i
 PENTALPHA SURVEILLANCE
 March
4, 2014
 Management’s Report on
Assessment of 2013 Compliance by Pentalpha
   Surveillance, LLC With Regulation AB Servicing
Criteria
 
 
 
 Pentalpha
Surveillance, LLC (the Asserting Party) is responsible for assessing
its compliance, as of and for the year ended December 31, 2013, with
the servicing criteria set forth in Title 17, Section 229.1122(d) of
the Code of Federal Regulations.
The assessment concerns the
Asserting Party’s servicing efforts for its servicing “Platform,” which
consists of its servicing activities encompassed by contractual
obligations to perform Regulation AB reporting (see the Exhibit for a
list of the Asserting Party’s Platform of required reporting by the
servicing agreements).
The Asserting Party has assessed its
compliance with the applicable servicing criteria as of and for the
year ended December 31, 2013. The Asserting Party used the criteria in
Paragraph (d) of Section 1122 of Regulation AB (17 C.F.R. 229.1122) to
assess its compliance.
Based on such assessment, the Asserting
Party believes that as of and for the year ended December 31, 2013, the
Asserting Party has complied in all material respects with the
servicing criteria set forth in Item 1122(d) of Regulation AB relating
to its operational advisor role in the servicing of the Platform,
except for servicing criteria 1122(d)(1)(i-iv), 1122(d)(2)(i-vii),
1122(d)(3)(ii-iv), 1122(d)(4)(i-vi) and 1122(d)(4)(viii-xv), which the
Asserting Party has determined as being inapplicable to the activities
it performs with respect to the Platform being serviced (the
“applicable servicing criteria”).
McGladrey LLP, an independent
registered public accounting firm, has issued an attestation report on
the assessment of compliance with the applicable servicing criteria for
the reporting period as set forth in this assertion.


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ii
 PENTALPHA SURVEILLANCERegulation
AB Section 229.1122(d) Servicing Criteria
 
 Regulation
AB Reference
 
 Servicing
Criterion
 
 
 
 1122(d)(1)(i)
 
 Policies
and procedures are instituted to monitor any performance 
or other triggers and events of default in accordance with the 
transaction agreements.
 
 
 
 Applicability/Compliance:
 
 Not
applicable.
 
 
 
 
 
 
 1122(d)(1)(ii)
 
 If any
material servicing activities are outsourced to third parties, 
policies and procedures are instituted to monitor the third party’s 
performance and compliance with such servicing activities.
 
 
 
 
 
 
 Applicability/Compliance:
 
 Not
applicable.
 
 
 
 
 
 
 1122(d)(1)(iii)
 
 Any
requirements in the transaction agreements to maintain a 
backup servicer for the pool assets are maintained.
 
 
 
 Applicability/Compliance:
 
 Not
applicable.
 
 
 
 
 
 
 1122(d)(1)(iv)
 
 A
fidelity bond and errors and omissions policy is in effect on the 
party participating in the servicing function throughout the reporting 
period in the amount of coverage required by and otherwise in 
accordance with the terms of the transaction agreements.
 
 
 
 Applicability/Compliance:
 
 Not
applicable.
 
 
 
 
 
 
 1122(d)(2)(i)
 
 Payments
on pool assets are deposited into the appropriate 
custodial bank accounts and related bank clearing accounts no 
more than two business days of receipt, or such other number of 
days specified in the transaction agreements.
 
 
 
 Applicability/Compliance:
 
 Not
applicable.
 
 
 
 
 
 
 1122(d)(2)(ii)
 
 Disbursements
made via wire transfer on behalf of an obligor or to 
an investor are made only by authorized personnel.
 
 
 
 Applicability/Compliance:
 
 Not
applicable.
 
 
 
 
 
 
 1122(d)(2)(iii)
 
 Advances
of funds or guarantees regarding collections, cash flows 
or distributions, and any interest or other fees charged for such 
advances are made, reviewed and approved as specified in the 
transaction agreements.
 
 
 
 Applicability/Compliance:
 
 Not
applicable.


---

iii
 PENTALPHA SURVEILLANCERegulation
AB Reference
 
 Servicing
Criterion
 
 
 
 1122(d)(2)(iv)
 
 The
related accounts for the transaction, such as cash reserve 
accounts or accounts established as a form of overcollateralization, 
are separately maintained (e.g., with respect to commingling of 
cash) as set forth in the transaction agreements.
 
 
 
 Applicability/Compliance:
 
 Not
applicable.
 
 
 
 
 
 
 1122(d)(2)(v)
 
 Each
custodial account is maintained at a federally insured 
depository institution as set forth in the transaction agreements.
For purposes of this criterion, “federally insured depository 
institution” with respect to a foreign financial institution means a 
foreign financial institution that meets the requirements of 
§ 240.13k-1(b)(1) of this chapter.
 
 
 
 
 
 Applicability/Compliance:
 
 Not
applicable.
 
 
 
 
 
 
 1122(d)(2)(vi)
 
 Unissued
checks are safeguarded so as to prevent unauthorized 
access.
 
 
 
 Applicability/Compliance:
 
 Not
applicable.
 
 
 
 
 
 
 1122(d)(2)(vii)
 
 Reconciliations
are prepared on a monthly basis for all asset-
backed securities-related bank accounts, including custodial 
accounts and related bank clearing accounts. These 
reconciliations: (A) are mathematically accurate; (B) are prepared 
within 30 calendar days after the bank statement cutoff date, or 
such other number of days specified in the transaction agreements; 
(C) are reviewed and approved by someone other than the person 
who prepared the reconciliation; and (D) contain explanations for 
reconciling items. These reconciling items are resolved within 
90 calendar days of their original identification, or such other 
number of days specified in the transaction agreements.
 
 
 
 Applicability/Compliance:
 
 Not
applicable.
 
 
 
 
 
 
 1122(d)(3)(i)(A)
 
 Reports
to investors, including those to be filed with the 
Commission, are maintained in accordance with the transaction 
agreements and applicable Commission requirements. Specifically, 
such reports are prepared in accordance with time frames and 
other terms set forth in the transaction agreements.
 
 
 
 Applicability/Compliance:
 
 Applicable.


---

iv
 PENTALPHA SURVEILLANCERegulation
AB Reference
 
 Servicing
Criterion
 
 
 
 1122(d)(3)(i)(B)
 Reports
to investors, including those to be filed with the 
Commission, are maintained in accordance with the transaction 
agreements and applicable Commission requirements. Specifically, 
such reports provide information calculated in accordance with the 
terms specified in the transaction agreements.
 
 
 
 Applicability/Compliance:
 
 Applicable.
 
 
 
 
 
 
 1122(d)(3)(i)(C)
 
 Reports
to investors, including those to be filed with the 
Commission, are maintained in accordance with the transaction 
agreements and applicable Commission requirements. Specifically, 
such reports are filed with the Commission as required by its rules 
and regulations.
 
 
 
 Applicability/Compliance:
 
 Applicable.
 
 
 
 
 
 
 1122(d)(3)(i)(D)
 
 Reports
to investors, including those to be filed with the Commission, are
maintained in accordance with the transaction agreements and applicable
Commission requirements. Specifically, such reports agree with
investors’ or the trustee’s records as to the total unpaid principal
balance and number of pool assets serviced by the servicer.
 
 
 
 
 
 
 
 
 Applicability/Compliance:
 
 Applicable.
 
 
 
 
 
 
 1122(d)(3)(ii)
 
 Amounts
due to investors are allocated and remitted in accordance 
with time frames, distribution priority and other terms set forth in 
the transaction agreements.
 
 
 
 Applicability/Compliance:
 
 Not
applicable.
 
 
 
 
 
 
 1122(d)(3)(iii)
 
 Disbursements
made to an investor are posted within two business days to the
servicer’s investor records, or such other number of days specified in
the transaction agreements.
 
 
 
 
 
 
 Applicability/Compliance:
 
 Not
applicable.
 
 
 
 
 
 
 1122(d)(3)(iv)
 
 Amounts
remitted to investors per the investor reports agree with 
canceled checks, or other form of payment, or custodial bank 
statements.
 
 
 
 Applicability/Compliance:
 
 Not
applicable.


---

v
 PENTALPHA SURVEILLANCERegulation
AB Reference
 
 Servicing
Criterion
 
 
 
 1122(d)(4)(i)
 
 Collateral
or security on pool assets is maintained as required by 
the transaction agreements or related pool asset documents.
 
 
 
 Applicability/Compliance:
 
 Not
applicable.
 
 
 
 
 
 
 1122(d)(4)(ii)
 
 Pool
assets and related documents are safeguarded as required 
by the transaction agreements.
 
 
 
 Applicability/Compliance:
 
 Not
applicable.
 
 
 
 
 
 
 1122(d)(4)(iii)
 
 Any
additions, removals or substitutions to the asset pool are 
made, reviewed and approved in accordance with any conditions 
or requirements in the transaction agreements.
 
 
 
 Applicability/Compliance:
 
 Not
applicable.
 
 
 
 
 
 
 1122(d)(4)(iv)
 
 Payments
on pool assets, including any payoffs, made in accordance with the
related pool asset documents are posted to the applicable servicer’s
obligor records maintained no more than two business days after
receipt, or such other number of days specified in the transaction
agreements, and allocated to principal, interest or other items (e g.,
escrow) in accordance with the related pool asset documents.
 
 
 
 
 
 
 Applicability/Compliance:
 
 Not
applicable.
 
 
 
 
 
 
 1122(d)(4)(v)
 
 The
servicer’s records regarding the pool assets agree with the servicer’s
records with respect to an obligor’s unpaid principal balance.
 
 
 
 
 
 
 
 
 
 
 
 Applicability/Compliance:
 
 Not
applicable.
 
 
 
 
 
 
 1122(d)(4)(vi)
 
 Changes
with respect to the terms or status of an obligor’s pool asset (e.g.,
loan modifications or re-agings) are made, reviewed and approved by
authorized personnel in accordance with the transaction agreements and
related pool asset documents.
 
 
 
 
 
 
 Applicability/Compliance:
 
 Not
applicable.


---

vi
 PENTALPHA SURVEILLANCERegulation
AB Reference
 
 Servicing
Criterion
 
 
 
 1122(d)(4)(vii)
 
 Loss
mitigation or recovery actions (e.g., forbearance plans, 
modifications and deeds in lieu of foreclosure, foreclosures and 
repossessions, as applicable) are initiated, conducted and 
concluded in accordance with the time frames or other 
requirements established by the transaction agreements.
 
 
 
 Applicability/Compliance:
 
 Applicable.
 
 
 
 
 
 
 1122(d)(4)(viii)
 
 Records
documenting collection efforts are maintained during the period a pool
asset is delinquent in accordance with the transaction agreements. Such
records are maintained on at least a monthly basis, or such other
period specified in the transaction agreements, and describe the
entity’s activities in monitoring delinquent pool assets including, for
example, phone calls, letters and payment rescheduling plans in cases
where delinquency is deemed temporary (e.g., illness or unemployment).
 
 
 
 
 
 
 Applicability/Compliance:
 
 Not
applicable.
 
 
 
 
 
 
 1122(d)(4)(ix)
 
 Adjustments
to interest rates or rates of return for pool assets with 
variable rates are computed based on the related pool asset 
documents.
 
 
 
 Applicability/Compliance:
 
 Not
applicable.
 
 
 
 
 
 
 1122(d)(4)(x)
 
 Regarding
any funds held in trust for an obligor (such as escrow 
accounts): (A) such funds are analyzed, in accordance with the 
obligor’s
pool asset documents, on at least an annual basis, or such other period
specified in the transaction agreements; (B) interest on such funds is
paid, or credited, to obligors in accordance with applicable pool asset
documents and state laws; and (C) such funds were returned to the
obligor within 30 calendar days of full repayment of the related pool
asset, or such other number of days specified in the transaction
agreements.
 
 
 
 
 
 
 Applicability/Compliance:
 
 Not
applicable.
 
 
 
 
 
 
 1122(d)(4)(xi)
 
 Payments
made on behalf of an obligor (such as tax or insurance 
payments) are made on or before the related penalty or expiration 
dates, as indicated on the appropriate bills or notices for such 
payments, provided that such support has been received by the 
servicer at least 30 calendar days prior to these dates, or such 
other number of days specified in the transaction agreements.
 
 
 
 Applicability/Compliance:
 
 Not
applicable.


---

vii
 PENTALPHA SURVEILLANCERegulation
AB Reference
 
 Servicing
Criterion
 
 
 
 1122(d)(4)(xii)
 
 Any
late payment penalties in connection with any payment to be made on
behalf of an obligor are paid from the servicer’s funds and not charged
to the obligor, unless the late payment was due to the obligor’s error
or omission.
 
 
 
 
 
 
 
 
 Applicability/Compliance:
 
 Not
applicable.
 
 
 
 1122(d)(4)(xiii)
 
 Disbursements
made on behalf of an obligor are posted within two business days to the
obligor’s records maintained by the servicer, or such other number of
days specified in the transaction agreements.
 
 
 
 
 
 
 Applicability/Compliance:
 
 Not
applicable.
 
 
 
 
 
 
 1122(d)(4)(xiv)
 
 Delinquencies,
charge-offs and uncollectible accounts are 
recognized and recorded in accordance with the transaction 
agreements.
 
 
 
 Applicability/Compliance:
 
 Not
applicable.
 
 
 
 
 
 
 1122(d)(4)(xv)
 
 Any
external enhancement or other support, identified in 
Item 1114(a)(1) through (3) or Item 1115 of Regulation AB, is 
maintained as set forth in the transaction agreements.
 
 
 
 Applicability/Compliance:
 
 Not
applicable.
 
 
 
 March 4, 2014 
__/s/
James Callahan__________________________________________

James Callahan, Executive Director 
___/s/Don Simon_________________________________________

Don Simon, Chief Operating Officer


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PENTALPHA SURVEILLANCEExhibit: Asserting Party’s 2013 Servicing Platform by Issuer and Master
Servicer
 
 
 viii
 Issuer
 Platform
and Public Name of
 Securitization
 
 Master
Servicer
 
 
 
 GS
Mortgage Securities 
Corporation II
 Commercial
Mortgage Pass-Through 
Certificates, Series 2011-GC5
 Wells
Fargo Bank, National 
Association
 
 
 
 J.P.
Morgan Chase 
Commercial Mortgage 
Securities, Corp.
 J.P.
Morgan Chase Commercial 
Mortgage Securities Trust 2011-C5
 Midland
Loan Services, a 
division of PNC Bank, National 
Association
 
 
 
 Wells
Fargo Commercial 
Mortgage Securities, Inc.
 Commercial
Mortgage Pass-Through 
Certificates, Series 2012-C6
 Wells
Fargo Bank, National 
Association
 
 
 
 J.P.
Morgan Chase 
Commercial Mortgage 
Securities, Corp.
 J.P.
Morgan Chase Commercial 
Mortgage Securities Trust 2012-C6 
Commercial Mortgage Pass-Through 
Certificates, Series 2012-C-6
 Wells
Fargo Bank, National 
Association
 
 
 
 Deutsche
Mortgage & Asset 
Receiving Corporation
 COMM
2012-CCRE1 Commercial 
Mortgage Pass-Through Certificates
 Wells
Fargo Bank, National 
Association
 
 
 
 UBS
Commercial Mortgage 
Securitization Corp.
 UBS-Barclays
Commercial Mortgage 
Trust 2012-C2, Commercial 
Mortgage Pass-Through Certificates, 
Series 2012-C2
 Wells
Fargo Bank, National 
Association
 
 
 
 Wells
Fargo Commercial 
Mortgage Securities, Inc.
 Commercial
Mortgage Pass-Through 
Certificates, Series 2012-C8
 Wells
Fargo Bank, National 
Association
 
 
 
 J.P.
Morgan Chase 
Commercial Mortgage 
Securities Corp.
 J.P.
Morgan Chase Commercial 
Mortgage Securities Trust 2012-C8 
Commercial Mortgage Pass-Through 
Certificates, Series 2012-C-8
 Keycorp
Real Estate Capital 
Markets, Inc.
 
 
 
 GS
Mortgage Securities 
Corporation II
 Commercial
Mortgage Pass-Through 
Certificates, Series 2012-GCJ9
 Wells
Fargo Bank, National 
Association
 
 
 
 Wells
Fargo Commercial 
Mortgage Securities, Inc.
 Commercial
Mortgage Pass-Through 
Certificates, Series 2012-C10
 Wells
Fargo Bank, National 
Association
 
 
 
 J.P.
Morgan Chase 
Commercial Mortgage 
Securities Corp.
 J.P.
Morgan Chase Commercial 
Mortgage Securities Trust 2012-LC9 
Commercial Mortgage Pass-Through 
Certificates, Series 2012-LC9
 Midland
Loan Services, a 
division of PNC Bank, National 
Association
 
 
 
 Wells
Fargo Commercial 
Mortgage Securities, Inc.
 Commercial
Mortgage Pass-Through 
Certificates, Series 2013-C12
 Wells
Fargo Bank, National 
Association
 
 
 
 Citigroup
Commercial 
Mortgage Securities, Inc.
 Commercial
Mortgage Pass-Through 
Certificates, Series 2013-GCJ11
 Wells
Fargo Bank, National 
Association


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PENTALPHA SURVEILLANCEExhibit: Asserting Party’s 2013 Servicing Platform by Issuer and Master
Servicer
 
 
 ix
 Issuer
 Platform
and Public Name of
 Securitization
 
 Master
Servicer
 
 
 
 Wells
Fargo Commercial 
Mortgage Securities, Inc.
 Commercial
Mortgage Pass-Through 
Certificates, Series 2013-C14
 Wells
Fargo Bank, National 
Association
 
 
 
 J.P.
Morgan Chase 
Commercial Mortgage 
Securities, Corp.
 J.P.
Morgan Chase Commercial 
Mortgage Securities Trust 2013-
LC11 Commercial Mortgage Pass-
Through Certificates, Series 2013-
LC11
 Midland
Loan Services, a 
division of PNC Bank, National 
Association
 
 
 
 J.P.
Morgan Chase 
Commercial Mortgage 
Securities, Corp.
 JPMBB
Commercial Mortgage 
Securities Trust 2013-C12 
Commercial Mortgage Pass-Through 
Certificates, Series 2013-C12
 Midland
Loan Services, a 
division of PNC Bank, National 
Association
 
 
 
 J.P.
Morgan Chase 
Commercial Mortgage 
Securities, Corp.
 J.P.
Morgan Chase Commercial 
Mortgage Securities Trust 2013-C13 
Commercial Mortgage Pass-Through 
Certificates, Series 2013-C13
 Midland
Loan Services, a 
division of PNC Bank, National 
Association
 
 
 
 J.P.
Morgan Chase 
Commercial Mortgage 
Securities, Corp.
 JPMBB
Commercial Mortgage 
Securities Trust 2013-C14 
Commercial Mortgage Pass-Through 
Certificates, Series 2013-C14
 Midland
Loan Services, a 
division of PNC Bank, National 
Association
 
 
 
 GS
Mortgage Securities 
Corporation II
 Commercial
Mortgage Pass-Through 
Certificates, Series 2013-GCJ14
 Wells
Fargo Bank, National 
Association
 
 
 
 Wells
Fargo Commercial 
Mortgage Securities, Inc.
 Commercial
Mortgage Pass-Through 
Certificates, Series 2013-C16
 Wells
Fargo Bank, National 
Association
 
 
 
 J.P.
Morgan Chase 
Commercial Mortgage 
Securities, Corp.
 JPMBB
Commercial Mortgage 
Securities Trust 2013-C15 
Commercial Mortgage Pass-Through 
Certificates, Series 2013-C15
 Wells
Fargo Bank, National 
Association
 
 
 
 J.P.
Morgan Chase 
Commercial Mortgage 
Securities, Corp.
 J.P.
Morgan Chase Commercial 
Mortgage Securities Trust 2013-C16 
Commercial Mortgage Pass-Through 
Certificates, Series 2013-C16
 Wells
Fargo Bank, National 
Association
 
 
 
 Citigroup
Commercial 
Mortgage Securities, Inc.
 Commercial
Mortgage Pass-Through 
Certificates, Series 2013-GC17
 Wells
Fargo Bank, National 
Association


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PENTALPHA SURVEILLANCEExhibit: Asserting Party’s 2013 Servicing Platform by Issuer and Master
Servicerrting Party
 
 
 x
 Issuer
 Platform
and Public Name of
 Securitization
 
 Master
Servicer
 
 
 
 J.P.
Morgan Chase 
Commercial Mortgage 
Securities, Corp.
 JPMBB
Commercial Mortgage 
Securities Trust 2013-C17 
Commercial Mortgage Pass-Through 
Certificates, Series 2013-C17
 Wells
Fargo Bank, National 
Association
 
 
 
 Wells
Fargo Commercial 
Mortgage Securities, Inc.
 Commercial
Mortgage Pass-Through 
Certificates, Series 2013-C18
 Wells
Fargo Bank, National 
Association