**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: 333-228697-03**

**Central Index Key Number of the issuing entity:0001793744**

**CF 2019-CF3 Mortgage Trust**

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

** **

**Central Index Key Number of the depositor: 0001515166**

**CCRE Commercial MortgageSecurities, L.P.**

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

** **

**Central Index Key Number of the sponsor: 0001558761**

**Cantor Commercial Real EstateLending, L.P.**

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

** **

**Central Index Key Number of the sponsor: 0001089877**

**KeyBank National Association**

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

** **

**Central Index Key Number of the sponsor: 0001548405**

**Starwood Mortgage Capital LLC**

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

** **

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

**the issuing entity)** | **38-4129048**

**38-4129049**

**(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:**

**(212) 915-1700**

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 reporting company                    o

                                                                                                                                                       Emerging growthcompany                    o

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

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

Indicate by check mark whether the registrant is a shell company(as defined in Rule 12b-2 of the Act).  oYes ⌧ 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 Airport Square Mortgage Loan, whichconstituted approximately 3.2% 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 Airport Square Mortgage Loan and one other *paripassu* loan, which is not an asset of the issuing entity. This loancombination, including the Airport Square 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 3 Columbus Circle Mortgage Loan, whichconstituted approximately 3.2% of the asset pool of the issuing entity as ofits cut-off date.  The 3 Columbus Circle Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the 3 ColumbusCircle Mortgage Loan, fifteen 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 Benchmark 2019-B10Mortgage Trust transaction, Commission File Number 333-226943-02 (the “Benchmark2019-B10 Transaction”). This loan combination, including the 3 ColumbusCircle Mortgage Loan, is being serviced and administered pursuant to thepooling and servicing agreement for the Benchmark 2019-B10 Transaction, whichis incorporated by reference as Exhibit 4.2 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 Bushwick Avenue Portfolio Mortgage Loan,which constituted approximately 2.4% of the asset pool of the issuing entity asof its cut-off date.  The Bushwick Avenue Portfolio Mortgage Loan is anasset of the issuing entity and is part of a loan combination that includes theBushwick Avenue Portfolio Mortgage Loan and four other *pari passu* loans,which are not assets of the issuing entity. A *pari passu* portion of theloan combination was securitized in the CF 2019-CF2 Mortgage Trust transaction,Commission File Number 333-228697-02 (the “CF 2019-CF2 Transaction”).This loan combination, including the Bushwick Avenue Portfolio Mortgage Loan,is being serviced and administered pursuant to the pooling and servicingagreement for the CF 2019-CF2 Transaction, which is incorporated by referenceas 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 Century Plaza Towers Mortgage Loan, whichconstituted approximately 6.3% of the asset pool of the issuing entity as ofits cut-off date.  The Century Plaza Towers Mortgage Loan is an asset ofthe issuing entity and is part of a loan combination that includes the CenturyPlaza Towers Mortgage Loan, twenty-seven other *pari passu* loans andthree subordinate companion loans, which are not assets of the issuing entity.A *pari passu* portion of the loan combination was securitized in the CPTS2019-CPT Mortgage Trust transaction (the “CPTS 2019-CPT Transaction”).This loan combination, including the Century Plaza Towers Mortgage Loan, isbeing serviced and administered pursuant to the trust and servicing agreement forthe CPTS 2019-CPT Transaction, which is incorporated by reference as Exhibit4.4 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 Parklawn Building Mortgage Loan and theWells Fargo Place Mortgage Loan, which constituted approximately 7.7% and 3.8%,respectively, of the asset pool of the issuing entity as of its cut-offdate.  The Parklawn Building Mortgage Loan and the Wells Fargo PlaceMortgage Loan are each an asset of the issuing entity and are each part of aloan combination that includes the Parklawn Building Mortgage Loan or the WellsFargo Place Mortgage Loan and three other *pari passu* loans, each ofwhich are not assets of the issuing entity. A *pari passu* portion of eachloan combination was securitized in the Morgan Stanley Capital I Trust 2019-L3transaction, Commission File Number 333-227446-07 (the “MSC 2019-L3Transaction”). These loan combinations, including the Parklawn BuildingMortgage Loan and the Wells Fargo Place Mortgage Loan, are being serviced andadministered pursuant to the pooling and servicing agreement for the MSC2019-L3 Transaction, which is incorporated by reference as Exhibit 4.5 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 225 Bush Mortgage Loan, which constitutedapproximately 3.6% of the asset pool of the issuing entity as of its cut-offdate.  The 225 Bush Mortgage Loan is an asset of the issuing entity and ispart of a loan combination that includes the 225 Bush Mortgage Loan, five other*pari passu* loans and one subordinate companion loan, which are notassets of the issuing entity. A *pari passu* portion of the loancombination was securitized in the Benchmark 2019-B14 Mortgage Trusttransaction, Commission File Number 333-226123-05 (the “Benchmark 2019-B14Transaction”). This loan combination, including the 225 Bush Mortgage Loan,is being serviced and administered pursuant to the pooling and servicingagreement for the Benchmark 2019-B14 Transaction, which is incorporated byreference as Exhibit 4.6 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 180 Water Mortgage Loan, which constitutedapproximately 3.2% of the asset pool of the issuing entity as of its cut-offdate.  The 180 Water Mortgage Loan is an asset of the issuing entity andis part of a loan combination that includes the 180 Water Mortgage Loan, fourother *pari passu* loans and one subordinate companion loan, which are notassets of the issuing entity. A *pari passu* portion of the loan combinationwas securitized in the COMM 2019-GC44 Mortgage Trust transaction, CommissionFile Number 333-226943-05 (the “COMM 2019-GC44 Transaction”). This loancombination, including the 180 Water Mortgage Loan, is being serviced andadministered pursuant to the pooling and servicing agreement for the COMM2019-GC44 Transaction, which is incorporated by reference as Exhibit 4.7 tothis 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 Central Tower Mortgage Loan, whichconstituted approximately 3.2% of the asset pool of the issuing entity as ofits cut-off date.  The Park Central Tower Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the Park CentralTower Mortgage Loan and one other *pari passu* loan, which is not an assetof the issuing entity. The other *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 Park Central TowerMortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the CGCMT 2019-C7 Transaction, which is incorporated byreference as Exhibit 4.8 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.

Midland Loan Services, a Divisionof PNC Bank, National Association is the master servicer and special servicerof the mortgage loans serviced under the Pooling and Servicing Agreement, theprimary servicer of the 180 Water Mortgage Loan and the 3 Columbus CircleMortgage Loan and the primary servicer and special servicer of the 225 BushMortgage Loan. As a result, Midland Loan Services, a Division of PNC Bank,National Association is a “servicer” as defined in Item 1108(a)(2)(iii) ofRegulation 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 Midland Loan Services, a Division of PNC Bank, NationalAssociation in the capacities described above are listed in the Exhibit Index.

Wells Fargo Bank, NationalAssociation is the certificate administrator of the mortgage loans servicedunder the Pooling and Servicing Agreement and the primary servicer of theCentury Plaza Towers Mortgage Loan, the Wells Fargo Place Mortgage Loan and thePark Central Tower Mortgage Loan. As a result, Wells Fargo Bank, NationalAssociation is a “servicer” as defined in Item 1108(a)(2)(iii) of RegulationAB, in the capacities described above, because it is servicing mortgage loansthat constituted 10% or more of the assets of the issuing entity as of itscut-off date. 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.

Wells Fargo Bank, National Association is the custodian ofthe mortgage loans serviced under the Pooling and Servicing Agreement, theParklawn Building Mortgage Loan, the Century Plaza Towers Mortgage Loan, theWells Fargo Place Mortgage Loan, the 225 Bush Mortgage Loan, the 180 WaterMortgage Loan and the 3 Columbus Circle Mortgage Loan.  As a result, WellsFargo Bank, National Association is a servicing function participant in thecapacities described above, because it is servicing mortgage loans thatconstituted 5% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria andaccountants’ attestation reports delivered by Wells Fargo Bank, NationalAssociation in the capacities 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 Wells Fargo Place Mortgage Loan, the 180Water Mortgage Loan and the Bushwick Avenue Portfolio Mortgage Loan.  As aresult, Park Bridge Lender Services LLC is a servicing function participant inthe capacities described above, because it is servicing mortgage loans thatconstituted 5% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria andaccountants’ attestation reports delivered by Park Bridge Lender Services LLCin the capacities described above are listed in the Exhibit Index.

KeyBank National Association isthe primary servicer of the Parklawn Building Mortgage Loan and the BushwickAvenue Portfolio Mortgage Loan. As a result, KeyBank National Association 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 KeyBank National Association in the capacities described above are listed inthe Exhibit Index.

LNR Partners, LLC is the specialservicer of the Parklawn Building Mortgage Loan, the Wells Fargo Place MortgageLoan, the Park Central Tower Mortgage Loan, the 3 Columbus Circle Mortgage Loanand the Bushwick Avenue Portfolio Mortgage Loan. As a result, LNR Partners, LLCis a “servicer” as defined in Item 1108(a)(2)(iii) of Regulation AB, in thecapacities described above, because it is servicing mortgage loans thatconstituted 10% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby LNR Partners, LLC in the capacities described above are listed in theExhibit Index.

CWCapitalAsset Management LLC is the special servicer of the Century Plaza TowersMortgage Loan and the 180 Water Mortgage Loan.  These mortgage loansconstitute more than 5%, but less than 10%, of the pool assets of the issuingentity.  Therefore, the Depositor included in this Annual Report on Form10-K an assessment of compliance with applicable servicing criteria forCWCapital Asset Management LLC and an accountants’ attestation report pursuantto Item 1122 of Regulation AB because CWCapital Asset Management LLC isservicing more than 5% of the pool assets.  However, the Depositor is notrequired to include in this Annual Report on Form 10-K a servicer compliancestatement pursuant to Item 1123 of Regulation AB of CWCapital Asset ManagementLLC because CWCapital Asset Management LLC is an unaffiliated servicerservicing less than 10% of pool assets.

Pentalpha Surveillance LLC is the operating advisor of the225 Bush Mortgage Loan, the Park Central Tower Mortgage Loan and the 3 ColumbusCircle Mortgage Loan.  As a result, Pentalpha Surveillance LLC is aservicing function participant in the capacities described above, because it isservicing mortgage loans that constituted 5% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria and accountants’ attestation reports delivered byPentalpha Surveillance LLC in the capacities described above are listed in theExhibit Index.

Citibank, N.A. is the custodian of the Park Central TowerMortgage Loan and the Bushwick Avenue Portfolio Mortgage Loan.  As aresult, Citibank, N.A. 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 Citibank, N.A. in the capacities describedabove are listed in the Exhibit Index, and exclude the servicing criteria setforth in Items 1122(d)(4)(i) and 1122(d)(4)(ii) of Regulation AB, relating to the maintenance of collateral or security on pool assets asrequired by the pooling and servicing agreement for the CGCMT 2019-C7Transaction and the pooling and servicing agreement for the CF 2019-CF2Transaction and the safeguarding of pool assets and related documents asrequired by the pooling and servicing agreement for the CGCMT 2019-C7 Transactionand the pooling and servicing agreement for the CF 2019-CF2 Transaction, whichservicing criteria have been assessed by U.S. Bank National Association, as aservicing function participant, as described below in these Explanatory Notes.

ThisAnnual Report on Form 10-K includes an assessment of compliance with applicableservicing criteria and an accountant’s attestation report from U.S. Bank,National Association. This entity was engaged by Citibank, N.A., as custodianof the Park Central Tower Mortgage Loan and the Bushwick Avenue PortfolioMortgage Loan to perform certain custodial services. These custodial servicesare servicing functions included within the servicing criteria set forth inItems 1122(d)(4)(i) and 1122(d)(4)(ii) of Regulation AB. Therefore, under theprinciples-based definition of “servicer” set forth in Item 1101(j) orRegulation AB that looks to the functions that an entity performs, this vendoris a “servicer” for the purposes of Item 1122 of Regulation AB. See Complianceand Disclosure Interpretations, Section 301.01 (Item 1101(j)).

Wells Fargo Bank, NationalAssociation acts as trustee of the Airport Square Mortgage Loan, the 3 ColumbusCircle Mortgage Loan, the 225 Bush Mortgage Loan and the 180 Water MortgageLoan.  Pursuant to the Pooling and Servicing Agreement, the pooling andservicing agreement for the Benchmark 2019-B10 Transaction, the pooling andservicing agreement for the Benchmark 2019-B14 Transaction and the pooling andservicing agreement for the COMM 2019-GC44 Transaction, the trustee is requiredto provide an assessment of compliance with applicable servicing criteriasolely with respect to Item 1122(d)(2)(iii) of Regulation AB (regardingadvances of funds or guarantees regarding collections, cash flows or distributions,and any interest or other fees charged for such advances, are made, reviewedand approved as specified in the transaction agreements). However, during thereporting period, the trustee did not perform any servicing function withrespect to the servicing criteria specified in Item 1122(d)(2)(iii) ofRegulation AB.  The master servicer or the special servicer, to the extentrequired, performed the servicing function identified with respect to Item1122(d)(2)(iii) of Regulation AB, and each such party included Item1122(d)(2)(iii) of Regulation AB in the assessment of compliance withapplicable servicing criteria and accountant’s attestation report for thesubject transaction.  As a result, this Annual Report on Form 10-K doesnot include an assessment of compliance with applicable servicing criteria ofthe trustee. One or more other servicers of the Airport Square Mortgage Loan,the 3 Columbus Circle Mortgage Loan, the 225 Bush Mortgage Loan and the 180Water Mortgage Loan have delivered one or more assessments of compliance withrespect to Item 1122(d)(2)(iii) of Regulation AB.

Citibank, N.A. acts as trustee ofthe Bushwick Avenue Portfolio Mortgage Loan.  Pursuant to the pooling andservicing agreement for the CF 2019-CF2 Transaction, the trustee is required toprovide an assessment of compliance with applicable servicing criteria solelywith respect to Item 1122(d)(2)(iii) of Regulation AB (regarding advances offunds or guarantees regarding collections, cash flows or distributions, and anyinterest or other fees charged for such advances, are made, reviewed andapproved as specified in the transaction agreements). However, during thereporting period, the trustee did not perform any servicing function withrespect to the servicing criteria specified in Item 1122(d)(2)(iii) ofRegulation AB.  The master servicer or the special servicer, to the extentrequired, performed the servicing function identified with respect to Item1122(d)(2)(iii) of Regulation AB, and each such party included Item 1122(d)(2)(iii)of Regulation AB in the assessment of compliance with applicable servicingcriteria and accountant’s attestation report for the subject transaction. As a result, this Annual Report on Form 10-K does not include an assessment ofcompliance with applicable servicing criteria of the trustee. One or more otherservicers of the Bushwick Avenue Portfolio Mortgage Loan have delivered one ormore assessments of compliance with respect to Item 1122(d)(2)(iii) ofRegulation AB.

Wilmington Trust, NationalAssociation acts as trustee of the Century Plaza Towers Mortgage Loan, theParklawn Building Mortgage Loan, the Wells Fargo Place Mortgage Loan and thePark Central Tower Mortgage Loan.  Pursuant to the trust and servicingagreement for the CPTS 2019-CPT Transaction, the pooling and servicingagreement for the MSC 2019-L3 Transaction and the pooling and servicingagreement for the CGCMT 2019-C7 Transaction, the trustee is required to providean assessment of compliance with applicable servicing criteria solely with respectto Item 1122(d)(2)(iii) of Regulation AB (regarding advances of funds orguarantees regarding collections, cash flows or distributions, and any interestor other fees charged for such advances, are made, reviewed and approved asspecified in the transaction agreements). However, during the reporting period,the trustee did not perform any servicing function with respect to theservicing criteria specified in Item 1122(d)(2)(iii) of Regulation AB. The master servicer or the special servicer, to the extent required, performedthe servicing function identified with respect to Item 1122(d)(2)(iii) ofRegulation AB, and each such party included Item 1122(d)(2)(iii) of RegulationAB in the assessment 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 Century Plaza Towers Mortgage Loan, the Parklawn Building Mortgage Loan,the Wells Fargo Place Mortgage Loan and the Park Central Tower Mortgage Loanhave 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 primary servicer of the Century Plaza Towers MortgageLoan, the Wells Fargo Place Mortgage Loan and the Park Central Tower MortgageLoan to remit tax payments received from the escrow accounts of borrowers tolocal taxing authorities, to report tax amounts due, to verify tax parcelinformation, and to verify non-escrow tax payments. These servicing functionsare included within the servicing criteria set forth in Items 1122(d)(4)(xi)and 1122(d)(4)(xii) of Regulation AB.  Therefore, under theprinciples-based definition of “servicer” set forth in Item 1101(j) ofRegulation AB that looks to the functions that an entity performs, this vendoris a “servicer” for the purposes of Item 1122 of Regulation AB.  *See*Compliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

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

Theassessments of compliance with applicable servicing criteria, accountants’attestation reports and servicer compliance statements of the certificateadministrator of the 3 Columbus Circle Mortgage Loan, the Century Plaza TowersMortgage Loan, the Wells Fargo Place Mortgage Loan, the 225 Bush Mortgage Loan,the 180 Water Mortgage Loan, the Bushwick Avenue Portfolio Mortgage Loan, thePark Central Tower Mortgage Loan and the Parklawn Building Mortgage Loan areomitted from this Annual Report on Form 10-K as the certificate administratorpursuant to the related pooling and servicing agreement or trust and servicingagreement does not perform any activities that address servicing criteria withrespect to the issuing entity and because they are each not a “servicer” thatmeets the criteria in Item 1108(a)(2)(i) through (iii) of Regulation AB.

With respect to the *pari passu*loan combinations that include the Century PlazaTowers Mortgage Loan and the 180 Water Mortgage Loan, the servicercompliance statement of CWCapital Asset Management LLC as special servicer ofthe Century Plaza Towers Mortgage Loan and the 180 Water Mortgage Loan, listedon the Exhibit Index is omitted from this Annual Report on Form 10-K as it isnot required by Item 1123 of Regulation AB to be included on this Annual Reporton Form 10-K because it is an unaffiliated party that is not a “servicer” thatmeets the criteria in Item 1108(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 DerivativesInstruments (Financial Information).**

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

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

The registrant knows of no material pending legal proceedinginvolving the trust or any party related to the trust, other than routine litigationincidental to the duties of those respective parties, and the following, withrespect to CWCapital Asset Management LLC, as special servicer, and Wells FargoBank, National Association, as trustee, 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 its propertyis 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 the properallocation of certain proceeds (“Disputed Proceeds”) received by CWCAMin connection with the sale of the Peter Cooper Village and Stuyvesant Townproperty in New York, New York securing loans held by those trusts.  CWCAMwas the special servicer of such property.  The petition requests theState Court to instruct the trustee, the trust beneficiaries, and any otherinterested parties as to the amount of the Disputed Proceeds, if any, that constitutepenalty interest and/or the amount of the Disputed Proceeds, if any, thatconstitute gain-on-sale proceeds, with respect to each trust.  On February24, 2016, CWCAM made a limited appearance with the State Court to file a motionto dismiss this proceeding based on lack of jurisdiction, mootness, standingand forum non conveniens.  On July 19, 2016, the State Court deniedCWCAM’s motion to dismiss.  On July 22, 2016, the action was removed tofederal court in Minnesota (“Federal Court”).  On October 21, 2016,the Federal Court held a hearing on the motion to transfer the action to theUnited States District Court for the Southern District of New York (“SDNYCourt”), a motion to remand to state court and a motion to hear CWCAM’srequest for reconsideration of the motion to dismiss.  On March 14, 2017,the Federal Court reserved the determination on the motion to hear CWCAM’srequest for reconsideration of the motion to dismiss, denied the motion toremand the matter to state court and granted the motion to transfer theproceeding to the SDNY Court.  Cross motions for judgment on the pleadingswere filed but the SDNY Court was unable to decide the case based on thepleadings and the SDNY Court ordered discovery.  All fact discovery wascompleted 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 abetting breachof fiduciary duty, conversion and unjust enrichment. On May 23, 2018, theOriginal 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 16counts and partially dismissing 2 additional counts.  Of the remainingcounts, 2 are asserted against CWCAM for aiding and abetting breach offiduciary duty and unjust enrichment.  On September 19, 2019, CWCapitalCobalt Vr Ltd. filed a notice of appeal relating to the August 20, 2019dismissal order and on September 26, 2019, filed an amended complaint againstCWCI and CWCAM attempting to address deficiencies relating to certain of theclaims dismissed by the August, 20, 2019 order.  CWCI and CWCAM filed itsMotion to Dismiss the amended complaint on October 28, 2019.  The courtheard argument on the Motion to Dismiss the amended complaint on January 22,2020 and on October 23, 2020, the court granted the motion dismissing the amendedclaims.  On November 30, 2020, CWCapital Cobalt Vr Ltd filed a notice ofappeal relating to the October 23, 2020 dismissal order.  On April 27,2021, the First Department affirmed the dismissal as to claims against CWCAMthat were part of the August 20, 2019 dismissal, but reversed the dismissal oftwo counts for breach of the Collateral Management Agreement againstCWCI.  CWCI has sought leave to file an appeal of the decision.  Bothrequests for leave were denied by the First Department.  The plaintiff hasalso sought leave to appeal the dismissal of the claims against CWCAM. CWCAM believes that it has performed its obligations under the related poolingand servicing agreements in good faith and the remaining allegations in the NewComplaint are without 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 BankCommercial Mortgage Trust 2007-C30 and COBALT CMBS Commercial Trust 2007-C2,U.S. Bank National Association as trustee under the pooling and servicingagreements for Wachovia Bank Commercial Mortgage Trust 2007-C31, ML-CFCCommercial Mortgage Trust 2007-5 and ML-CFC Commercial Mortgage Trust 2007-6(collectively, the “PSW Trusts”), PCV-M Holdings LLC and CWCapital AssetManagement LLC, individually and as special servicer for the PSW Trusts(collectively, the “Defendants”) seeking either (a) damages in an amount to bedetermined by the PSW Court but alleged by the plaintiffs to be approximately$500,000,000 – such amount being the amount PSW NYC LLC alleges would have beenrecovered on certain mezzanine loans (the “PCVST Mezzanine Loans”) related tothe Peter Cooper Village and Stuyvesant Town property (the “PCVST Property”) inNew York City which PSW NYC LLC sold to an entity related to the Defendantspursuant to a settlement agreement related to certain prior litigation (the“2010 Settlement Agreement”) or (b) the rescission of the 2010 SettlementAgreement which would result in, among other things, the rescission of the saleof the PCVST Mezzanine Loans and a claim for certain proceeds from the sale ofthe PCVST 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 apooling and 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 RAIT PreferredFunding has the right to terminate the special servicer, (c) monetary damagesfor the value of the bonds and fees paid to CWCAM as the special servicer ofthe Loan and (d) other things.  On May 17, 2016, CWCAM filed a motion todismiss the RAIT Complaint (“Motion to Dismiss”) stating that the RAITComplaint did not state a claim and the essential facts of the RAIT Complaintare negated by affidavits and evidentiary materials submitted with the RAITComplaint.  On June 14, 2016, RAIT Preferred Funding filed a Memorandum ofLaw in Opposition to the Motion to Dismiss (“Opposition”) stating thatthe claims in the RAIT Complaint were properly stated.  On June 30, 2016,CWCAM filed a reply in support of the Motion to Dismiss and in response to theOpposition, stating that each of CWCAM’s arguments is supported by the expresslanguage of the agreements between the parties, the documentary evidence andNew York case law.  On September 30, 2016, RAIT Preferred Funding andCWCAM entered into a confidential Settlement Agreement (the “2016 Settlement”),which provides for a stay of the RAIT Preferred Funding litigation (the “LitigationStay”) through August 25, 2017.  Pursuant to the terms of the 2016Settlement, upon satisfaction of a term of the 2016 Settlement by August 25,2017 (or such later date agreed to by the parties), the RAIT Preferred Fundinglitigation will be dismissed, with prejudice.  On May 19, 2017 theBorrower repaid the Loan in accordance with the terms of the notes andsatisfied the condition to dismissal with prejudice.  RAIT has refused todismiss the case and is claiming that the B Note should be paid in full. CWCAM believes that it has performed its obligations under the OperativeAgreements in good faith, and that the action should be dismissed withprejudice.  On August 29, 2017, the RAIT Court granted leave to RAITPreferred Funding to amend its complaint.  On September 20, 2017, RAITPreferred Funding filed an Amended Complaint (the “RAIT Amended Complaint”),which omits its original claims, adds Wells Fargo Bank as a defendant, andseeks (a) specific performance requiring repayment of the $18,500,000 principalamount of the B Note or, in the alternative, monetary damages, including the $18,500,000principal amount of the B Note, in an amount to be determined at trial, (b)monetary damages on any fees paid to CWCAM as special servicer or Wells FargoBank as master servicer in connection with the borrower’s repayment of theLoan, (c) a declaratory judgment that RAIT Preferred Funding is entitled torecover the full $18,500,000 principal amount of the B Note, (d) punitivedamages against CWCAM, and (e) other things.  On October 11, 2017, CWCAMfiled a motion to dismiss the RAIT Amended Complaint (“CWCAM Motion toDismiss Amended Complaint”) stating that the RAIT Amended Complaint did notstate a claim and the essential facts of the RAIT Amended Complaint are negatedby the Operative Agreements and other admissible evidentiary materials. On November 13, 2017, Wells Fargo Bank filed a motion to dismiss the RAITAmended Complaint (the “Wells Fargo Motion to Dismiss Amended Complaint”)and joined the CWCAM Motion to Dismiss Amended Complaint.  On January 29,2018, the court dismissed all claims but for breach of contract and discoveryhas commenced.  CWCAM filed a Motion for Summary Judgement on March 18,2019.   This matter was settled and the case dismissed 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 20, 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 ScheduleII to the Pooling and Servicing Agreement incorporated by reference as Exhibit4.1 to 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 3 Columbus Circle Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the Benchmark 2019-B10 Transaction, are attached hereto underItem 15 to this Annual Report on Form 10-K. Attached as Schedule II to thepooling and servicing agreement for the Benchmark 2019-B10 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 theBenchmark 2019-B10 Transaction responsible for each applicable servicingcriteria 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 Bushwick Avenue PortfolioMortgage Loan, which is being serviced and administered pursuant to the poolingand servicing agreement for the CF 2019-CF2 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Schedule II tothe pooling and servicing agreement for the CF 2019-CF2 Transactionincorporated by reference as Exhibit 4.3 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theCF 2019-CF2 Transaction responsible for each applicable servicing criteria setforth 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 Century Plaza Towers MortgageLoan, which is being serviced and administered pursuant to the trust andservicing agreement for the CPTS 2019-CPT Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Schedule I to thetrust and servicing agreement for the CPTS 2019-CPT Transaction incorporated byreference as Exhibit 4.4 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the CPTS2019-CPT Transaction responsible for each applicable servicing criteria setforth 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 Wells Fargo Place 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 4.5 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 225 Bush Mortgage Loan, which isbeing serviced and administered pursuant to the pooling and servicing agreementfor the Benchmark 2019-B14 Transaction, are attached hereto under Item 15 tothis Annual Report on Form 10-K. Attached as Exhibit AA to the pooling andservicing agreement for the Benchmark 2019-B14 Transaction incorporated byreference as Exhibit 4.6 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for theBenchmark 2019-B14 Transaction responsible for each applicable servicingcriteria 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 180 Water Mortgage Loan, which isbeing serviced and administered pursuant to the pooling and servicing agreementfor the COMM 2019-GC44 Transaction, are attached hereto under Item 15 to thisAnnual Report on Form 10-K. Attached as Schedule II to the pooling andservicing agreement for the COMM 2019-GC44 Transaction incorporated byreference as Exhibit 4.7 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the COMM2019-GC44 Transaction responsible for each applicable servicing criteria setforth 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 Central Tower Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the CGCMT 2019-C7 Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit O to the pooling andservicing agreement for the CGCMT 2019-C7 Transaction incorporated by referenceas Exhibit 4.8 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the CGCMT 2019-C7Transaction responsible for each applicable servicing criteria set forth inItem 1122(d).

**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 ofthis Annual Report on Form 10-K:

(1) Not applicable

(2) Not applicable

(3) See below

 

4.1          Poolingand Servicing Agreement, dated as of December 1, 2019, by and among CCRECommercial Mortgage Securities, L.P., as Depositor, Midland Loan Services, aDivision of PNC Bank, National Association, as Master Servicer, Midland LoanServices, a Division of PNC Bank, National Association, as Special Servicer,Wells Fargo Bank, National Association, as Trustee, Wells Fargo Bank, NationalAssociation, as Certificate Administrator, Paying Agent and Custodian, ParkBridge Lender Services LLC, as Operating Advisor and Park Bridge LenderServices LLC, as Asset Representations Reviewer (filed as Exhibit 4.1 to theregistrant’s Current Report on Form 8-K filed on December 20, 2019 underCommission File No. 333-228697-03 and incorporated by reference herein).

4.2          Poolingand Servicing Agreement, dated as of April 1, 2019, by and among DeutscheMortgage & Asset Receiving Corporation, as Depositor, KeyBank NationalAssociation, as Master Servicer, LNR Partners, LLC, as Special Servicer, WellsFargo Bank, National Association, as Trustee, Wells Fargo Bank, NationalAssociation, as Certificate Administrator, Paying Agent and Custodian, andPentalpha Surveillance LLC, as Operating Advisor and Asset RepresentationsReviewer (filed as Exhibit 4.2 to the registrant’s Current Report on Form 8-Kfiled on December 20, 2019 under Commission File No. 333-228697-03 andincorporated by reference herein).

4.3          Poolingand Servicing Agreement, dated as of October 1, 2019, by and among CCRECommercial Mortgage Securities, L.P., as Depositor, KeyBank NationalAssociation, as Master Servicer, LNR Partners, LLC and KeyBank NationalAssociation, each as a Special Servicer, Citibank, N.A., as Trustee, Citibank,N.A., Certificate Administrator, Paying Agent and Custodian, Park Bridge LenderServices LLC, as Operating Advisor, and Park Bridge Lender Services LLC, asAsset Representations Reviewer (filed as Exhibit 4.4 to the registrant’sCurrent Report on Form 8-K filed on December 20, 2019 under Commission File No.333-228697-03 and incorporated by reference herein).

4.4          Trustand Servicing Agreement, dated as of November 9, 2019, by and among DeutscheMortgage & Asset Receiving Corporation, as Depositor, Wells Fargo Bank,National Association, as Master Servicer, CWCapital Asset Management LLC, asSpecial Servicer, Wilmington Trust, National Association, as Trustee, WellsFargo Bank, National Association, as Certificate Administrator, Paying Agentand Custodian (filed as Exhibit 4.7 to the registrant’s Current Report on Form8-K filed on December 20, 2019 under Commission File No. 333-228697-03 andincorporated by reference herein).

4.5          Poolingand Servicing Agreement, dated as of November 1, 2019, between Morgan StanleyCapital I Inc., as Depositor, Wells Fargo Bank, National Association, as MasterServicer, LNR Partners, LLC, as General Special Servicer, Situs Holdings, LLC,as ILPT Industrial Portfolio Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator, Wilmington Trust, NationalAssociation, as Trustee, and Park Bridge Lender Services LLC, as OperatingAdvisor and Asset Representations Reviewer (filed as Exhibit 4.1 to theregistrant’s Current Report on Form 8-K/A filed on January 6, 2020 underCommission File No. 333-228697-03 and incorporated by reference herein).

4.6          Poolingand Servicing Agreement, dated as of November 1, 2019, by and among J.P. MorganChase Commercial Mortgage Securities Corp., as Depositor, Midland LoanServices, a Division of PNC Bank, National Association, as Master Servicer,Midland Loan Services, a Division of PNC Bank, National Association, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administrator,Wells Fargo Bank, National Association, as Trustee, and Pentalpha SurveillanceLLC, as Operating Advisor and as Asset Representations Reviewer (filed asExhibit 4.3 to the registrant’s Current Report on Form 8-K filed on December20, 2019 under Commission File No. 333-228697-03 and incorporated by referenceherein).

4.7          Poolingand Servicing Agreement, dated as of December 1, 2019, by and among DeutscheMortgage & Asset Receiving Corporation, as Depositor, Midland LoanServices, a Division of PNC Bank, National Association, as Master Servicer,Rialto Capital Advisors, LLC, as Special Servicer, Wells Fargo Bank, NationalAssociation, as Trustee, Wells Fargo Bank, National Association, as CertificateAdministrator, Paying Agent and Custodian, and Park Bridge Lender Services LLC,as Operating Advisor and Asset Representations Reviewer (filed as Exhibit 4.6to the registrant’s Current Report on Form 8-K filed on December 20, 2019 underCommission File No. 333-228697-03 and incorporated by reference herein).

4.8          Poolingand Servicing Agreement, dated as of December 1, 2019, by and 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 Asset RepresentationsReviewer, Citibank, N.A., as Certificate Administrator and Custodian, andWilmington Trust, National Association, as Trustee (filed as Exhibit 4.5 to theregistrant’s Current Report on Form 8-K filed on December 20, 2019 underCommission File No. 333-228697-03 and incorporated by reference herein).

4.9          PrimaryServicing Agreement, dated as of December 1, 2019, by and between Midland LoanServices, a Division of PNC Bank, National Association, as Master Servicer, andKeyBank National Association, as Primary Servicer (filed as Exhibit 99.4 to theregistrant’s Current Report on Form 8-K filed on December 20, 2019 underCommission File No. 333-228697-03 and incorporated by reference herein).

4.10         PrimaryServicing Agreement, dated as of November 1, 2019, by and between Wells FargoBank, National Association, as Master Servicer, and KeyBank NationalAssociation, as Primary Servicer (filed as Exhibit 99.5 to the registrant’sCurrent Report on Form 8-K filed on December 20, 2019 under Commission File No.333-228697-03 and incorporated by reference herein).

4.11         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 4.9 to the registrant’sCurrent Report on Form 8-K filed on December 20, 2019 under Commission File No.333-228697-03 and incorporated by reference herein).

4.12         Co-LenderAgreement, dated as of October 21, 2019, by and between Deutsche Bank AG, NewYork Branch, as Initial Note A Holder, Wells Fargo Bank, National Association,as Initial Note A Holder, Morgan Stanley Bank, National Association, as InitialNote A Holder, Deutsche Bank AG, New York Branch, as Initial Note B-1 Holder,Morgan Stanley Bank, National Association, as Initial Note B-2 Holder, andWells Fargo Bank, National Association, as Initial Note B-3 Holder (filed asExhibit 4.10 to the registrant’s Current Report on Form 8-K filed on December20, 2019 under Commission File No. 333-228697-03 and incorporated by referenceherein).

4.13         Co-LenderAgreement, dated as of November 19, 2019, by and between Starwood MortgageCapital LLC, as Initial Note A-1 Holder, and Starwood Mortgage Capital LLC, asInitial Note A-2 Holder (filed as Exhibit 4.11 to the registrant’s CurrentReport on Form 8-K filed on December 20, 2019 under Commission File No.333-228697-03 and incorporated by reference herein).

4.14         Co-LenderAgreement, dated as of October 25, 2019, by and among Starwood Mortgage CapitalLLC, as Initial Note A-1 Holder, Starwood Mortgage Capital LLC, as Initial NoteA-2 Holder, Starwood Mortgage Capital LLC, as Initial Note A-3 Holder, StarwoodMortgage Capital LLC, as Initial Note A-4 Holder, Starwood Mortgage CapitalLLC, as Initial Note A-5 Holder, Starwood Mortgage Capital LLC, as Initial NoteA-6 Holder, and Starwood Mortgage Capital LLC, as Initial Note A-7 Holder(filed as Exhibit 4.12 to the registrant’s Current Report on Form 8-K filed onDecember 20, 2019 under Commission File No. 333-228697-03 and incorporated byreference herein).

4.15         AgreementBetween Noteholders, dated as of November 18, 2019, by and between DBRInvestments Co. Limited, as Initial Note A-1 Holder, DBR Investments Co.Limited, as Initial Note A-2 Holder, UBS AG, by and through its branch officeat 1285 Avenue of the Americas, New York, New York, as Initial Note A-3 Holder,UBS AG, by and through its branch office at 1285 Avenue of the Americas, NewYork, New York, as Initial Note A-4 Holder, DBR Investments Co. Limited, asInitial Note A-5 Holder, DBR Investments Co. Limited, as Initial Note A-6 Holder,and DBR Investments Co. Limited, as Initial Note B Holder (filed as Exhibit4.13 to the registrant’s Current Report on Form 8-K filed on December 20, 2019under Commission File No. 333-228697-03 and incorporated by reference herein).

4.16         AgreementBetween Noteholders, dated as of November 21, 2019, by and between DBRInvestments Co. Limited, as Initial Note A-1 Holder, DBR Investments Co.Limited, as Initial Note A-2 Holder, DBR Investments Co. Limited, as InitialNote A-3 Holder, DBR Investments Co. Limited, as Initial Note A-4 Holder, DBRInvestments Co. Limited, as Initial Note A-5 Holder, and DBR Investments Co.Limited, as Initial Note B Holder (filed as Exhibit 4.14 to the registrant’sCurrent Report on Form 8-K filed on December 20, 2019 under Commission File No.333-228697-03 and incorporated by reference herein).

4.17         AgreementBetween Noteholders, dated as of March 13, 2019, by and between JPMorgan ChaseBank, National Association, as Initial Note A-1-1 Holder, Initial Note A-1-2Holder, Initial Note A-1-3 Holder, Initial Note A-1-4 Holder, Initial NoteA-1-5 Holder, Initial Note A-1-6 Holder, Initial Note A-1-7 Holder and InitialNote A-1-8 Holder, Deutsche Bank AG, acting through its New York Branch, asNote A-2-1 Holder, Note A-2-2 Holder, Note A-2-3 Holder, Note A-2-4 Holder andNote A-2-5 Holder, JPMorgan Chase Bank, National Association, as Initial NoteB-1 Holder, and Deutsche Bank AG, acting through its New York Branch, as NoteB-2 Holder (filed as Exhibit 4.15 to the registrant’s Current Report on Form 8-Kfiled on December 20, 2019 under Commission File No. 333-228697-03 andincorporated by reference herein).

4.18         Co-LenderAgreement, dated as of November 7, 2019, by and between Starwood MortgageCapital LLC, as Initial Note A-1 Holder, and Starwood Mortgage Capital LLC, asInitial Note A-2 Holder (filed as Exhibit 4.16 to the registrant’s CurrentReport on Form 8-K filed on December 20, 2019 under Commission File No.333-228697-03 and incorporated by reference herein).

4.19         AgreementBetween Noteholders, dated as of December 20, 2019, by and between CantorCommercial Real Estate Lending, L.P., as Initial Note A-1 Holder, and CantorCommercial Real Estate Lending, L.P., as Initial Note A-2 Holder (filed asExhibit 4.17 to the registrant’s Current Report on Form 8-K filed on December20, 2019 under Commission File No. 333-228697-03 and incorporated by referenceherein).

4.20         Co-LenderAgreement, dated as of August 9, 2019, by and among Starwood Mortgage CapitalLLC, as Initial Note A-1 Holder, Starwood Mortgage Capital LLC, as Initial NoteA-2 Holder, Starwood Mortgage Capital LLC, as Initial Note A-3 Holder, StarwoodMortgage Capital LLC, as Initial Note A-4 Holder, and Starwood Mortgage CapitalLLC, as Initial Note A-5 Holder (filed as Exhibit 4.18 to the registrant’sCurrent Report on Form 8-K filed on December 20, 2019 under Commission File No.333-228697-03 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        Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer

33.2        Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer (see Exhibit 33.1)

33.3        Wells Fargo Bank, National Association, as Trusteeand Certificate Administrator

33.4        Wells Fargo Bank, National Association, asCustodian

33.5        Park Bridge Lender Services LLC, as OperatingAdvisor

33.6        KeyBank National Association, as Primary Servicer

33.7        Computershare Trust Company, National Association,as Servicing Function Participant for the Trustee and Certificate Administratoron and after November 1, 2021

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

33.9        Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Airport Square Mortgage Loan(see Exhibit 33.1)

33.10      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Airport Square Mortgage Loan(see Exhibit 33.1)

33.11      Wells Fargo Bank, National Association, as Trustee of the Airport SquareMortgage Loan (Omitted. See Explanatory Notes.)

33.12      Wells Fargo Bank, National Association, asCustodian of the Airport Square Mortgage Loan (see Exhibit 33.4)

33.13      Park Bridge Lender Services LLC, as OperatingAdvisor of the Airport Square Mortgage Loan (see Exhibit 33.5)          

33.14      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

33.15      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 3 Columbus Circle MortgageLoan (see Exhibit 33.1)

33.16      LNR Partners, LLC, as Special Servicer of the 3Columbus Circle Mortgage Loan

33.17      Wells Fargo Bank, National Association, as Trustee of the 3 Columbus CircleMortgage Loan (Omitted. See Explanatory Notes.)

33.18      Wells Fargo Bank, National Association, asCustodian of the 3 Columbus Circle Mortgage Loan (see Exhibit 33.4)

33.19      Pentalpha Surveillance LLC, as Operating Advisorof the 3 Columbus Circle Mortgage Loan          

33.20      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

33.21      KeyBank National Association, as Primary Servicerof the Bushwick Avenue Portfolio Mortgage Loan (see Exhibit 33.6)

33.22      LNR Partners, LLC, as Special Servicer of theBushwick Avenue Portfolio Mortgage Loan (see Exhibit 33.16)

33.23      Citibank, N.A., as Trustee and Custodian of theBushwick Avenue Portfolio Mortgage Loan

33.24      Park Bridge Lender Services LLC, as OperatingAdvisor of the Bushwick Avenue Portfolio Mortgage Loan (see Exhibit 33.5)

33.25      U.S. Bank National Association, as ServicingFunction Participant of the Bushwick Avenue Portfolio Mortgage Loan

33.26      Wells Fargo Bank, National Association, as PrimaryServicer of the Century Plaza Towers Mortgage Loan

33.27      CWCapital Asset Management LLC, as SpecialServicer of the Century Plaza Towers Mortgage Loan

33.28      Wilmington Trust, National Association, as Trustee of the Century Plaza TowersMortgage Loan (Omitted. See Explanatory Notes.)

33.29      Wells Fargo Bank, National Association, asCustodian of the Century Plaza Towers Mortgage Loan (see Exhibit 33.4)

33.30      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Century Plaza Towers Mortgage Loan

33.31      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

33.32      KeyBank National Association, as Primary Servicerof the Parklawn Building Mortgage Loan (see Exhibit 33.6)

33.33      LNR Partners, LLC, as Special Servicer of theParklawn Building Mortgage Loan (see Exhibit 33.16)

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

33.35      Wells Fargo Bank, National Association, asCustodian of the Parklawn Building Mortgage Loan (see Exhibit 33.4)

33.36      Park Bridge Lender Services LLC, as OperatingAdvisor of the Parklawn Building Mortgage Loan (see Exhibit 33.5)

33.37      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

33.38      Wells Fargo Bank, National Association, as PrimaryServicer of the Wells Fargo Place Mortgage Loan (see Exhibit 33.26)

33.39      LNR Partners, LLC, as Special Servicer of theWells Fargo Place Mortgage Loan (see Exhibit 33.16)

33.40      Wilmington Trust, National Association, as Trustee of the Wells Fargo PlaceMortgage Loan (Omitted. See Explanatory Notes.)

33.41      Wells Fargo Bank, National Association, asCustodian of the Wells Fargo Place Mortgage Loan (see Exhibit 33.4)

33.42      Park Bridge Lender Services LLC, as OperatingAdvisor of the Wells Fargo Place Mortgage Loan (see Exhibit 33.5)

33.43      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Wells Fargo Place Mortgage Loan (see Exhibit 33.30)

33.44      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

33.45      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 225 Bush Mortgage Loan (seeExhibit 33.1)

33.46      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the 225 Bush Mortgage Loan (seeExhibit 33.1)

33.47      Wells Fargo Bank, National Association, as Trustee of the 225 Bush MortgageLoan (Omitted. See Explanatory Notes.)

33.48      Wells Fargo Bank, National Association, asCustodian of the 225 Bush Mortgage Loan (see Exhibit 33.4)

33.49      Pentalpha Surveillance LLC, as Operating Advisorof the 225 Bush Mortgage Loan (see Exhibit 33.19)          

33.50      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

33.51      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 180 Water Mortgage Loan (seeExhibit 33.1)

33.52      CWCapital Asset Management LLC, as Special Servicerof the 180 Water Mortgage Loan (see Exhibit 33.27)

33.53      Wells Fargo Bank, National Association, as Trustee of the 180 Water MortgageLoan (Omitted. See Explanatory Notes.)

33.54      Wells Fargo Bank, National Association, asCustodian of the 180 Water Mortgage Loan (see Exhibit 33.4)

33.55      Park Bridge Lender Services LLC, as OperatingAdvisor of the 180 Water Mortgage Loan (see Exhibit 33.5)  

33.56      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.8)

33.57      Wells Fargo Bank, National Association, as PrimaryServicer of the Park Central Tower Mortgage Loan (see Exhibit 33.26)

33.58      LNR Partners, LLC, as Special Servicer of the ParkCentral Tower Mortgage Loan (see Exhibit 33.16)

33.59      Wilmington Trust, National Association, as Trustee of the Park Central TowerMortgage Loan (Omitted. See Explanatory Notes.)

33.60      Citibank, N.A., as Custodian of the Park CentralTower Mortgage Loan (see Exhibit 33.23)

33.61      Pentalpha Surveillance LLC, as Operating Advisorof the Park Central Tower Mortgage Loan (see Exhibit 33.19)

33.62      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Park Central Tower Mortgage Loan (see Exhibit 33.30)

33.63      U.S. Bank National Association, as ServicingFunction Participant of the Park Central Tower Mortgage Loan (see Exhibit33.25)

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

34.1        Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer

34.2        Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer (see Exhibit 34.1)

34.3        Wells Fargo Bank, National Association, as Trusteeand Certificate Administrator

34.4        Wells Fargo Bank, National Association, asCustodian

34.5        Park Bridge Lender Services LLC, as OperatingAdvisor

34.6        KeyBank National Association, as Primary Servicer

34.7        Computershare Trust Company, National Association,as Servicing Function Participant for the Trustee and Certificate Administratoron and after November 1, 2021   

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

34.9        Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Airport Square Mortgage Loan(see Exhibit 34.1)

34.10      Midland Loan Services, a Division of PNC Bank, NationalAssociation, as Special Servicer of the Airport Square Mortgage Loan (seeExhibit 34.1)

34.11      Wells Fargo Bank, National Association, as Trustee of the Airport SquareMortgage Loan (Omitted. See Explanatory Notes.)

34.12      Wells Fargo Bank, National Association, asCustodian of the Airport Square Mortgage Loan (see Exhibit 34.4)

34.13      Park Bridge Lender Services LLC, as OperatingAdvisor of the Airport Square Mortgage Loan (see Exhibit 34.5)          

34.14      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

34.15      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 3 Columbus Circle MortgageLoan (see Exhibit 34.1)

34.16      LNR Partners, LLC, as Special Servicer of the 3Columbus Circle Mortgage Loan

34.17      Wells Fargo Bank, National Association, as Trustee of the 3 Columbus CircleMortgage Loan (Omitted. See Explanatory Notes.)

34.18      Wells Fargo Bank, National Association, asCustodian of the 3 Columbus Circle Mortgage Loan (see Exhibit 34.4)

34.19      Pentalpha Surveillance LLC, as Operating Advisorof the 3 Columbus Circle Mortgage Loan          

34.20      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

34.21      KeyBank National Association, as Primary Servicerof the Bushwick Avenue Portfolio Mortgage Loan (see Exhibit 34.6)

34.22      LNR Partners, LLC, as Special Servicer of theBushwick Avenue Portfolio Mortgage Loan (see Exhibit 34.16)

34.23      Citibank, N.A., as Trustee and Custodian of theBushwick Avenue Portfolio Mortgage Loan

34.24      Park Bridge Lender Services LLC, as OperatingAdvisor of the Bushwick Avenue Portfolio Mortgage Loan (see Exhibit 34.5)

34.25      U.S. Bank National Association, as ServicingFunction Participant of the Bushwick Avenue Portfolio Mortgage Loan

34.26      Wells Fargo Bank, National Association, as PrimaryServicer of the Century Plaza Towers Mortgage Loan

34.27      CWCapital Asset Management LLC, as SpecialServicer of the Century Plaza Towers Mortgage Loan

34.28      Wilmington Trust, National Association, as Trustee of the Century Plaza TowersMortgage Loan (Omitted. See Explanatory Notes.)

34.29      Wells Fargo Bank, National Association, asCustodian of the Century Plaza Towers Mortgage Loan (see Exhibit 34.4)

34.30      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Century Plaza Towers Mortgage Loan

34.31      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

34.32      KeyBank National Association, as Primary Servicerof the Parklawn Building Mortgage Loan (see Exhibit 34.6)

34.33      LNR Partners, LLC, as Special Servicer of theParklawn Building Mortgage Loan (see Exhibit 34.16)

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

34.35      Wells Fargo Bank, National Association, asCustodian of the Parklawn Building Mortgage Loan (see Exhibit 34.4)

34.36      Park Bridge Lender Services LLC, as OperatingAdvisor of the Parklawn Building Mortgage Loan (see Exhibit 34.5)

34.37      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

34.38      Wells Fargo Bank, National Association, as PrimaryServicer of the Wells Fargo Place Mortgage Loan (see Exhibit 34.26)

34.39      LNR Partners, LLC, as Special Servicer of theWells Fargo Place Mortgage Loan (see Exhibit 34.16)

34.40      Wilmington Trust, National Association, as Trustee of the Wells Fargo PlaceMortgage Loan (Omitted. See Explanatory Notes.)

34.41      Wells Fargo Bank, National Association, asCustodian of the Wells Fargo Place Mortgage Loan (see Exhibit 34.4)

34.42      Park Bridge Lender Services LLC, as OperatingAdvisor of the Wells Fargo Place Mortgage Loan (see Exhibit 34.5)

34.43      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Wells Fargo Place Mortgage Loan (see Exhibit 34.30)

34.44      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

34.45      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 225 Bush Mortgage Loan (seeExhibit 34.1)

34.46      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the 225 Bush Mortgage Loan (see Exhibit34.1)

34.47      Wells Fargo Bank, National Association, as Trustee of the 225 Bush MortgageLoan (Omitted. See Explanatory Notes.)

34.48      Wells Fargo Bank, National Association, asCustodian of the 225 Bush Mortgage Loan (see Exhibit 34.4)

34.49      Pentalpha Surveillance LLC, as Operating Advisorof the 225 Bush Mortgage Loan (see Exhibit 34.19)          

34.50      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.8)

34.51      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 180 Water Mortgage Loan (seeExhibit 34.1)

34.52      CWCapital Asset Management LLC, as SpecialServicer of the 180 Water Mortgage Loan (see Exhibit 34.27)

34.53      Wells Fargo Bank, National Association, as Trustee of the 180 Water MortgageLoan (Omitted. See Explanatory Notes.)

34.54      Wells Fargo Bank, National Association, asCustodian of the 180 Water Mortgage Loan (see Exhibit 34.4)

34.55      Park Bridge Lender Services LLC, as OperatingAdvisor of the 180 Water Mortgage Loan (see Exhibit 34.5)  

34.56      Computershare Trust Company, National Association, asServicing Function Participant for the Custodian on and after November 1, 2021(see Exhibit 34.8)

34.57      Wells Fargo Bank, National Association, as PrimaryServicer of the Park Central Tower Mortgage Loan (see Exhibit 34.26)

34.58      LNR Partners, LLC, as Special Servicer of the ParkCentral Tower Mortgage Loan (see Exhibit 34.16)

34.59      Wilmington Trust, National Association, as Trustee of the Park Central TowerMortgage Loan (Omitted. See Explanatory Notes.)

34.60      Citibank, N.A., as Custodian of the Park CentralTower Mortgage Loan (see Exhibit 34.23)

34.61      Pentalpha Surveillance LLC, as Operating Advisorof the Park Central Tower Mortgage Loan (see Exhibit 34.19)

34.62      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Park Central Tower Mortgage Loan (see Exhibit 34.30)

34.63      U.S. Bank National Association, as ServicingFunction Participant of the Park Central Tower Mortgage Loan (see Exhibit34.25)

35           Servicer compliance statements.

35.1        Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer

35.2        Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer (see Exhibit 35.1)

35.3        Wells Fargo Bank, National Association, asCertificate Administrator

35.4        KeyBank National Association, as Primary Servicer

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

35.6        Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Airport Square Mortgage Loan(see Exhibit 35.1)

35.7        Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Airport Square Mortgage Loan(see Exhibit 35.1)

35.8        Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 3 Columbus Circle MortgageLoan (see Exhibit 35.1)

35.9        LNR Partners, LLC, as Special Servicer of the 3Columbus Circle Mortgage Loan

35.10      KeyBank National Association, as Primary Servicerof the Bushwick Avenue Portfolio Mortgage Loan (see Exhibit 35.4)

35.11      LNR Partners, LLC, as Special Servicer of theBushwick Avenue Portfolio Mortgage Loan (see Exhibit 35.9)

35.12      Wells Fargo Bank, National Association, as PrimaryServicer of the Century Plaza Towers Mortgage Loan

35.13      CWCapital Asset Management LLC, as Special Servicer of the Century Plaza TowersMortgage Loan (Omitted. See Explanatory Notes.)

35.14      KeyBank National Association, as Primary Servicerof the Parklawn Building Mortgage Loan (see Exhibit 35.4)

35.15      LNR Partners, LLC, as Special Servicer of theParklawn Building Mortgage Loan (see Exhibit 35.9)

35.16      Wells Fargo Bank, National Association, as PrimaryServicer of the Wells Fargo Place Mortgage Loan (see Exhibit 35.12)

35.17      LNR Partners, LLC, as Special Servicer of the WellsFargo Place Mortgage Loan (see Exhibit 35.9)

35.18      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 225 Bush Mortgage Loan (seeExhibit 35.1)

35.19      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the 225 Bush Mortgage Loan (seeExhibit 35.1)

35.20      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 180 Water Mortgage Loan (seeExhibit 35.1)

35.21      CWCapital Asset Management LLC, as Special Servicer of the 180 Water MortgageLoan (Omitted. See Explanatory Notes.)

35.22      Wells Fargo Bank, National Association, as PrimaryServicer of the Park Central Tower Mortgage Loan (see Exhibit 35.12)

35.23      LNR Partners, LLC, as Special Servicer of the ParkCentral Tower Mortgage Loan (see Exhibit 35.9)

99.1         MortgageLoan Purchase Agreement, dated as of December 1, 2019, between CCRE CommercialMortgage Securities, L.P. and Cantor Commercial Real Estate Lending, L.P. (filedas Exhibit 99.1 to the registrant’s Current Report on Form 8-K filed onDecember 20, 2019 under Commission File No. 333-228697-03 and incorporated byreference herein).

99.2         MortgageLoan Purchase Agreement, dated as of December 1, 2019, between CCRE CommercialMortgage Securities, L.P. and KeyBank National Association (filed as Exhibit99.3 to the registrant’s Current Report on Form 8-K filed on December 20, 2019under Commission File No. 333-228697-03 and incorporated by reference herein).

99.3         MortgageLoan Purchase Agreement, dated as of December 1, 2019, between CCRE CommercialMortgage Securities, L.P. and Starwood Mortgage Capital LLC (filed as Exhibit99.2 to the registrant’s Current Report on Form 8-K filed on December 20, 2019under Commission File No. 333-228697-03 and incorporated 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 the SecuritiesExchange Act of 1934, the registrant has duly caused this report to be signedon its behalf by the undersigned, thereunto duly authorized.

CCRE Commercial Mortgage Securities,L.P.(Depositor)

/s/ JimBuccola

JimBuccola, Executive Managing Director

(senior officer in charge ofsecuritization of the depositor)

Date: March 15, 2022