**Management's Assertion on Compliance************Management's Assertion on Compliance with Applicable****Regulation AB Servicing Criteria**1. Rialto Capital Advisors, LLC ("Rialto"), the Special Servicer in the agreements listed on Exhibit  1  (the  "Pooling  and  Servicing  Agreements"),  is  responsible  for  assessing  compliance with the servicing criteria applicable to it under paragraph (d) of Item 1122 of Regulation AB, for  the  period  from  January  1,  2014,  up  to  and  including  December  31,  2014,  or  applicable shorter  period  there  within,  (the  "Reporting  Period"),  as  set  forth  in  Appendix  A  hereto.    The transactions  covered  by  this  report  include  the  transactions  listed  on  Exhibit  1  that  are commercial  mortgage-asset  backed  securities  transactions  for  which  Rialto  acted  as  Special Servicer  on  or  after  January  1,  2014,  or  for  the  Applicable  Certification  Period  as  listed  on Exhibit  1  (the  "Platform"),  and  were  registered  after  January  1,  2006,  with  the  Securities  and Exchange Commission pursuant to the Securities Act of 1933. 2. Rialto  has  engaged  certain  vendors  (the  "Vendors")  to  perform  specific,  limited,  or scripted  activities,  and  Rialto  elects  to  take  responsibility  for  assessing  compliance  with  the servicing criteria, or portion of the servicing criteria, applicable to such Vendors' activities as set forth in Appendix A hereto. Rialto has determined  its Vendors are not "servicers" as defined in Item 1101 (j) of Regulation AB and asserts that it has policies and procedures in place to provide reasonable  assurance  that  the  Vendors'  activities  comply,  in  all  material  respects,  with  the servicing criteria applicable to each vendor; 3. Except as set forth in paragraph 4 below, Rialto used the criteria set forth in paragraph (d) of Item 1122 of Regulation AB to assess the compliance with the applicable servicing criteria; 4. The criteria listed in the column titled "Inapplicable Servicing Criteria" on Appendix A hereto  are  inapplicable  to  Rialto  based  on  the  activities  it  performs,  directly  or  through  its Vendors, with respect to the Platform; 5. Rialto has complied, in all material respects, with the applicable servicing criteria as of December 31, 2014, and for the Reporting Period****with respect to the Platform taken as a whole. 6. Rialto has not identified and is not aware of any material instance of noncompliance by the  Vendors  with  the  applicable  servicing  criteria  as  of  December  31,  2014,  and  for  the Reporting Period with respect to the Platform taken as a whole;****7. Rialto has not identified any material deficiency in its policies and procedures to monitor the compliance by the Vendors with the applicable servicing criteria as of December 31, 2014, and for the Reporting Period with respect to the Platform taken as a whole;****and 8. NDB Accountants & Consultants, LLP, a registered public accounting firm, has issued an attestation report on Rialto's assessment of compliance with the applicable servicing criteria for the Reporting Period. **Management's Assertion on Compliance**Date: March 5, 2015 Name: Adam Singer Title: Managing Director Signature: /s/Adam Singer **Exhibit 1****Pooling and Servicing Agreements****Applicable Certification Period**WFRBS 2012-C8 January 1, 2014, to December 31, 2014 FDIC 2012-C1 January 1, 2014, to December 31, 2014WFCM 2012-LC5 January 1, 2014, to December 31, 2014UBS-Barclays 2012-C3 January 1, 2014, to December 31, 2014UBS-Barclays 2012-C4 January 1, 2014, to December 31, 2014GSMS 2012-GCJ9 January 1, 2014, to December 31, 2014JPMCC 2012-LC9 January 1, 2014, to December 31, 2014COMM 2013-LC6 January 1, 2014, to December 31, 2014WFRBS 2013-C12 January 1, 2014, to December 31, 2014UBS-Barclays 2013-C6 January 1, 2014, to December 31, 2014GSMS 2013-GCJ12 January 1, 2014, to December 31, 2014WFRBS 2013-C14 January 1, 2014, to December 31, 2014WFRBS 2011-C5 January 1, 2014, to December 31, 2014WFCM 2013-LC12 January 1, 2014, to December 31, 2014WFRBS 2011-C2 January 1, 2014, to December 31, 2014WFRBS 2011-C3  January 1, 2014, to December 31, 2014WFRBS 2011-C4 January 1, 2014, to December 31, 2014UBS-Citigroup 2011-C1 January 1, 2014, to December 31, 2014UBS 2012-C1 January 1, 2014, to December 31, 2014WFRBS 2012-C6 January 1, 2014, to December 31, 2014GSMS 2011-GC3 January 1, 2014, to December 31, 2014COMM 2013-LC13 January 1, 2014, to December 31, 2014WFRBS 2013-C16 January 1, 2014, to December 31, 2014GSMS 2013-GCJ16 January 1, 2014, to December 31, 2014WFRBS 2013-C17 January 1, 2014, to December 31, 2014GSMS 2012-GC6 January 1, 2014, to December 31, 2014MSBAM 2013-C13 January 1, 2014, to December 31, 2014COMM 2014-CCRE14 January 22, 2014, to December 31, 2014MSBAM 2014-C14 February 14, 2014, to December 31, 2014WFRBS 2014-LC14 February 20, 2014, to December 31, 2014COMM 2014-LC15 March 25, 2014, to December 31, 2014WFRBS 2014-C20 May 13, 2014, to December 31, 2014COMM 2014-CCRE18 June 27, 2014, to December 31, 2014CGCMT 2014-GC23 August 7, 2014, to December 31, 2014MSBAM 2014-C17 August 14, 2014, to December 31, 2014**Management's Assertion on Compliance**COMM 2014-UBS5 September 23, 2014, to December 31, 2014MSBAM 2014-C18 September 29, 2014, to December 31, 2014COMM 2012-CCRE4 October 6, 2014, to December 31, 2014COMM 2012-LC4 October 6, 2014, to December 31, 2014WFRBS 2014-C24 November 18, 2014, to December 31, 2014JPMBB 2014-C25 November 24, 2014, to December 31, 2014LCCM 2014-909 June 23, 2014, to December 31, 2014 MLMI 1998-C3 June 19, 2014, to December 31, 2014 Carefree Portfolio Trust 2014-CARE MZ A November 26, 2014 to December 31, 2014 WFCM 2014-LC18 December 30, 2014, to December 31, 2014**Management's Assertion on Compliance**APPENDIX A **SERVICING CRITERIA************Reference****Criteria****Performed****by****Servicer****Inapplicable****Servicing****Criteria****General Servicing Considerations**1122(d)(1)(i) Policies and procedures are instituted to monitor any performance or other triggers and events of default in accordance with the transaction agreements. **X******1122(d)(1)(ii) If any material servicing activities are outsourced to third parties, policies and procedures are instituted to monitor the third party's performance and compliance with such servicing activities. ******X******1122(d)(1)(iii) Any requirements in the transaction agreements to maintain a back-up servicer for the [pool assets] are maintained. ******X**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. ******X************Cash Collection and Administration**********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 following receipt, or such other number of days specified in the transaction agreements. **X1**********1122(d)(2)(ii) Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel. **X**********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. **X**********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. **X******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 Rule 13k-1(b)(1) of the Securities Exchange Act. **X******1122(d)(2)(vi) Unissued checks are safeguarded so as to prevent unauthorized access. **X******1122(d)(2)(vii) Reconciliations are prepared on a monthly basis for all asset-backed securities related bank accounts, including custodial accounts and related bank clearing accounts. These reconciliations are (A) mathematically accurate; (B) prepared within 30 calendar days after the bank statement cutoff date, or such other number of days specified in the transaction agreements; (C) reviewed and approved by someone other than the person who prepared the reconciliation; and (D) contain explanations for reconciling items. These reconciling items are resolved within 90 calendar days of their original identification, or such other number of days specified in the transaction agreements. **********************X********Management's Assertion on Compliance********SERVICING CRITERIA************Reference****Criteria****Performed****by****Servicer****Inapplicable****Servicing****Criteria****Investor Remittances and Reporting**********1122(d)(3)(i) Reports to investors, including those to be filed with the Commission, are maintained in accordance with the transaction agreements and applicable Commission requirements. Specifically, such reports (A) are prepared in accordance with timeframes and other terms set forth in the transaction agreements; (B) provide information calculated in accordance with the terms specified in the transaction agreements; (C) are filed with the Commission as required by its rules and regulations; and (D) agree with investors' or the trustee's records as to the total unpaid principal balance and number of [pool assets] serviced by the Servicer. **X2******1122(d)(3)(ii) Amounts due to investors are allocated and remitted in accordance with timeframes, distribution priority and other terms set forth in the transaction agreements. ******X**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. ******X**1122(d)(3)(iv) Amounts remitted to investors per the investor reports agree with cancelled checks, or other form of payment, or custodial bank statements. ******X****Pool Asset Administration**********1122(d)(4)(i) Collateral or security on [pool assets] is maintained as required by the transaction agreements or related mortgage loan documents. **X******1122(d)(4)(ii) [pool asset] and related documents are safeguarded as required by the transaction agreements **X******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. **X******1122(d)(4)(iv) Payments on [pool assets], including any payoffs, made in accordance with the related [pool asset] documents are posted to the 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. ******X3**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. ******X**1122(d)(4)(vi) Changes with respect to the terms or status of an obligor's [pool assets] (e.g., loan modifications or re-agings) are made, reviewed and approved by authorized personnel in accordance with the transaction agreements and related pool asset documents. **X******1122(d)(4)(vii) 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 timeframes or other requirements established by the transaction agreements. **********X******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). ******************X********Management's Assertion on Compliance********SERVICING CRITERIA************Reference****Criteria****Performed****by****Servicer****Inapplicable****Servicing****Criteria**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. ******X**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 are returned to the obligor within 30 calendar days of full repayment of the related [pool assets], or such other number of days specified in the transaction agreements. ******X**1122(d)(4)(xi) Payments made on behalf of an obligor (such as tax or insurance payments) are made on or before the related penalty or expiration dates, as indicated on the 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. ******X**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. ******X**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. ******X**1122(d)(4)(xiv) Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction agreements. ******X4******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. ******X**1)Rialto  Capital  Advisors,  LLC  performs  the  activities  pertaining  to  these  criteria,  except  for  specific,  limited  activities performed by its third party property managers relating to REO Property, if any.  Rialto has elected to take responsibility for assessing compliance with these servicing criteria with respect to the activities of its third party property managers.   2)Only items (A) and (B) of the Servicing Criteria are applicable to Rialto Capital Advisors, LLC as special servicer.  Items (C) and  (D)  are  inapplicable  as  the  responsibility  for  filing  reports  with  the  Commission  and  agreeing  totals  to  the  Servicer records rests with the Trustee and/or Certificate Administrator, as applicable.  3)Primary responsibility for processing borrower payments  rests with the Master Servicer, however, Rialto Capital Advisors, LLC  may  from  time  to  time  receive  payments  on  an  exception  basis  which  are  forwarded  to  the  Master  Servicer  in accordance with such criterion. 4)Rialto  Capital  Advisors,  LLC  provides  the  applicable  Master  Servicer  relating  to  each  deal  with  the  final  recovery determination and data utilized to complete IRS Form 1099C on loans with charge-offs, however, the ultimate responsibility for  adjusting  the  loan  record,    reporting  to  the  IRS,  and  delivering  1099C  Forms  to  the  borrower  rests  with  the  Master Servicer.