington Trust, National Association, as Trustee of the Park Tower at TransbayMortgage Loan (Omitted. See Explanatory Notes.)

34.21     Wells Fargo Bank, NationalAssociation, as Custodian of the Park Tower at Transbay Mortgage Loan (seeExhibit 34.7)

34.22     Park Bridge LenderServices LLC, as Operating Advisor of the Park Tower at Transbay Mortgage Loan(see Exhibit 34.8)

34.23     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Park Tower atTransbay Mortgage Loan (see Exhibit 34.9)

34.24     National Tax Search, LLC,as Servicing Function Participant of the Park Tower at Transbay Mortgage Loan(see Exhibit 34.10)

34.25     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Jackson Park Mortgage Loan (see Exhibit34.1)

34.26     AEGON USA RealtyAdvisors, LLC, as Special Servicer of the Jackson Park Mortgage Loan

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

34.28     Wells Fargo Bank, NationalAssociation, as Custodian of the Jackson Park Mortgage Loan (see Exhibit 34.7)

34.29     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Jackson ParkMortgage Loan (see Exhibit 34.9)

34.30     National Tax Search, LLC,as Servicing Function Participant of the Jackson Park Mortgage Loan (seeExhibit 34.10)

34.31     KeyBank NationalAssociation, as Primary Servicer of the Parklawn Building Mortgage Loan

34.32     LNR Partners, LLC, asSpecial Servicer of the Parklawn Building Mortgage Loan

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

34.34     Wells Fargo Bank, NationalAssociation, as Custodian of the Parklawn Building Mortgage Loan (see Exhibit34.7)

34.35     Park Bridge Lender ServicesLLC, as Operating Advisor of the Parklawn Building Mortgage Loan (see Exhibit34.8)

34.36     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the ILPT Industrial Portfolio Mortgage Loan(see Exhibit 34.1)

34.37     Situs Holdings, LLC, as Special Servicer of the ILPT Industrial PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

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

34.39     Wells Fargo Bank, NationalAssociation, as Custodian of the ILPT Industrial Portfolio Mortgage Loan (seeExhibit 34.7)

34.40     Park Bridge Lender ServicesLLC, as Operating Advisor of the ILPT Industrial Portfolio Mortgage Loan (seeExhibit 34.8)

34.41     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the ILPT IndustrialPortfolio Mortgage Loan (see Exhibit 34.9)

34.42     National Tax Search, LLC,as Servicing Function Participant of the ILPT Industrial Portfolio MortgageLoan (see Exhibit 34.10)

34.43     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 55 Hudson Yards Mortgage Loan (seeExhibit 34.1)

34.44     CWCapital AssetManagement LLC, as Special Servicer of the 55 Hudson Yards Mortgage Loan

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

34.46     Wells Fargo Bank, NationalAssociation, as Custodian of the 55 Hudson Yards Mortgage Loan (see Exhibit34.7)

34.47     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the 55 Hudson YardsMortgage Loan (see Exhibit 34.9)

34.48     National Tax Search, LLC,as Servicing Function Participant of the 55 Hudson Yards Mortgage Loan (seeExhibit 34.10)

34.49     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Giant Anchored Portfolio Mortgage Loan(see Exhibit 34.1)

34.50     LNR Partners, LLC, asSpecial Servicer of the Giant Anchored Portfolio Mortgage Loan (see Exhibit34.32)

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

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

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

34.54     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Giant AnchoredPortfolio Mortgage Loan (see Exhibit 34.9)

34.55     National Tax Search, LLC,as Servicing Function Participant of the Giant Anchored Portfolio Mortgage Loan(see Exhibit 34.10)

35          Servicer compliance statements.

35.1       Wells Fargo Bank, NationalAssociation, as General Master Servicer

35.2       National Cooperative Bank,N.A., as NCB Master Servicer

35.3       Midland Loan Services, aDivision of PNC Bank, National Association, as General Special Servicer

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

35.5       Wells Fargo Bank, NationalAssociation, as Certificate Administrator

35.6       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 1412 Broadway Mortgage Loan (seeExhibit 35.1)

35.7       Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the 1412Broadway Mortgage Loan (see Exhibit 35.3)

35.8       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Park Tower at Transbay Mortgage Loan(see Exhibit 35.1)

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

35.10     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Jackson Park Mortgage Loan (see Exhibit35.1)

35.11     AEGON USA Realty Advisors, LLC, as Special Servicer of the Jackson ParkMortgage Loan (Omitted. See Explanatory Notes.)

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

35.13     LNR Partners, LLC, as Special Servicer of the Parklawn Building Mortgage Loan(Omitted. See Explanatory Notes.)

35.14     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the ILPT Industrial Portfolio Mortgage Loan(see Exhibit 35.1)

35.15     Situs Holdings, LLC, as Special Servicer of the ILPT Industrial PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

35.16     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 55 Hudson Yards Mortgage Loan (seeExhibit 35.1)

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

35.18     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Giant Anchored Portfolio Mortgage Loan(see Exhibit 35.1)

35.19     LNR Partners, LLC, as Special Servicer of the Giant Anchored Portfolio MortgageLoan (Omitted. See Explanatory Notes.)

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/ LelandF. Bunch, III

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

(senior officer in charge of securitizationof the depositor)

Date: March 23, 2020