Management’s
Assertion on Compliance with Applicable Regulation
AB Servicing Criteria  1.
    Rialto
    Capital Advisors, LLC (the “Asserting Party”) is responsible for assessing compliance with the servicing criteria
    applicable to it under paragraph (d) of Item 1122 of Regulation AB, as of and for the 12-month period ending December 31,
    2021 (the “Reporting Period”), as set forth in Appendix A hereto. The transactions covered by this report, include
    commercial mortgage-asset-backed securities transactions, as listed on Exhibit 1 hereto, for which the Asserting Party served
    as special servicer, and that were registered with the Securities and Exchange Commission pursuant to the Securities Act of
    1933 (the “Platform”);  2.
    The
    Asserting Party has engaged certain vendors, which are not servicers as defined in Item 1101(j) of Regulation AB (the “Vendors”),
    to perform specific, limited or scripted activities, and the Asserting Party 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;  3.
    Except
    as set forth in paragraph 4 below, the Asserting Party 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
    the Asserting Party based on the activities it performs, directly or through its Vendors, with respect to the Platform;  5.
    The
    Asserting Party has complied, in all material respects, with the applicable servicing criteria as of December 31, 2021 and
    for the Reporting Period with respect to the Platform taken as a whole;  6.
    The
    Asserting Party 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, 2021 and for the Reporting Period with respect to the Platform taken as a whole;  7.
    The
    Asserting Party 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, 2021 and for the Reporting Period with respect to the Platform
    taken as a whole; and  8.
    Deloitte
    & Touche LLP, an independent registered public accounting firm, has issued an attestation report on the Asserting Party’s
    assessment of compliance with the applicable servicing criteria for the Reporting Period.  February
17, 2022  Name:
Adam Singer  Title:
Managing Director  Signature:
    /s/ Adam
    Singer












Exhibit 1  Pooling
    and Servicing Agreements
    Applicable
    Certification PeriodWFRBS
    2012-C8
    January
    1, 2021 to December 31, 2021WFCM
    2012-LC5
    January
    1, 2021 to December 31, 2021UBS-Barclays
    2012-C3
    January
    1, 2021 to December 31, 2021UBS-Barclays
    2012-C4
    January
    1, 2021 to December 31, 2021GSMS
    2012-GCJ9
    January
    1, 2021 to December 31, 2021JPMCC
    2012-LC9
    January
    1, 2021 to December 31, 2021COMM
    2013-LC6
    January
    1, 2021 to December 31, 2021WFRBS
    2013-C12
    January
    1, 2021 to December 31, 2021UBS-Barclays
    2013-C6
    January
    1, 2021 to December 31, 2021GSMS
    2013-GCJ12
    January
    1, 2021 to December 31, 2021WFRBS
    2013-C14
    January
    1, 2021 to December 31, 2021WFRBS
    2011-C5
    January
    1, 2021 to December 31, 2021WFCM
    2013-LC12
    January
    1, 2021 to December 31, 2021WFRBS
    2011-C2
    January
    1, 2021 to December 31, 2021WFRBS
    2011-C3
    January
    1, 2021 to December 31, 2021WFRBS
    2011-C4
    January
    1, 2021 to December 31, 2021UBS-Citigroup
    2011-C1
    January
    1, 2021 to December 31, 2021UBSCM
    2012-C1
    January
    1, 2021 to December 31, 2021WFRBS
    2012-C6
    January
    1, 2021 to December 31, 2021GSMS
    2011-GC3
    January
    1, 2021 to December 31, 2021COMM
    2013-LC13
    January
    1, 2021 to December 31, 2021WFRBS
    2013-C16
    January
    1, 2021 to December 31, 2021GSMS
    2013-GCJ16
    January
    1, 2021 to December 31, 2021WFRBS
    2013-C17
    January
    1, 2021 to December 31, 2021GSMS
    2012-GC6
    January
    1, 2021 to December 31, 2021MSBAM
    2013-C13
    January
    1, 2021 to December 31, 2021COMM
    2014-CCRE14
    January
    1, 2021 to December 31, 2021MSBAM
    2014-C14
    January
    1, 2021 to December 31, 2021WFRBS
    2014-LC14
    January
    1, 2021 to December 31, 2021COMM
    2014-LC15
    January
    1, 2021 to December 31, 2021WFRBS
    2014-C20
    January
    1, 2021 to December 31, 2021COMM
    2014-CCRE18
    January
    1, 2021 to December 31, 2021






2







CGCMT
    2014-GC23
    January
    1, 2021 to December 31, 2021MSBAM
    2014-C17
    January
    1, 2021 to December 31, 2021COMM
    2014-UBS5
    January
    1, 2021 to December 31, 2021MSBAM
    2014-C18
    January
    1, 2021 to December 31, 2021COMM
    2012-CCRE4
    January
    1, 2021 to December 31, 2021WFRBS
    2014-C24
    January
    1, 2021 to December 31, 2021JPMBB
    2014-C25
    January
    1, 2021 to December 31, 2021LCCM
    2014-909
    January
    1, 2021 to December 31, 2021WFCM
    2014-LC18
    January
    1, 2021 to December 31, 2021COMM
    2015-DC1
    January
    1, 2021 to December 31, 2021GSMS
    2015-GC28
    January
    1, 2021 to December 31, 2021WFCM
    2015-C27
    January
    1, 2021 to December 31, 2021WFCM
    2015-LC20
    January
    1, 2021 to December 31, 2021WFCM
    2015-NXS1
    January
    1, 2021 to December 31, 2021CSAIL
    2015-C2
    January
    1, 2021 to December 31, 2021WFCM
    2015-NXS2
    January
    1, 2021 to December 31, 2021COMM
    2015-PC1
    January
    1, 2021 to December 31, 2021CSAIL
    2015-C3
    January
    1, 2021 to December 31, 2021WFCM
    2015-SG1
    January
    1, 2021 to December 31, 2021WFCM
    2015-LC22
    January
    1, 2021 to December 31, 2021COMM
    2015-CCRE27
    January
    1, 2021 to December 31, 2021WFCM
    2015-NXS4
    January
    1, 2021 to December 31, 2021MSCI
    2015-UBS8
    January
    1, 2021 to December 31, 2021CSAIL
    2016-C5
    January
    1, 2021 to December 31, 2021WFCM
    2016-C32
    January
    1, 2021 to December 31, 2021WFCM
    2016-NXS5
    January
    1, 2021 to December 31, 2021CGCMT
    2015-GC27
    January
    1, 2021 to December 31, 2021WFCM
    2016-C33
    January
    1, 2021 to December 31, 2021MSBAM
    2015-C20
    January
    1, 2021 to December 31, 2021CFCRE
    2016-C4
    January
    1, 2021 to December 31, 2021BACM
    2016-UBS10
    January
    1, 2021 to December 31, 2021SGCMS
    2016-C5
    January
    1, 2021 to December 31, 2021WFCM
    2016-BNK1
    January
    1, 2021 to December 31, 2021CD
    2016-CD1
    January
    1, 2021 to December 31, 2021GSMS
    2016-GS3
    January
    1, 2021 to December 31, 2021MSBAM
    2016-C31
    January
    1, 2021 to December 31, 2021




3







CGCMT
    2016-C3
    January
    1, 2021 to December 31, 2021CFCRE
    2016-C6
    January
    1, 2021 to December 31, 2021CSAIL
    2016-C7
    January
    1, 2021 to December 31, 2021MSCI
    2016-UBS12
    January
    1, 2021 to December 31, 2021BBCMS
    2017-C1
    January
    1, 2021 to December 31, 2021GSMS
    2017-GS5
    January
    1, 2021 to December 31, 2021CGCMT
    2017-P7
    January
    1, 2021 to December 31, 2021BANK
    2017-BNK4
    January
    1, 2021 to December 31, 2021CD
    2017-CD4
    January
    1, 2021 to December 31, 2021CFCRE
    2017-C8
    January
    1, 2021 to December 31, 2021JPMCC
    2017-JP6
    January
    1, 2021 to December 31, 2021CD
    2017-CD5
    January
    1, 2021 to December 31, 2021GSMS
    2017-GS7
    January
    1, 2021 to December 31, 2021BANK
    2017-BNK7
    January
    1, 2021 to December 31, 2021CSAIL
    2017-CX9
    January
    1, 2021 to December 31, 2021UBSCM
    2017-C4
    January
    1, 2021 to December 31, 2021UBSCM
    2017-C6
    January
    1, 2021 to December 31, 2021BANK
    2017-BNK9
    January
    1, 2021 to December 31, 2021GSMS
    2018-GS9
    January
    1, 2021 to December 31, 2021UBSCM
    2018-C9
    January
    1, 2021 to December 31, 2021MSBAM
    2012-C5
    January
    1, 2021 to December 31, 2021WFCM
    2018-C44
    January
    1, 2021 to December 31, 2021UBSCM
    2018-C10
    January
    1, 2021 to December 31, 2021WFCM
    2015-C30
    January
    1, 2021 to December 31, 2021JPMBB
    2014-C23
    January
    1, 2021 to December 31, 2021MSBAM
    2014-C19
    January
    1, 2021 to December 31, 2021COMM
    2015-LC21
    January
    1, 2021 to December 31, 2021MSBAM
    2016-C29
    January
    1, 2021 to December 31, 2021JPMBB
    2015-C31
    January
    1, 2021 to December 31, 2021GSMS
    2018-GS10
    January
    1, 2021 to December 31, 2021CD
    2018-CD7
    January
    1, 2021 to December 31, 2021GSMS
    2018-3PCK
    January
    1, 2021 to December 31, 2021BANK
    2018-BNK14
    January
    1, 2021 to December 31, 2021DBGS
    2018-C1
    January
    1, 2021 to December 31, 2021CSAIL
    2018-C14
    January
    1, 2021 to December 31, 2021UBSCM
    2018-C14
    January
    1, 2021 to December 31, 2021




4









ILPT
    2019-SURF
    January
    1, 2021 to December 31, 2021MSCI
    2019-L2
    January
    1, 2021 to December 31, 2021WFCM
    2019-C50
    January
    1, 2021 to December 31, 2021BANK
    2019-BNK18
    January
    1, 2021 to December 31, 2021WFCM
    2015-P2
    January
    1, 2021 to December 31, 2021BMARK
    2019-B11
    January
    1, 2021 to December 31, 2021CGCMT
    2019-GC41
    January
    1, 2021 to December 31, 2021BBCMS
    2019-C4
    January
    1, 2021 to December 31, 2021COMM
    2014-CCRE15
    January
    1, 2021 to December 31, 2021UBSCM
    2019-C17
    January
    1, 2021 to December 31, 2021BANK
    2019-BNK21
    January
    1, 2021 to December 31, 2021CGCMT
    2019-GC43
    January
    1, 2021 to December 31, 2021CSAIL
    2019-C18
    January
    1, 2021 to December 31, 2021COMM
    2019-GC44
    January
    1, 2021 to December 31, 2021UBSCM
    2019-C18
    January
    1, 2021 to December 31, 2021WFCM
    2020-C55
    January
    1, 2021 to December 31, 2021UBSBB
    2012-C2
    January
    1, 2021 to December 31, 2021BBCMS
    2020-C7
    January
    1, 2021 to December 31, 2021CSMC
    2020-NET
    January
    1, 2021 to December 31, 2021BMARK
    2020-B19
    January
    1, 2021 to December 31, 2021BMARK
    2020-B22
    January
    1, 2021 to December 31, 2021CSMC
    2020-FACT
    January
    1, 2021 to December 31, 2021CLNY
    2019-IKPR
    January
    1, 2021 to December 31, 2021BANK
    2020-BNK29
    January
    1, 2021 to December 31, 2021WFCM
    2020-C58
    January
    1, 2021 to December 31, 2021FSRIA
    2019-FL1
    January
    1, 2021 to December 31, 2021BANK
    2021-BNK32
    March
    24, 2021 to December 31, 2021BSST
    2021-1818
    March
    30, 2021 to December 31, 2021BMARK
    2021-B25
    April
    29, 2021 to December 31, 2021FSRIA
    2021-FL2
    May
    5, 2021 to December 31, 2021MSC
    2007-T27
    May
    19, 2021 to December 31, 2021BANK
    2021-BNK33
    May
    20, 2021 to December 31, 2021BBCMS
    2021-C10
    July
    15, 2021 to December 31, 2021CSMC
    2021-ADV
    August
    5, 2021 to December 31, 2021BANK
    2021-BNK36
    October
    7, 2021 to December 31, 2021FSRIA
    2021-FL3
    November
    4, 2021 to December 31, 2021






5







BACM
    2017-BNK3
    November
    15, 2021 to December 31, 2021BMARK
    2021-B31
    December
    22, 2021 to December 31, 2021




6







APPENDIX
A  Servicing
    CriteriaReference
    Criteria
    Performed
    by Servicer
    InapplicableServicing CriteriaGeneral Servicing Considerations1122(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.
    X1122(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.
    X11122(d)(1)(iii)
    Any
    requirements in the transaction agreements to maintain a back-up servicer for the pool assets are maintained.
    
    X1122(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.
    X1122(d)(i)(v)
    Aggregation
    of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information.
    X




7







Cash
    Collection and Administration1122(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.
    X1122(d)(2)(ii)
    Disbursements
    made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.
    
    X31122(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.
    
    X31122(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.
    X1122(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.
    X1122(d)(2)(vi)
    Unissued
    checks are safeguarded so as to prevent unauthorized access.
    X1122(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




8







Investor
    Remittances and Reporting1122(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.
    X41122(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.
    
    X1122(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.
    
    X1122(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




9







Pool
    Asset Administration1122(d)(4)(i)
    Collateral
    or security on Pool assets is maintained as required by the transaction agreements or related mortgage loan documents.
    X1122(d)(4)(ii)
    Pool
    asset and related documents are safeguarded as required by the transaction agreements
    X1122(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.
    X1122(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.
    X21122(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.
    
    X1122(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.
    X1122(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.
    X1122(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).
    X1122(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




10







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.
    
    X1122(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.
    
    X1122(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.
    
    X1122(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.
    
    X1122(d)(4)(xiv)
    Delinquencies,
    charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.
    
    X1122(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  X1-
Rialto Capital Advisors, LLC performs the activities pertaining to this criterion, except for specific, limited activities performed
by (a) its third-party property managers relating to REO Property, if any; and (b) RERC, LLC, a SitusAMC Company, pursuant to
a Staffing Agreement, in which RERC provides RCA with real estate consultant and valuation professionals to perform support functions
in connection with property appraisals. Rialto has elected to take responsibility for assessing compliance with these servicing
criteria with respect to the activities of its third-party property managers and RERC, LLC.  X2-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 criteria.
The criteria is marked applicable as Rialto Capital Advisors, LLC had instances or activity relating to this criteria for the
calendar year of January 1, 2021 to December 31, 2021.  X3-Rialto
Capital Advisors, LLC performs the activities under the criteria, however the related criteria are marked inapplicable as Rialto
did not have instances/activity during the calendar year of January 1, 2021 and ending on December 31, 2021 relating to the criteria.




11









X4-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.




12