**UNITED STATESSECURITIES AND EXCHANGE COMMISSION**

**Washington, D.C. 20549**

**FORM 10-K**

(Mark One)

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

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

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

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

**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 acceleratedfiler        o                                                                                                       Acceleratedfiler                                     o

Non-acceleratedfiler          ⌧  (Do not check if asmaller reporting company)                          Smaller reportingcompany                    o

                                                                                                                                                       Emerging growthcompany                    o

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

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

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

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

Not applicable.

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

Not applicable.

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

Not applicable.

**DOCUMENTS INCORPORATED BY REFERENCE**

** **

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

Not applicable.

 

** **

**EXPLANATORY NOTES**

The 1412 Broadway Mortgage Loan, whichconstituted approximately 8.2% of the asset pool of the issuing entity as ofits cut-off date, is an asset of the issuing entity and is part of a loancombination that includes the 1412 Broadway Mortgage Loan and two other *paripassu* loans, which are not assets of the issuing entity. This loancombination, including the 1412 Broadway Mortgage Loan, is being serviced andadministered pursuant to the Pooling and Servicing Agreement, which isincorporated by reference as Exhibit 4.1 to this Annual Report on Form 10-K. 

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Park Tower at Transbay Mortgage Loan, whichconstituted approximately 4.1% of the asset pool of the issuing entity as ofits cut-off date.  The Park Tower at Transbay Mortgage Loan is an asset ofthe issuing entity and is part of a loan combination that includes the ParkTower at Transbay Mortgage Loan and nine other *pari passu* loans, whichare not assets of the issuing entity. A *pari passu* portion of the loancombination was securitized in the BANK 2019-BNK21 transaction, Commission FileNumber 333-228375-02 (the “BANK 2019-BNK21 Transaction”). This loancombination, including the Park Tower at Transbay Mortgage Loan, is beingserviced and administered pursuant to the pooling and servicing agreement forthe BANK 2019-BNK21 Transaction, which is incorporated by reference as Exhibit4.2 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on 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 theissuing entity 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 *pari passu*portion of the loan combination was securitized in the Jackson Park Trust2019-LIC transaction (the “JAX 2019-LIC Transaction”). This loancombination, including the Jackson Park Mortgage Loan, is being serviced andadministered pursuant to the trust and servicing agreement for the JAX 2019-LICTransaction, which is incorporated by reference as Exhibit 4.3 to this AnnualReport 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 Parklawn BuildingMortgage Loan, four other *pari passu* loans, which are not assets of theissuing entity or (b) with respect to the ILPT Industrial Portfolio MortgageLoan, seven other *pari passu* loans and twelve subordinate companionloans, which are not assets of the issuing entity. A *pari passu* portionof each loan combination was securitized in the Morgan Stanley Capital I Trust2019-L3 transaction, Commission File Number 333-227446-07 (the “MSC 2019-L3Transaction”). These loan combinations, including the Parklawn BuildingMortgage Loan and the ILPT Industrial Portfolio Mortgage Loan, are beingserviced and administered pursuant to the pooling and servicing agreement forthe MSC 2019-L3 Transaction, which is incorporated by reference as Exhibit 4.4to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the 55 Hudson Yards Mortgage Loan, whichconstituted approximately 8.2% of the asset pool of the issuing entity as ofits cut-off date.  The 55 Hudson Yards Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the 55 HudsonYards Mortgage Loan, thirty-one other *pari passu* loans and threesubordinate companion loans, which are not assets of the issuing entity. A *paripassu* portion of the loan combination was securitized in the Hudson Yards2019-55HY Mortgage Trust transaction (the “Hudson Yards 2019-55HYTransaction”). This loan combination, including the 55 Hudson Yards MortgageLoan, is being serviced and administered pursuant to the trust and servicingagreement for the Hudson Yards 2019-55HY Transaction, which is incorporated byreference as Exhibit 4.5 to this Annual Report on Form 10-K.

The Exhibit Index describes exhibitsprovided by certain parties (in their capacities indicated on the ExhibitIndex) with respect to the Giant Anchored Portfolio Mortgage Loan, whichconstituted approximately 2.4% of the asset pool of the issuing entity as ofits cut-off date.  The Giant Anchored Portfolio Mortgage Loan is an assetof the issuing entity and is part of a loan combination that includes the GiantAnchored Portfolio Mortgage Loan and three other *pari passu* loans, whichare not assets of the issuing entity. A *pari passu* portion of the loancombination was securitized in the Citigroup Commercial Mortgage Trust 2019-C7transaction, Commission File Number 333-228597-05 (the “CGCMT 2019-C7Transaction”). 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 (except withrespect to those mortgage loans for which National Cooperative Bank, N.A. isthe master servicer) and certificate administrator of the mortgage loansserviced under the Pooling and Servicing Agreement and the primary servicer ofthe 55 Hudson Yards Mortgage Loan, the Jackson Park Mortgage Loan, thePark Tower at Transbay Mortgage Loan, the Giant Anchored Portfolio MortgageLoan and the ILPT Industrial Portfolio Mortgage Loan. As a result, Wells FargoBank, National Association is a “servicer” as defined in Item 1108(a)(2)(iii)of Regulation AB, in the capacities described above, because it is servicingmortgage loans that constituted 10% or more of the assets of the issuing entityas of its cut-off date. The assessments of compliance with applicable servicingcriteria, accountants’ attestation reports and servicer compliance statementsdelivered by Wells Fargo Bank, National Association in the capacities describedabove are listed in the Exhibit Index.

Wells Fargo Bank, National Association is the custodian ofthe mortgage loans serviced under the Pooling and Servicing Agreement, the 55 Hudson Yards Mortgage Loan, the Jackson ParkMortgage Loan, the Parklawn Building Mortgage Loan, the Park Tower at TransbayMortgage Loan and the ILPT Industrial Portfolio Mortgage Loan.  As aresult, Wells Fargo Bank, National Association is a servicing functionparticipant in the capacities described above, because it is servicing mortgageloans that constituted 5% or more of the assets of the issuing entity as of itscut-off date. The assessments of compliance with applicable servicing criteriaand accountants’ attestation reports delivered by Wells Fargo Bank, NationalAssociation in the capacities described above are listed in the Exhibit Index.

LNR Partners, LLC is the special servicer (except withrespect to those mortgage loans for which National Cooperative Bank, N.A. isthe special servicer) of the mortgage loans serviced under the Pooling andServicing Agreement on and after July 13, 2021, the Parklawn Building MortgageLoan and the Giant Anchored Portfolio Mortgage Loan. As a result, LNR Partners,LLC is a “servicer” as defined in Item 1108(a)(2)(iii) of Regulation AB, in thecapacities described above, because it is servicing mortgage loans thatconstituted 10% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby Wells Fargo Bank, National Association in the capacities described above arelisted in the Exhibit Index.

Park Bridge Lender Services LLC is the operating advisor ofthe mortgage loans serviced under the Pooling and Servicing Agreement, 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.

AEGON USA Realty Advisors, LLC isthe special servicer of the Jackson Park Mortgage Loan, which constitutedapproximately 8.2% of the asset pool of the issuing entity as of its cut-offdate. In accordance with the Compliance and Disclosure Interpretations, Section200.03 (Rules 13a-18 and 15d-18, Servicer’s Assessment of Compliance), thispercentage must be reduced *pro rata*because it was only acting asspecial servicer of the Jackson Park Mortgage Loan from January 1, 2021 to May20, 2021. As a result, it falls below the *de minimis*requirements inItem 1122 of Regulation AB and no such assessment or attestation is required.

Situs Holdings, LLC is the specialservicer of the Jackson Park Mortgage Loan and the ILPT Industrial PortfolioMortgage Loan, which constituted approximately 8.2% and 2.0%, respectively, ofthe asset pool of the issuing entity as of its cut-off date. In accordance withthe Compliance and Disclosure Interpretations, Section 200.03 (Rules 13a-18 and15d-18, Servicer’s Assessment of Compliance), this percentage must be reducedpro rata because it was only acting as special servicer of the Jackson ParkMortgage Loan from May 21, 2021 to December 31, 2021. As a result, Situs Holdings,LLC is an unaffiliated party that, as a result of such pro rata reduction ofsuch percentage, is not a “servicer” that meets the criteria in Item1108(a)(2)(i) through (iii) of Regulation AB and so no servicer compliancestatement is required.

Wilmington Trust, NationalAssociation acts as trustee of  the mortgage loans serviced under thePooling and Servicing Agreement, the Park Tower at Transbay Mortgage Loan, theJackson Park Mortgage Loan, the Parklawn Building Mortgage Loan, the ILPTIndustrial Portfolio Mortgage Loan, the 55 Hudson Yards Mortgage Loan and theGiant Anchored Portfolio Mortgage Loan.  Pursuant to the Pooling andServicing Agreement, the pooling and servicing agreement for the BANK2019-BNK21 Transaction, 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 servicersof  the mortgage loans serviced under the Pooling and Servicing Agreement,the Park Tower at Transbay Mortgage Loan, the Jackson Park Mortgage Loan, theParklawn Building Mortgage Loan, the ILPT Industrial Portfolio Mortgage Loan,the 55 Hudson Yards Mortgage Loan and the Giant Anchored Portfolio MortgageLoan have delivered one or more assessments of compliance with respect to Item1122(d)(2)(iii) of Regulation AB.

This Annual Report on Form 10-Kincludes assessments of compliance with applicable servicing criteria andaccountants’ attestation reports from CoreLogic Solutions, LLC  Thisentity was engaged by the master servicer under the Pooling and ServicingAgreement and the primary servicer of the Jackson Park Mortgage Loan, the ParkTower at Transbay Mortgage Loan, the ILPT Industrial Portfolio Mortgage Loan,the 55 Hudson Yards Mortgage Loan and the Giant Anchored Portfolio MortgageLoan to remit tax payments received from the escrow accounts of borrowers tolocal taxing authorities, to report tax amounts due, to verify tax parcelinformation, and to verify non-escrow tax payments. These servicing functionsare included within the servicing criteria set forth in Items 1122(d)(4)(xi)and 1122(d)(4)(xii) of Regulation AB.  Therefore, under theprinciples-based definition of “servicer” set forth in Item 1101(j) ofRegulation AB that looks to the functions that an entity performs, this vendoris a “servicer” for the purposes of Item 1122 of Regulation AB.  *See*Compliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

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

Theassessments of compliance with applicable servicing criteria, accountants’attestation reports and servicer compliance statements of the certificateadministrator of the Park Tower at Transbay Mortgage Loan, the Jackson ParkMortgage Loan, the ILPT Industrial Portfolio Mortgage Loan, the 55 Hudson YardsMortgage Loan, the Parklawn Building Mortgage Loan and the Giant AnchoredPortfolio Mortgage Loan are omitted from this Annual Report on Form 10-K as thecertificate administrator pursuant to the related pooling and servicingagreement or trust and servicing agreement does not perform any activities thataddress servicing criteria with respect to the issuing entity and because theyare each not a “servicer” that meets the criteria in Item 1108(a)(2)(i) through(iii) of Regulation AB.

With respect to the *pari passu*loan combinations that include the 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 and 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 and Pentalpha Surveillance LLC asoperating advisor of the Giant Anchored Portfolio Mortgage Loan, listed on theExhibit Index are omitted from this Annual Report on Form 10-K as they are notrequired to be included on this Annual Report on Form 10-K per Instruction 3 toItem 1122 of Regulation AB because they are parties performing activities thataddress servicing criteria relating to 5% or less of the assets of the issuingentity, and the report on assessment of compliance with servicing criteria andattestation report on assessment of compliance with servicing criteria of AEGONUSA Realty Advisors, LLC as special servicer of the Jackson Park Mortgage Loanprior to May 21, 2021 listed on the Exhibit Index are omitted from this AnnualReport on Form 10-K for the reasons set forth in the Explanatory Notes above;and (ii) the servicer compliance statements of Rialto Capital Advisors, LLC asspecial servicer of the Park Tower at Transbay Mortgage Loan, AEGON USA RealtyAdvisors, LLC as special servicer of the Jackson Park Mortgage Loan prior toMay 21, 2021, KeyBank National Association as primary servicer of the ParklawnBuilding Mortgage Loan and CWCapital Asset Management LLC as special servicerof the 55 Hudson Yards Mortgage Loan, listed on the Exhibit Index are omittedfrom this Annual Report on Form 10-K as they are not required by Item 1123 ofRegulation AB to be included on this Annual Report on Form 10-K because theyare each an unaffiliated party that is not a “servicer” that meets the criteriain Item 1108(a)(2)(i) through (iii) of Regulation AB, and the servicercompliance statement of Situs Holdings, LLC as special servicer of the JacksonPark Mortgage Loan on and after May 21, 2021 and the ILPT Industrial PortfolioMortgage Loan listed on the Exhibit Index is omitted from this Annual Report onFrom 10-K for the reasons set forth in the Explanatory Notes above. 

**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 DerivativesInstruments (Financial Information).**

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

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

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

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

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

On December 1, 2017, a complaint against CWCAM and others wasfiled in the United States District Court for the Southern District of New Yorkstyled as CWCapital Cobalt Vr Ltd. v. CWCapital Investments LLC, et al., No.17-cv-9463 (the “Original Complaint”). The gravamen of theOriginal  Complaint alleged breaches of a contract and fiduciary duties byCWCAM’s affiliate, CWCapital Investments LLC in its capacity as collateralmanager for the collateralized debt obligation transaction involving CWCapitalCobalt Vr, Ltd. In total, there are 14 counts pled in the Original Complaint.Of those 14, 5 claims were asserted against CWCAM for aiding and abettingbreach of fiduciary duty, conversion and unjust enrichment. On May 23, 2018,the Original Complaint was dismissed for lack of subject matterjurisdiction.   On June 28, 2018, CWCapital Cobalt Vr Ltd. filed asubstantially similar complaint in the Supreme Court of the State of New York,County of New York styled as CWCapital Cobalt Vr Ltd. v. CWCapital InvestmentsLLC, et al., Index No. 653277/2018 (the “New Complaint”).  Thegravamen of the New Complaint is the same as the previous complaint filed inthe United State District Court for the Southern District of New York.  Intotal there are 16 counts pled in the New Complaint. Of those 16 counts, 5claims were asserted against CWCAM for aiding and abetting breach of fiduciaryduty, conversion and unjust enrichment, 1 count seeks a declaratory judgementthat the plaintiff has the right to enforce the contracts in question and 1count seeks an injunction requiring the defendants to recognize the plaintiffas the directing holder for the trusts in question. On January 11, 2019, theplaintiff dismissed with prejudice the declaratory judgment and injunctioncounts.  The New Complaint and related summons was not served on thedefendants until July 13, 2018 and July 16, 2018.  The plaintiff’s motionfor a preliminary injunction was denied by the court on July 31, 2018.  OnAugust 3, 2018, the defendants, including CWCAM, filed a motion to dismiss theNew Complaint in its entirety. On August 20, 2019, the court entered an ordergranting defendants’ motion almost in its entirety, dismissing 11 of the 16 countsand partially dismissing 2 additional counts.  Of the remaining counts, 2are asserted against CWCAM for aiding and abetting breach of fiduciary duty andunjust enrichment.  On September 19, 2019, CWCapital Cobalt Vr Ltd. fileda notice of appeal relating to the August 20, 2019 dismissal order and onSeptember 26, 2019, filed an amended complaint against CWCI and CWCAMattempting to address deficiencies relating to certain of the claims dismissedby the August, 20, 2019 order.  CWCI and CWCAM filed its Motion to Dismissthe amended complaint on October 28, 2019.  The court heard argument onthe Motion to Dismiss the amended complaint on January 22, 2020 and on October23, 2020, the court granted the motion dismissing the amended claims.  OnNovember 30, 2020, CWCapital Cobalt Vr Ltd filed a notice of appeal relating tothe October 23, 2020 dismissal order.  On April 27, 2021, the FirstDepartment affirmed the dismissal as to claims against CWCAM that were part ofthe August 20, 2019 dismissal, but reversed the dismissal of two counts forbreach of the Collateral Management Agreement against CWCI.  CWCI hassought leave to file an appeal of the decision.  Both requests for leavewere denied by the First Department.  The plaintiff has also sought leaveto appeal the dismissal of the claims against CWCAM.  CWCAM believes thatit has performed its obligations under the related pooling and servicingagreements in good faith and the remaining allegations in the New Complaint arewithout merit.  

On January 24, 2016 PSW NYC LLCcommenced a complaint (the “PSW Complaint”) with the Supreme Court of the Stateof New York, County of New York (the “PSW Court”) against Bank of America, N.A.as trustee under the pooling and servicing agreements for Wachovia Bank CommercialMortgage Trust 2007-C30 and COBALT CMBS Commercial Trust 2007-C2, U.S. BankNational Association as trustee under the pooling and servicing agreements forWachovia Bank Commercial Mortgage Trust 2007-C31, ML-CFC Commercial MortgageTrust 2007-5 and ML-CFC Commercial Mortgage Trust 2007-6 (collectively, the“PSW Trusts”), PCV-M Holdings LLC and CWCapital Asset Management LLC,individually and as special servicer for the PSW Trusts (collectively, the“Defendants”) seeking either (a) damages in an amount to be determined by thePSW Court but alleged by the plaintiffs to be approximately $500,000,000 – suchamount being the amount PSW NYC LLC alleges would have been recovered oncertain mezzanine loans (the “PCVST Mezzanine Loans”) related to the PeterCooper Village and Stuyvesant Town property (the “PCVST Property”) in New YorkCity which PSW NYC LLC sold to an entity related to the Defendants pursuant toa settlement agreement related to certain prior litigation (the “2010Settlement Agreement”) or (b) the rescission of the 2010 Settlement Agreementwhich would result in, among other things, the rescission of the sale of thePCVST Mezzanine Loans and a claim for certain proceeds from the sale of thePCVST Property. PSW NYC LLC alleges that the Defendants procured the 2010Settlement Agreement by fraud and further that the terms of the 2010 SettlementAgreement were breached by the Defendants. On February 26, 2016, CWCAM onbehalf of itself and the other Defendants filed a motion to dismiss the PSWComplaint (the “CWCAM Motion to Dismiss”). On April 11, 2016, PSW NYC LLCopposed the CWCAM Motion to Dismiss and cross-moved for a partial summaryjudgment on liability regarding allegations of breach of the 2010 SettlementAgreement (the “PSW Cross-Motion”). On May 5, 2016, the Defendants subsequentlyfiled its reply and opposition to the PSW Cross-Motion. On August 23, 2016,oral arguments were provided to the PSW Court regarding the PSW Complaint, theCWCAM Motion to Dismiss and the PSW Cross-Motion and the PSW Court took sucharguments under advisement. On October 31, 2016, the PSW Court issued an ordergranting the CWCAM Motion to Dismiss, denying the PSW Cross-Motion anddismissing the PSW Complaint with prejudice. Subsequently, PSW NYC LLC filed anotice of appeal relating to such order. On February 21, 2017, PSW NYC LLCfiled its appeal and supporting brief arguing that the PSW Court erred byfinding no breach of the assignment agreement and no fraudulent inducement.Oral argument was heard on May 4, 2017 at which point the court took thearguments under advisement. On May 25, 2017, the New York 1stDepartment appellate court affirmed the dismissal of all PSW claims and denieda request for leave to appeal to the New York Court of Appeals on September 12,2017.  

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

 

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

 

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

 

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

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

The information regarding this Item has been previouslyprovided in the prospectus of the Registrant relating to the issuing entityfiled on December 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 servicingagreement for the JAX 2019-LIC Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit K to the trust andservicing agreement for the JAX 2019-LIC Transaction incorporated by referenceas Exhibit 4.3 to this Annual Report on Form 10-K is a chart identifying theentities participating 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 setforth in Item 1122(d).

The report on assessment of compliance for the twelve monthsended December 31, 2021, furnished pursuant to Item 1122 of Regulation AB byAegon USA Realty Advisors, LLC (“Aegon” or the “Company”), as special servicer,discloses that the following material instance of noncompliance occurred withrespect to its platform:

The examination performed by PWC identified an instance ofmaterial noncompliance with the servicing criteria set forth in Item1122(d)(3)(i)(A) of Regulation AB applicable to the Company during year endedDecember 31, 2021. More specifically, for the only active special serviced dealsubject to Item 1122(d)(3)(i)(A), the report to the investors was not preparedin accordance with the timeframes and other terms set forth in the transactionagreements for the period of January 1, 2021 to January 21, 2021. UBSCM 2017-C4is the specific deal related to the aforementioned finding. No other dealswithin Aegon’s CMBS special servicing portfolio were related to or impacted bythis instance of non-compliance.

Management acknowledges the timeframe for reporting for thisactive special serviced deal was missed by two days. Despite the timingdiscrepancy, there was no impact on any investor reporting, issuing, orservicing. No additional testing was available for this particular criteria dueto the downsizing of the CMBS portfolio given Aegon’s pending exit from thebusiness line.

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

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

The servicer compliance statement for the twelve months endedDecember 31, 2021, furnished pursuant to Item 1123 of Regulation AB by AegonUSA Realty Advisors, LLC (“Aegon” or the “Company”), as special servicer,discloses that the following material instance of noncompliance occurred withrespect to its platform:

The examination performed by PWC identified an instance ofmaterial noncompliance with the servicing criteria set forth in Item1122(d)(3)(i)(A) of Regulation AB applicable to the Company during year endedDecember 31, 2021. More specifically, for the only active special serviced dealsubject to Item 1122(d)(3)(i)(A), the report to the investors was not preparedin accordance with the timeframes and other terms set forth in the transactionagreements for the period of January 1, 2021 to January 21, 2021. UBSCM 2017-C4is the specific deal related to the aforementioned finding. No other dealswithin Aegon’s CMBS special servicing portfolio were related to or impacted by thisinstance of non-compliance.

Management acknowledges the timeframe for reporting for thisactive special serviced deal was missed by two days. Despite the timingdiscrepancy, there was no impact on any investor reporting, issuing, orservicing. No additional testing was available for this particular criteria dueto the downsizing of the CMBS portfolio given Aegon’s pending exit from thebusiness line.

 

**PART IV**

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

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

(1) Not applicable

(2) Not applicable

(3) See below

4.1          Poolingand Servicing Agreement, dated 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 Lender ServicesLLC, as Operating Advisor and as Asset Representations Reviewer (filed asExhibit 4.1 to the registrant’s Current Report on Form 8-K filed on December19, 2019 under Commission File No. 333-228375-03 and incorporated by referenceherein).

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

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

4.4          Poolingand Servicing Agreement, dated and effective as of November 1, 2019, betweenMorgan Stanley Capital I Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, LNR Partners, LLC, as General SpecialServicer, Situs Holdings, LLC, as ILPT Industrial Portfolio Special Servicer,Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Park Bridge LenderServices LLC, as Operating Advisor and Asset Representations Reviewer (filed asExhibit 4.4 to the registrant’s Current Report on Form 8-K/A filed on January6, 2020 under Commission File No. 333-228375-03 and incorporated by referenceherein).

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

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

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

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

33.1        Wells Fargo Bank, National Association, as GeneralMaster Servicer

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

33.3        Midland Loan Services, a Division of PNC Bank,National Association, as General Special Servicer prior to July 13, 2021

33.4        LNR Partners, LLC, as General Special Servicer onand after July 13, 2021

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

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

33.7        Wells Fargo Bank, National Association, asCertificate Administrator

33.8        Wells Fargo Bank, National Association, asCustodian

33.9        Park Bridge Lender Services LLC, as OperatingAdvisor

33.10      CoreLogic Solutions, LLC, as Servicing FunctionParticipant

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

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

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

33.14      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the 1412 Broadway Mortgage Loanprior to July 13, 2021 (see Exhibit 33.3)

33.15      LNR Partners, LLC, as Special Servicer of the 1412Broadway Mortgage Loan on and after July 13, 2021 (see Exhibit 33.4)

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

33.17      Wells Fargo Bank, National Association, asCustodian of the 1412 Broadway Mortgage Loan (see Exhibit 33.8)

33.18      Park Bridge Lender Services LLC, as OperatingAdvisor of the 1412 Broadway Mortgage Loan (see Exhibit 33.9)

33.19      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 1412 Broadway Mortgage Loan (see Exhibit 33.10)

33.20      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.12)

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

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

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

33.24      Wells Fargo Bank, National Association, asCustodian of the Park Tower at Transbay Mortgage Loan (see Exhibit 33.8)

33.25      Park Bridge Lender Services LLC, as Operating Advisorof the Park Tower at Transbay Mortgage Loan (see Exhibit 33.9)

33.26      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Park Tower at Transbay Mortgage Loan (see Exhibit 33.10)

33.27      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.12)

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

33.29      AEGON USA Realty Advisors, LLC, as Special Servicer of the Jackson ParkMortgage Loan prior to May 21, 2021 (Omitted. See Explanatory Notes.)

33.30      Situs Holdings, LLC, as Special Servicer of theJackson Park Mortgage Loan on and after May 21, 2021

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

33.32      Wells Fargo Bank, National Association, asCustodian of the Jackson Park Mortgage Loan (see Exhibit 33.8)

33.33      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Jackson Park Mortgage Loan (see Exhibit 33.10)

33.34      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.12)

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

33.36      LNR Partners, LLC, as Special Servicer of theParklawn Building Mortgage Loan (see Exhibit 33.4)

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

33.38      Wells Fargo Bank, National Association, asCustodian of the Parklawn Building Mortgage Loan (see Exhibit 33.8)

33.39      Park Bridge Lender Services LLC, as OperatingAdvisor of the Parklawn Building Mortgage Loan (see Exhibit 33.9)

33.40      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.12)

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

33.42      Situs Holdings, LLC, as Special Servicer of theILPT Industrial Portfolio Mortgage Loan (see Exhibit 33.30)

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

33.44      Wells Fargo Bank, National Association, asCustodian of the ILPT Industrial Portfolio Mortgage Loan (see Exhibit 33.8)

33.45      Park Bridge Lender Services LLC, as OperatingAdvisor of the ILPT Industrial Portfolio Mortgage Loan (see Exhibit 33.9)

33.46      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the ILPT Industrial Portfolio Mortgage Loan (see Exhibit 33.10)

33.47      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.12)

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

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

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

33.51      Wells Fargo Bank, National Association, asCustodian of the 55 Hudson Yards Mortgage Loan (see Exhibit 33.8)

33.52      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 55 Hudson Yards Mortgage Loan (see Exhibit 33.10)

33.53      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.12)

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

33.55      LNR Partners, LLC, as Special Servicer of the GiantAnchored Portfolio Mortgage Loan (see Exhibit 33.4)

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

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

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

33.59      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Giant Anchored Portfolio Mortgage Loan (see Exhibit 33.10)

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

34.1        Wells Fargo Bank, National Association, as GeneralMaster Servicer

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

34.3        Midland Loan Services, a Division of PNC Bank,National Association, as General Special Servicer prior to July 13, 2021

34.4        LNR Partners, LLC, as General Special Servicer onand after July 13, 2021

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

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

34.7        Wells Fargo Bank, National Association, asCertificate Administrator

34.8        Wells Fargo Bank, National Association, asCustodian

34.9        Park Bridge Lender Services LLC, as OperatingAdvisor

34.10      CoreLogic Solutions, LLC, as Servicing FunctionParticipant

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

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

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

34.14      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the 1412 Broadway Mortgage Loanprior to July 13, 2021 (see Exhibit 34.3)

34.15      LNR Partners, LLC, as Special Servicer of the 1412Broadway Mortgage Loan on and after July 13, 2021 (see Exhibit 34.4)

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

34.17      Wells Fargo Bank, National Association, asCustodian of the 1412 Broadway Mortgage Loan (see Exhibit 34.8)

34.18      Park Bridge Lender Services LLC, as OperatingAdvisor of the 1412 Broadway Mortgage Loan (see Exhibit 34.9)

34.19      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 1412 Broadway Mortgage Loan (see Exhibit 34.10)

34.20      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.12)

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

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

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

34.24      Wells Fargo Bank, National Association, asCustodian of the Park Tower at Transbay Mortgage Loan (see Exhibit 34.8)

34.25      Park Bridge Lender Services LLC, as OperatingAdvisor of the Park Tower at Transbay Mortgage Loan (see Exhibit 34.9)

34.26      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Park Tower at Transbay Mortgage Loan (see Exhibit 34.10)

34.27      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.12)

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

34.29      AEGON USA Realty Advisors, LLC, as Special Servicer of the Jackson ParkMortgage Loan prior to May 21, 2021 (Omitted. See Explanatory Notes.)

34.30      Situs Holdings, LLC, as Special Servicer of theJackson Park Mortgage Loan on and after May 21, 2021

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

34.32      Wells Fargo Bank, National Association, asCustodian of the Jackson Park Mortgage Loan (see Exhibit 34.8)

34.33      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Jackson Park Mortgage Loan (see Exhibit 34.10)

34.34      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.12)

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

34.36      LNR Partners, LLC, as Special Servicer of theParklawn Building Mortgage Loan (see Exhibit 34.4)

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

34.38      Wells Fargo Bank, National Association, asCustodian of the Parklawn Building Mortgage Loan (see Exhibit 34.8)

34.39      Park Bridge Lender Services LLC, as OperatingAdvisor of the Parklawn Building Mortgage Loan (see Exhibit 34.9)

34.40      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.12)

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

34.42      Situs Holdings, LLC, as Special Servicer of theILPT Industrial Portfolio Mortgage Loan (see Exhibit 34.30)

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

34.44      Wells Fargo Bank, National Association, asCustodian of the ILPT Industrial Portfolio Mortgage Loan (see Exhibit 34.8)

34.45      Park Bridge Lender Services LLC, as OperatingAdvisor of the ILPT Industrial Portfolio Mortgage Loan (see Exhibit 34.9)

34.46      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the ILPT Industrial Portfolio Mortgage Loan (see Exhibit 34.10)

34.47      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.12)

34.48      Wells Fargo Bank, National Association, as Primary Servicerof the 55 Hudson Yards Mortgage Loan (see Exhibit 34.1)

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

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

34.51      Wells Fargo Bank, National Association, asCustodian of the 55 Hudson Yards Mortgage Loan (see Exhibit 34.8)

34.52      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 55 Hudson Yards Mortgage Loan (see Exhibit 34.10)

34.53      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.12)

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

34.55      LNR Partners, LLC, as Special Servicer of the GiantAnchored Portfolio Mortgage Loan (see Exhibit 34.4)

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

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

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

34.59      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Giant Anchored Portfolio Mortgage Loan (see Exhibit 34.10)

35           Servicer compliance statements.

35.1        Wells Fargo Bank, National Association, as GeneralMaster Servicer

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

35.3        Midland Loan Services, a Division of PNC Bank,National Association, as General Special Servicer prior to July 13, 2021

35.4        LNR Partners, LLC, as General Special Servicer onand after July 13, 2021

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

35.6        Wells Fargo Bank, National Association, asCertificate Administrator

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

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

35.9        Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the 1412 Broadway Mortgage Loanprior to July 13, 2021 (see Exhibit 35.3)

35.10      LNR Partners, LLC, as Special Servicer of the 1412Broadway Mortgage Loan on and after July 13, 2021 (see Exhibit 35.4)

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

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

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

35.14      AEGON USA Realty Advisors, LLC, as Special Servicer of the Jackson ParkMortgage Loan prior to May 21, 2021 (Omitted. See Explanatory Notes.)

35.15      Situs Holdings, LLC, as Special Servicer of the Jackson Park Mortgage Loan onand after May 21, 2021 (Omitted. See Explanatory Notes.)

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

35.17      LNR Partners, LLC, as Special Servicer of theParklawn Building Mortgage Loan (see Exhibit 35.4)

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

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

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

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

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

35.23      LNR Partners, LLC, as Special Servicer of the GiantAnchored Portfolio Mortgage Loan (see Exhibit 35.4)

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 Current Reporton Form 8-K filed on December 19, 2019 under Commission File No. 333-228375-03and 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 ofsecuritization of the depositor)

Date: March 15, 2022